UMG Recordings and Sony Music Entertainment are seeking leave to file a Second Amended Complaint to add 61,026 more works to the list of works Suno allegedly infringed, plus a claim for circumvention of technological protection measures under the DMCA, Section 1201.

The plaintiffs contend they obtained relevant information of works infringed from discovery of Suno’s training materials, which were allegedly acquired by “stream ripping” audio files from YouTube videos.
DOWNLOAD THE REDLINED VERSION OF THE SECOND AMENDED COMPLAINT
DOWNLOAD UMG’S BRIEF IN SUPPORT OF MOTION FOR LEAVE
DOWNLOAD THE WORKS LIST