Reservoir has sued Suno, alleging that the AI music company copied 1,050 of Reservoir’s compositions to train its models without permission.
The complaint, obtained by Music Business Worldwide, was filed on Wednesday (October 21) in the US District Court for the Northern District of California.
Reservoir also filed a separate lawsuit against Anthropic in the same court on the same day.
Reservoir accuses Suno of having “built its entire business model based on copyright infringement at a scale never seen before.”
The plaintiffs are Reservoir Media Management, Inc., its UK subsidiary Reservoir Media Management (UK) Limited, and Shapiro, Bernstein & Co. Limited, which is wholly owned by the UK entity.
Songs in Reservoir‘s catalog named in the complaint include Joni Mitchell‘s Both Sides Now, Johnny Cash‘s Ring of Fire, Madonna‘s Papa Don’t Preach, and Evanescence‘s Bring Me to Life.
An exhibit to the complaint lists 1,050 compositions whose US copyrights Reservoir says it owns 100% or exclusively controls.
Reservoir is seeking actual damages and Suno‘s profits or, alternatively, statutory damages of up to USD $150,000 per work willfully infringed.
The complaint puts that total at $157.5 million for the 1,050 works.
Two further counts, brought under the Digital Millennium Copyright Act over the alleged circumvention of access controls and removal of copyright management information, carry stated totals of $2.625 million and $26.25 million.
Across the three counts, the figures pleaded come to just over $186 million.
Reservoir is also seeking an injunction and the impoundment or destruction of unauthorized copies of its works, “including copies retained in training datasets, internal repositories, model weights, and server infrastructure.”
“Suno‘s business model was admittedly and clearly: infringe now, make billions by being the first mover, and try to settle on the cheap later,” the complaint states. “Seeking forgiveness is clearly more profitable than permission, which they obviously could have done but consciously chose not to do.”
The filing cites Suno‘s licensing agreements with Warner Music Group, BMG, and Believe as evidence against it.
By striking those deals, the complaint argues, Suno “has all but admitted that there is a functioning market for licensing music and sound recordings for training data.”
“Suno’s business model was admittedly and clearly: infringe now, make billions by being the first mover, and try to settle on the cheap later.”
Reservoir, complaint against Suno
The complaint also draws on Suno source code that was obtained by a hacker and reported on by 404 Media in July.
Citing that report, Reservoir alleges that Suno used proxy services acquired from Bright Data to scrape “millions of songs and lyrics” from YouTube Music, Deezer, and Genius.
According to the complaint, a YouTube Music workflow in the code saved 2,057,486 artist records as output, while a Genius workflow recorded 6,980,653 “successful song-page processing records.”
The complaint alleges that several of the works at issue appear in the leaked code, including Both Sides Now, Ring of Fire, and Ben Harper‘s Diamonds on the Inside.
It also alleges that Suno trained on cover versions alongside the original recordings: “The Suno code puts a cover recording followed by the ‘main’ (original) recording of the same song when creating a training data instance.”
When 404 Media reported the hack, Suno said the incident had primarily involved “outdated source code that is no longer in use at Suno.”
On outputs, Reservoir argues that Suno‘s guardrails against imitating existing artists “are easily circumvented.”
The complaint says Suno will not accept a prompt that includes the name Reba McEntire, but will allow a prompt for a female-vocal country song “in the style of Reba McIntyre [sic].”
Elsewhere, the complaint alleges that, with v6, Suno now accepts prompts that name artists and “redirect[s]” them “toward descriptive musical characteristics.”
It adds that a prompt for “a Miles Davis like Blues track with horns and a quartet” produced two tracks without lyrics, both named Blue Note Quartet, which Reservoir alleges are “clearly inspired by and are unlicensed derivative works of Miles Davis music.” The complaint lists Davis’s So What among Reservoir‘s works.
The filing argues that fair use does not apply, citing the Northern District of California‘s June 2025 ruling in Bartz v. Anthropic, which held that keeping a permanent library of pirated copies was not fair use, and the Third Circuit‘s September 29 decision in Thomson Reuters v. ROSS Intelligence.
“There is simply nothing fair about a company using theft to build for purely commercial purposes a multi-billion-dollar business while those from whom it steals receive nothing,” Reservoir‘s complaint states.
Reservoir is represented by Richard S. Busch of Adams & Reese, who won the Blurred Lines case for Marvin Gaye‘s family while at King & Ballow.
Busch and his colleagues, with Skaggs Faucette LLP as local counsel, have also sued Suno in the same court on behalf of Round Hill Music on August 17 and Regional Mexican label Gerencia 360 on August 31.
Both of those complaints originally named data-scraping firm Bright Data as a defendant, but on Monday (October 19) Round Hill and Gerencia 360 voluntarily dismissed their claims against it, without prejudice, and filed amended complaints against Suno alone.
Reservoir‘s complaint likewise names only Suno, although it alleges that Suno used Bright Data‘s tools and services to circumvent access controls.
The Reservoir filing also cites Suno‘s loss to German collecting society GEMA at the Munich Regional Court on July 31.
That ruling was a first-instance decision, and Suno said at the time that it was “evaluating all available options, including an appeal.”
Universal Music Group and Sony Music Entertainment, which first sued Suno in June 2024, filed a second lawsuit against the company on September 18 covering 60,202 recordings.
Warner Music Group settled with Suno in November 2025, and BMG and Believe have since struck licensing deals with the platform, ahead of the launch of its v6 models on September 9.
Suno raised more than $400 million in June at a valuation of $5.4 billion.
Reservoir, whose parent company Reservoir Media, Inc. is listed on the Nasdaq, describes itself in the complaint as “the first female-founded and -led publicly traded independent music company in the United States.”
MBW has contacted Suno for comment.Music Business Worldwide