Who is suing
Reservoir Media Management, Inc. is a Delaware corporation based in New York. The other two plaintiffs are English companies it owns, directly or through its UK subsidiary (¶¶ 10-12). The complaint describes Reservoir as an independent music company whose parent, Reservoir Media, Inc., trades on NASDAQ (¶¶ 1, 13). It says Reservoir owns or controls copyrights in tens of thousands of compositions and master recordings (¶ 21).
The suit covers 853 registered compositions listed in Exhibit A, in which Reservoir says it owns 100% of, or exclusively controls, the U.S. copyright (¶¶ 2, 14). The works named in the text include “Big Yellow Taxi” and “Both Sides Now,” “Lush Life,” “Ring of Fire,” “Papa Don’t Preach,” “Conga” and four Evanescence songs (¶ 2). Reservoir licenses lyric display to aggregators such as LyricFind and Musixmatch, on terms that require the song title, songwriters and other identifying information to be shown. The complaint treats that information as the CMI at issue (¶ 26).
Five theories of liability
| Theory | What the complaint alleges | Paragraphs |
|---|---|---|
| Acquisition and training | Lyrics reached Anthropic through scraping and through Common Crawl, “Book3,” The Pile and its YouTube Subtitles subset, the Internet Archive, and books torrented from Library Genesis and PiLiMi. Each new Claude model is pleaded as a new infringing copy. The complaint also says at least one Claude model was trained on synthetic data, or given feedback, by a model trained on pirated text. | ¶¶ 30-43, 80 |
| Indefinite retention | Keeping the works in a permanent, all-purpose internal repository is pleaded as standalone infringement, relying on Bartz’s holding that such retention is not fair use. | ¶¶ 44-47, 73, 81 |
| Removal of CMI | Anthropic is said to have tested Readability, Newspaper and jusText and chosen Newspaper because it removed more CMI. Each stage of the pipeline (cleaning, tokenization, encoding) is pleaded as a further copy that removed CMI. | ¶¶ 48-51, 93-95 |
| Outputs | Claude reproduced lyrics on request from the start. Haiku 4.5 and Sonnet 5 now decline to give lyrics but will rewrite songs “for a modern audience.” Each output is pleaded as a violation of all five § 106 rights. | ¶¶ 52-66, 83-85 |
| Circumvention | Scraping tools, which the complaint says include Newspaper, are said to have bypassed logins, paywalls, CAPTCHAs, rate limits, JavaScript rendering and robots.txt directives on licensed lyric and streaming platforms. | ¶¶ 88-89 |
The evidence the complaint relies on
Most of the factual support comes from other cases and public sources. From Bartz, the complaint cites Anthropic’s admission that at least one released Claude model was trained on data derived from YouTube subtitles in a version of The Pile (¶ 36), and the court’s findings about Library Genesis and PiLiMi (¶¶ 39, 46-47). It cites a Bartz filing for the statement that Anthropic was aware Claude 3 Opus could reconstruct training data, as reported by ETH Zurich researchers (¶ 38). For outputs, it relies on the Concord I record, including the publishers’ expert review of more than 100 Anthropic records (¶ 60); on the BMG complaint (¶ 60); and on example conversations in Anthropic’s public hh-rlhf dataset, including “Let It Go,” “Eleanor Rigby” and “Hallelujah” (¶¶ 56-59).
The allegations tied to Reservoir’s own works are narrower. The one specific source allegation is a 2011 Wayback Machine capture of a lyrics page for “Big Yellow Taxi” (¶ 37 and n. 14). Inclusion of each work in Common Crawl, “Book3,” The Pile and YouTube Subtitles is pleaded on information and belief (¶¶ 30-35). The claim that Claude has produced infringing output for all 853 works is also made on information and belief. The complaint says the user logs that would show it are held by Anthropic (¶ 65).
The only post-guardrail output quoted is an exchange in which Sonnet 5, after rewriting songs “for a modern audience,” said its renders kept “landing very close to the originals” (¶¶ 4, 64). The complaint does not name the songs or give a date. The footnote at that point cites outputs described in the Round Hill complaint for “Iris,” “I Got You (I Feel Good)” and “Total Eclipse of the Heart” (¶ 63 n. 24). None of the output examples in the complaint is identified as one of Reservoir’s 853 works.
How the complaint addresses fair use
The complaint argues against fair use before Anthropic has raised it. Its points are that Bartz held indefinite retention in a general-purpose library is not fair use (¶¶ 73, 81); that public-domain material was available for training (¶ 74); that companies and collecting societies already license music for AI training, naming ElevenLabs, Musical AI, Symphonic, Soundverse, GEMA, GCX/Rightsify and Troveo (¶ 75); and that copying by torrent shows a lack of good faith under Harper & Row (¶ 76). It also quotes Anthropic’s Head of Policy calling adversarial distillation of Anthropic’s models “IP theft” (¶ 77).
On timing, the complaint says the scale of the copying came to light only through The Atlantic’s searchable dataset tool (September 2025, extended to music in June 2026) and the filing of Concord II in January 2026 (¶ 68).
Damages math and remedies
| Count | Statutory basis | Per work | × 853 |
|---|---|---|---|
| Copyright infringement (willful) | § 504(c) | $150,000 | $127,950,000 |
| Circumvention | § 1203(c)(3)(A) | $2,500 | $2,132,500 |
| Removal of CMI | § 1203(c)(3)(B) | $25,000 | $21,325,000 |
| Sum of the maximum statutory figures pleaded | $151,407,500 |
Each row total is stated in the complaint (¶¶ 86, 91, 97) and checks: 853 × $150,000 = $127,950,000; 853 × $2,500 = $2,132,500; 853 × $25,000 = $21,325,000. The sum is ours; the complaint does not add the counts together. The DMCA figures assume one violation per work. Statutory damages are pleaded in the alternative to actual damages and profits (¶ 86; Prayer (g)). The prayer also asks for impoundment or destruction under § 503(b) of copies held in training datasets, internal repositories, model weights and server infrastructure, and for an accounting of all training data, scraping and datasets involving the works (Prayer (e)-(f)).
Same counsel, same week: compared with the Elvis complaint
Adams & Reese and Skaggs Faucette filed ABG EPE IP v. Anthropic two days later. Large parts of the two complaints use the same text: the dataset paragraphs, the Newspaper and jusText allegation, the hh-rlhf examples, the unnamed Sonnet 5 exchange, the distillation passage, the five theories and the request to impound model weights. The differences are in the plaintiff-specific facts.
| Reservoir v. Anthropic | ABG EPE IP v. Anthropic | |
|---|---|---|
| Filed | 21 Oct 2026 | 23 Oct 2026 |
| Works in suit | 853 | 274 |
| Works named as in YouTube Subtitles | None; pleaded on information and belief for each work (¶ 35) | Five, citing a published listing |
| Wayback Machine example | One work, 2011 capture (¶ 37) | Two works, 2010 captures |
| Music suits said to be pending in the district | At least five (¶ 7) | At least six |
| Statutory total for infringement | $127,950,000 | $41,100,000 |
The same plaintiffs also sued Suno, Inc. on 21 October 2026, No. 3:26-cv-12305 (Reservoir v. Suno).
Related matters
The complaint identifies these actions against Anthropic as related and pending in the district (¶ 19):
- Concord Music Group, Inc. v. Anthropic PBC, No. 5:24-cv-03811-EKL (“Concord I”)
- Concord Music Group, Inc. v. Anthropic PBC, No. 5:26-cv-00880-EKL (“Concord II”)
- BMG Rights Management (US) LLC v. Anthropic PBC, No. 5:26-cv-02334
It also cites Round Hill Music LP v. Anthropic PBC (filed 17 August 2026) for its output examples (¶ 63 n. 24).
Documents
| Date | ECF | Document | Filed by |
|---|---|---|---|
| 21 Oct 2026 | 1 | Complaint for direct copyright infringement, circumvention of protection measures, and removal or alteration of CMI | Plaintiffs |
The complaint links to the copy hosted by ChatGPT Is Eating the World. Exhibit A (the list of 853 works) is referenced in the complaint and will be added when available. Paragraph references are to the complaint.
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