IN THE UNITED STATES DISTRICT COURTFOR THE MIDDLE DISTRICT OF TENNESSEENASHVILLE DIVISIONCONCORD MUSIC GROUP, INC.; CAPITOL
CMG, INC. D/B/A ARIOSE MUSIC, D/B/A
CAPITOL CMG GENESIS, D/B/A CAPITOL
CMG PARAGON, D/B/A GREG NELSONMUSIC, D/B/A JUBILEE
COMMUNICATIONS, INC., D/B/A
MEADOWGREEN MUSIC COMPANY, D/B/A
MEAUX HITS, D/B/A MEAUX MERCY,
D/B/A RIVER OAKS MUSIC, D/B/A
SHEPHERD’S FOLD MUSIC, D/B/A
SPARROW SONG, D/B/A WORSHIPTOGETHER MUSIC, D/B/A
WORSHIPTOGETHER.COM SONGS;
UNIVERSAL MUSIC CORP. D/B/A ALMOMUSIC CORP., D/B/A CRITERION MUSIC
CORP., D/B/A GRANITE MUSIC CORP.,
D/B/A IRVING MUSIC, INC., D/B/A
MICHAEL H. GOLDSEN, INC., D/B/A
UNIVERSAL – GEFFEN MUSIC, D/B/A
UNIVERSAL MUSIC WORKS; SONGS OF
UNIVERSAL, INC. D/B/A UNIVERSAL –GEFFEN AGAIN MUSIC, D/B/A UNIVERSALTUNES; UNIVERSAL MUSIC – MGB NA
LLC D/B/A MULTISONGS, D/B/A
UNIVERSAL MUSIC – CAREERS, D/B/A
UNIVERSAL MUSIC – MGB SONGS;POLYGRAM PUBLISHING, INC. D/B/A
UNIVERSAL – POLYGRAMINTERNATIONAL TUNES, INC., D/B/A
UNIVERSAL – POLYGRAMINTERNATIONAL PUBLISHING, INC.,
D/B/A UNIVERSAL – SONGS OF
POLYGRAM INTERNATIONAL, INC.;
UNIVERSAL MUSIC – Z TUNES LLC D/B/A
NEW SPRING PUBLISHING, D/B/A
UNIVERSAL MUSIC – BRENTWOOD
BENSON PUBLISHING, D/B/A UNIVERSALMUSIC – BRENTWOOD BENSON SONGS,
D/B/A UNIVERSAL MUSIC – BRENTWOOD
BENSON TUNES, D/B/A UNIVERSALMUSIC – Z MELODIES, D/B/A UNIVERSAL

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Case No. ___________COMPLAINT AND
DEMAND FOR JURY TRIAL

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MUSIC – Z SONGS; and ABKCO MUSIC,
INC.,
Plaintiffs,
v.
ANTHROPIC PBC,
Defendant.

Plaintiffs Concord Music Group, Inc.; Capitol CMG, Inc. d/b/a Ariose Music, d/b/a
Capitol CMG Genesis, d/b/a Capitol CMG Paragon, d/b/a Greg Nelson Music, d/b/a Jubilee
Communications, Inc., d/b/a Meadowgreen Music Company, d/b/a Meaux Hits, d/b/a Meaux
Mercy, d/b/a River Oaks Music, d/b/a Shepherd’s Fold Music, d/b/a Sparrow Song, d/b/a
Worship Together Music, d/b/a Worshiptogether.com Songs; Universal Music Corp. d/b/a AlmoMusic Corp., d/b/a Criterion Music Corp., d/b/a Granite Music Corp., d/b/a Irving Music, Inc.,d/b/a Michael H. Goldsen, Inc., d/b/a Universal – Geffen Music, d/b/a Universal Music Works;
Songs of Universal, Inc. d/b/a Universal – Geffen Again Music, d/b/a Universal Tunes;
Universal Music – MGB NA LLC d/b/a Multisongs, d/b/a Universal Music – Careers, d/b/a
Universal Music – MGB Songs; Polygram Publishing, Inc. d/b/a Universal – Polygram
International Tunes, Inc., d/b/a Universal – Polygram International Publishing, Inc., d/b/a
Universal – Songs of Polygram International, Inc.; Universal Music – Z Tunes LLC d/b/a New
Spring Publishing, d/b/a Universal Music – Brentwood Benson Publishing, d/b/a Universal
Music – Brentwood Benson Songs, d/b/a Universal Music – Brentwood Benson Tunes, d/b/a
Universal Music – Z Melodies, d/b/a Universal Music – Z Songs; and ABKCO Music, Inc.
(collectively, “Publishers”), for their complaint against Defendant Anthropic PBC (“Anthropic”),

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Page 2 of 60 PageID #: 2allege, on personal knowledge as to matters relating to themselves and on information and belief
as to all other matters, as set forth below.
NATURE OF THE CASE
1.

Publishers bring this action to address the systematic and widespreadinfringement of their copyrighted song lyrics by the artificial intelligence (“AI”) company
Anthropic. In the process of building and operating AI models, Anthropic unlawfully copies anddisseminates vast amounts of copyrighted works—including the lyrics to myriad musicalcompositions owned or controlled by Publishers. Publishers embrace innovation and recognize
the great promise of AI when used ethically and responsibly. But Anthropic violates theseprinciples on a systematic and widespread basis. Anthropic must abide by well-establishedcopyright laws, just as countless other technology companies regularly do.
2.

Although the AI technology involved in this case may be complex and cutting-edge, the legal issues presented here are straightforward and long-standing. A defendant cannot
reproduce, distribute, and display someone else’s copyrighted works to build its own business
unless it secures permission from the rightsholder. This foundational rule of copyright law dates
all the way back to the Statute of Anne in 1710, and it has been applied time and time again tonumerous infringing technological developments in the centuries since. That principle does not
fall away simply because a company adorns its infringement with the words “AI.” Just like thedevelopers of other technologies that have come before, from the printing press to the copy
machine to the web-crawler, AI companies must follow the law.
3.

The recent explosion in the development of AI portends extraordinary changes in

the way people and businesses operate, including the potential for exceptional breakthroughs forCase 3:23-cv-01092

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the music and entertainment industries. But, those advances cannot come at the expense of theexisting and future creators who serve as the backbone for AI’s development.
4.

Publishers are among the world’s leading music publishers. They own or control

the copyrights to the musical compositions—including the lyrics contained therein—for
thousands of the most popular and beloved songs of all time. Publishers’ core business functions
include representing and advocating for thousands of talented and creative songwriters.
Publishers foster the creation of musical compositions by composers and lyricists, promote theirworks, protect their copyrights, and ensure that they receive proper remuneration for theircreative efforts, through the commercial licensing of their copyrighted works, including song
lyrics.
5.

Music is rooted in creativity and innovation. To succeed, Publishers innovate,

foster innovation, and partner with innovators—including entrepreneurs, start-ups, andestablished companies. Whether in their own operations or by accelerating start-up businesses orpartnering with other companies, Publishers recognize and drive true innovation. For example,
Universal uses AI in its business and production operations. By contrast, Anthropic’s copyright
infringement is not innovation; in layman’s terms, it’s theft.
6.

Anthropic is in the business of developing, operating, selling, and licensing AI

technologies. Its primary product is a series of AI models referred to as “Claude.” Anthropic
builds its AI models by scraping and ingesting massive amounts of text from the internet andpotentially other sources, and then using that vast corpus to train its AI models and generate
output based on this copied text. Included in the text that Anthropic copies to fuel its AI models
are the lyrics to innumerable musical compositions for which Publishers own or control the
copyrights, among countless other copyrighted works harvested from the internet. This

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copyrighted material is not free for the taking simply because it can be found on the internet.
Anthropic has neither sought nor secured Publishers’ permission to use their valuablecopyrighted works in this way. Just as Anthropic does not want its code taken without its
authorization, neither do music publishers or any other copyright owners want their works to be
exploited without permission.
7.

Anthropic claims to be different from other AI businesses. It calls itself an AI“safety and research” company, and it claims that, by training its AI models using a so-called“constitution,” it ensures that those programs are more “helpful, honest, and harmless.” Yet,despite its purportedly principled approach, Anthropic infringes on copyrights without regard forthe law or respect for the creative community whose contributions are the backbone of
Anthropic’s infringing service.
8.

As a result of Anthropic’s mass copying and ingestion of Publishers’ song lyrics,

Anthropic’s AI models generate identical or nearly identical copies of those lyrics, in clear
violation of Publishers’ copyrights. When a user prompts Anthropic’s Claude AI chatbot toprovide the lyrics to songs such as “A Change Is Gonna Come,” “God Only Knows,” “What a
Wonderful World,” “Gimme Shelter,” “American Pie,” “Sweet Home Alabama,” “Every Breath
You Take,” “Life Is a Highway,” “Somewhere Only We Know,” “Halo,” “Moves Like Jagger,”“Uptown Funk,” or any other number of Publishers’ musical compositions, the chatbot will
provide responses that contain all or significant portions of those lyrics.
9.

There are already a number of music lyrics aggregators and websites that serve

this same function, but those sites have properly licensed Publishers’ copyrighted works toprovide this service. Indeed, there is an existing market through which Publishers license their
copyrighted lyrics, ensuring that the creators of musical compositions are compensated andCase 3:23-cv-01092

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credited for such uses. By refusing to license the content it is copying and distributing, Anthropic
is depriving Publishers and their songwriters of control over their copyrighted works and thehard-earned benefits of their creative endeavors, it is competing unfairly against those website
developers that respect the copyright law and pay for licenses, and it is undermining existing andfuture licensing markets in untold ways.
10.

What’s more, Anthropic’s AI models generate output containing Publishers’ lyrics

even when the models are not specifically asked to do so. Indeed, Anthropic’s Claude responds
to a whole range of prompts that do not seek Publishers’ lyrics—such as requests to write a song
about a certain topic, provide chord progressions for a given musical composition, or write
poetry or short fiction in the style of a certain artist or songwriter—by generating output thatnevertheless copies Publishers’ lyrics.
11.

By copying and exploiting Publishers’ lyrics in this manner—both as the input it

uses to train its AI models and as the output those AI models generate—Anthropic directly
infringes Publishers’ exclusive rights as copyright holders, including the rights of reproduction,
preparation of derivative works, distribution, and public display. In addition, because Anthropic
unlawfully enables, encourages, and profits from massive copyright infringement by its users, it
is secondarily liable for the infringing acts of its users under well-established theories ofcontributory infringement and vicarious infringement. Moreover, Anthropic’s AI output often
omits critical copyright management information regarding these works, in further violation of
Publishers’ rights; in this respect, the composers of the song lyrics frequently do not get
recognition for being the creators of the works that are being distributed. It is unfathomable for
Anthropic to treat itself as exempt from the ethical and legal rules it purports to embrace.

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12.

Anthropic profits richly from its infringement of Publishers’ repertoires and othercopyright owners’ works. Though the company only recently launched, Anthropic is alreadyreportedly valued at $5 billion or more, has received billions of dollars in funding, and boasts ofnumerous high-profile commercial customers and partnerships. None of that would be possible
without the vast troves of copyrighted material that Anthropic scrapes from the internet andexploits as the input and output for its AI models. Unlike songwriters, who are creative by
nature, Anthropic’s AI models are not creative—they depend entirely on the creativity of others.
13.

Yet, Anthropic pays nothing to Publishers, their songwriters, or the countlessother copyright owners whose copyrighted works Anthropic uses to train its AI models.
Anthropic has never even attempted to license the use of Publishers’ lyrics.
14.

Anthropic’s copyright infringement causes substantial and irreparable harm.

Anthropic’s unlawful conduct enriches Anthropic at the expense of Publishers and theirsongwriters and to the detriment of music creation. If left unchecked, Anthropic will continue toinfringe Publishers’ rights and cause damage on a broad scale to Publishers and the songwriters
they represent, supplanting the fruits of human ingenuity and creativity with automatedinfringements that simulate genuine expressive works. Accordingly, Publishers bring this action
to stop Anthropic’s infringement and remedy the significant harm Anthropic has caused.
JURISDICTION AND VENUE
15.

This is a civil action in which Publishers seek injunctive relief and damages under

the Copyright Act, 17 U.S.C. § 101, et seq. As such, the Court has original subject matter
jurisdiction over Publishers’ copyright infringement claims pursuant to 28 U.S.C. §§ 1331 and1338(a).

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16.

This Court has specific personal jurisdiction over Anthropic pursuant to Tenn.

Code Ann. § 20-2-214. Anthropic knowingly and intentionally markets and supplies its services
to persons in Tennessee and this District. Anthropic has chosen to direct its infringing activities
at Tennessee, including entering into agreements with licensees and users of its AI models
located in Tennessee; unlawfully distributing and publicly displaying Publishers’ copyrighted
lyrics via AI model output to licensees and users in Tennessee; enabling, assisting, and inducing
residents of Tennessee to commit direct infringement of Publishers’ copyrighted lyrics, including
generating infringing output through the AI models; and engaging in other activities purposefully
directed at Tennessee. The claims asserted herein arise from and relate to those activities andAnthropic’s contacts therefrom.
17.

This Court has personal jurisdiction over Anthropic because, among other things,

Anthropic does systematic and continuous business in this District and/or has performed acts
directed at and causing harm in this District that give rise to the Complaint.
18.

Anthropic provides its highly interactive AI models to individuals in Tennessee,

including residents of this District. Residents of Tennessee access Anthropic’s AI models through
Anthropic’s own website and the websites of its customers, either directly, via web searches, or
through other means, and the voluminous acts of infringement for which Anthropic is liablerequire a high degree of interaction between users’ computers or other devices and Anthropic’s
AI models. Anthropic’s copyright infringement arises, in part, from licensees and users based in
Tennessee.
19.

Anthropic’s conduct complained of herein causes Publishers to suffer harm in

Tennessee, given that Publishers either have their principal place of business in Tennessee and/or
offices, operations, staff, and songwriters in Tennessee.

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20.

Venue is proper in this District in accordance with 28 U.S.C. §§ 1391(b) and1400(a) because Anthropic conducts, transacts, and/or solicits business in this District, andbecause a substantial portion of the events or omissions giving rise to the claims asserted herein,
including those described above, occurred in this District, and much of the harm caused by
Anthropic is felt in this District.
THE PARTIES
Plaintiff Concord
21.

Plaintiff Concord Music Group, Inc. (“Concord”) is a Delaware corporation with

its principal place of business in Nashville, Tennessee.
22.

Concord is a global, independent music publisher with rights in over 800,000

copyrighted musical works by some of the world’s most celebrated songwriters, composers, andlyricists, including, for example, “7 Rings” (as recorded by Ariana Grande) and “Humble andKind” (as recorded by Tim McGraw). Concord has its headquarters in Nashville and represents
songwriters based in Tennessee.
Plaintiff Universal
23.

Plaintiff Capitol CMG, Inc. d/b/a Ariose Music, d/b/a Capitol CMG Genesis,

d/b/a Capitol CMG Paragon, d/b/a Greg Nelson Music, d/b/a Jubilee Communications, Inc.,d/b/a Meadowgreen Music Company, d/b/a Meaux Hits, d/b/a Meaux Mercy, d/b/a River Oaks
Music, d/b/a Shepherd’s Fold Music, d/b/a Sparrow Song, d/b/a Worship Together Music, d/b/a
Worshiptogether.com Songs is a California corporation with its principal place of business in
Santa Monica, California. Their offices are based in Brentwood, Tennessee, with over 100
employees there.

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Plaintiff Universal Music Corp. d/b/a Almo Music Corp., d/b/a Criterion Music

Corp., d/b/a Granite Music Corp., d/b/a Irving Music, Inc., d/b/a Michael H. Goldsen, Inc., d/b/a
Universal – Geffen Music, d/b/a Universal Music Works is a Delaware corporation with its
principal place of business in Santa Monica, California.
25.

Plaintiff Songs of Universal, Inc. d/b/a Universal – Geffen Again Music, d/b/a

Universal Tunes is a California corporation with its principal place of business in Santa Monica,
California.
26.

Plaintiff Universal Music – MGB NA LLC d/b/a Multisongs, d/b/a Universal

Music – Careers, d/b/a Universal Music – MGB Songs is a California limited liability company
with its principal place of business in Santa Monica, California.
27.

Plaintiff Polygram Publishing, Inc. d/b/a Universal – Polygram International

Tunes, Inc., d/b/a Universal – Polygram International Publishing, Inc., d/b/a Universal – Songsof Polygram International Inc. is a Delaware corporation with its principal place of business in
Santa Monica, California.
28.

Plaintiff Universal Music – Z Tunes LLC d/b/a New Spring Publishing, d/b/a

Universal Music – Brentwood Benson Publishing, d/b/a Universal Music – Brentwood Benson
Songs, d/b/a Universal Music – Brentwood Benson Tunes, d/b/a Universal Music – Z Melodies,
d/b/a Universal Music – Z Songs is a New York limited liability company with its principal placeof business in Santa Monica, California.
29.

Plaintiffs Capitol CMG, Inc. d/b/a Ariose Music, d/b/a Capitol CMG Genesis,

d/b/a Capitol CMG Paragon, d/b/a Greg Nelson Music, d/b/a Jubilee Communications, Inc.,d/b/a Meadowgreen Music Company, d/b/a Meaux Hits, d/b/a Meaux Mercy, d/b/a River Oaks
Music, d/b/a Shepherd’s Fold Music, d/b/a Sparrow Song, d/b/a Worship Together Music, d/b/a

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Worshiptogether.com Songs; Universal Music Corp. d/b/a Almo Music Corp., d/b/a Criterion
Music Corp., d/b/a Granite Music Corp., d/b/a Irving Music, Inc., d/b/a Michael H. Goldsen,
Inc., d/b/a Universal – Geffen Music, d/b/a Universal Music Works; Songs of Universal, Inc.
d/b/a Universal – Geffen Again Music, d/b/a Universal Tunes; Universal Music – MGB NA LLC
d/b/a Multisongs, d/b/a Universal Music – Careers, d/b/a Universal Music – MGB Songs;
Polygram Publishing, Inc. d/b/a Universal – Polygram International Tunes, Inc., d/b/a Universal– Polygram International Publishing, Inc., d/b/a Universal – Songs of Polygram International,
Inc.; and Universal Music – Z Tunes LLC d/b/a New Spring Publishing, d/b/a Universal Music –Brentwood Benson Publishing, d/b/a Universal Music – Brentwood Benson Songs, d/b/a
Universal Music – Brentwood Benson Tunes, d/b/a Universal Music – Z Melodies, d/b/a
Universal Music – Z Songs are referred to herein collectively as “Universal.”
30.

The entities comprising Universal are part of Universal Music Publishing Group,

one of the largest music publishers in the world, with rights to an extensive music catalog,
representing iconic standards and hit pop songs alike. Universal Music Publishing Group has an
office in Nashville and represents songwriters based in Tennessee.
Plaintiff ABKCO
31.

Plaintiff ABKCO Music, Inc. (“ABKCO”) is a New York corporation with its

principal place of business in New York, New York.
32.

ABKCO is a leading independent music publisher. Founded over 60 years ago,

ABKCO holds rights in the catalogs of countless iconic songwriters, including Sam Cooke (forexample, “You Send Me,” as recorded by Sam Cooke) and Mick Jagger/Keith Richards (forexample, “Wild Horses,” as recorded by the Rolling Stones), among many others. ABKCO
represents songwriters based in Tennessee.

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Defendant Anthropic
33.

Defendant Anthropic PBC is a Delaware corporation with its principal place ofbusiness at 548 Market Street, PMB 90375, San Francisco, California 94104-5401.
PUBLISHERS AND THEIR COPYRIGHTS
34.

Publishers are among the world’s foremost music publishers. As music publishers,

they foster the creation and lawful exploitation of musical compositions, including the lyrics
contained therein. Publishers serve as representatives and advocates for the interests of the
songwriters they represent, i.e., lyricists and composers, who have written many of the mostwell-known and cherished songs of all time. Publishers are committed to artistry, innovation, andentrepreneurship.
35.

It takes enormous talent, energy, and resources for songwriters to create the songs

listened to by fans throughout the world. Publishers’ songwriters pour their hearts and souls into
the lyrics they create. Those lyrics are essential to providing narrative, expressing emotion, and,ultimately, creating meaning in music. Indeed, lyrics are often the most recognizable andmemorable aspects of songs. Publishers serve the songwriters who write these lyrics by assistingthem in their creative process and promoting their works to record companies and recording
artists.
36.

Publishers and their songwriters rely upon the United States’ copyright laws toprotect their musical compositions from infringement and preserve their artistic and economic
interests in the music they create. Publishers’ financial incentives to invest in songwriters and thecreation and promotion of their musical compositions flow directly from the protections affordedby copyright. Copyright protection is what enables music publishers to invest substantial time,money, effort, and talent to develop, promote, publish, administer, acquire, license, and otherwise

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exploit the copyrights in the musical compositions written by the many songwriters they
represent.
37.

Publishers own and/or control, in whole or in part, the exclusive rights to millions

of valuable musical compositions, including the compositions listed on Exhibit A, which is an
illustrative and non-exhaustive list of the musical compositions owned by Publishers that
Anthropic infringed, and which will be amended as necessary as the case proceeds.
38.

Publishers own, control, administer, or are the exclusive licensors of the

copyrights in and to these works in a variety of ways, including pursuant to agreements with the
songwriters and rightsholders.
39.

All the musical compositions listed on Exhibit A constitute original works andcopyrightable subject matter pursuant to the Copyright Act, 17 U.S.C. § 101, et seq., and they
have been duly registered with the U.S. Copyright Office. The copyrights in the musicalcompositions set forth in Exhibit A remain valid and subsisting and have been owned and/or
controlled by Publishers at all times relevant to the allegations in this Complaint.
40.

The registered copyrights for these musical compositions include the lyrics

contained therein.
41.

Publishers own and/or exclusively control the rights set forth in 17 U.S.C. § 106

of the Copyright Act with respect to the musical compositions on Exhibit A, and many more.
42.

Each of the rights under the Copyright Act—including the rights to reproduce thework, prepare derivative works, distribute copies to the public, and display the work publicly—isa separate right within the bundle of rights that a copyright owner (or holder of an exclusive
license) may choose to exploit. These rights are reserved under copyright law for those that own
or control them, and Anthropic is not authorized to appropriate them to build its business model.

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43.

Publishers work to ensure that songwriters’ creative achievements are properly

rewarded. Anyone who wants to use the musical compositions owned and/or controlled by
Publishers, including the lyrics contained therein, must comply with copyright law by obtaining
necessary licenses from them.
44.

Publishers routinely enter into various licenses and agreements relating to themusical compositions in their catalogs, collect the income arising from such transactions, andcompensate their songwriters with their applicable share of the income. Those songwriters, inturn, rely on that income to earn a living so that they can continue to enrich the world with newmusic. Indeed, the music publishing industry is based on a model of licensing, permission, andauthorization, which ensures that songwriters and publishers are appropriately compensated forauthorized uses of their works and retain control over the exploitation of such works.
45.

Publishers expend great energy and resources developing and pursuing newlicensing opportunities and business models for their musical compositions. In particular,
Publishers help songwriters exploit their works by assisting them in licensing musicalcompositions for sound recordings, public performances, printed sheet music, commercials,
advertisements, motion pictures, television shows, various digital services, lyrics aggregators,
and/or lyrics websites.
46.

Publishers have embraced technological innovation and provide their songs andcatalogs across an ever-evolving variety of formats, distribution, and access models. Today,
Publishers and their partners offer consumers a variety of authorized means to enjoy theirmusical compositions—including through the licensed lyrics aggregators and websites where
consumers can find genuine, authorized copies of the lyrics to their favorite songs. Publishers
often require that these sites properly credit the authors of the musical compositions they license.

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47.

Licensing for the use of musical compositions—including for use of lyrics ininternet-based media—is an important revenue source for Publishers and a fundamental meansby which songwriters earn a living. Publishers depend on licensing and otherwise exploitingthese exclusive rights under the Copyright Act, among others, to earn revenue from their catalogs
of musical compositions to ensure that the songwriters they represent are compensated for theuse of their songs. Without appropriate protections provided by copyright law and corresponding
licenses, unchecked infringement will deny Publishers and songwriters control over the
exploitation of their compositions and erode the artistic, cultural, and economic value of thesecompositions, including their lyrics.
48.

Publishers recognize the great potential of ethical AI as a powerful tool for the

future. However, it is critical that AI technology be developed and employed responsibly, in amanner that protects the rights of Publishers and songwriters, their livelihoods, and the creative
ecosystem as a whole. Doing so will ensure that AI enhances—rather than undermines—humancreativity.
ANTHROPIC AND ITS INFRINGING CONDUCTA.

Anthropic and Its AI Business

49.

Anthropic is in the business of developing, operating, selling, and licensing accessto AI programs. Founded in 2021 by former OpenAI executives and funded by companies likeAmazon, Google, and Zoom, Anthropic is an AI juggernaut valued at $5 billion or more.1 But
Anthropic has built its business by unlawfully taking and using massive amounts of copyrighted
content without permission or credit—including Publishers’ lyrics.

1 See, e.g., Krystal Hu and Jaiveer Shekhawat, Google-backed Anthropic raises $450 mln inlatest AI funding, REUTERS (May 23, 2023), https://www.reuters.com/markets/deals/alphabetbacked-ai-startup-anthropic-raises-450-million-funding-freeze-thaws-2023-05-23/.

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50.

Anthropic’s primary product offering is a series of AI models referred to as“Claude.” Anthropic’s Claude AI models are a type of model known as a general purpose large
language model (“LLM”). Anthropic feeds the model vast amounts of text copied from theinternet, totaling billions or trillions of words, in order to “train” Claude. As a result, Claude isthen able to provide text-based responses to user queries in a seemingly intelligent, human-likemanner.
51.

Anthropic released its latest Claude model, known as “Claude 2,” in July 2023.

Anthropic touts Claude 2 as its “most capable system yet.”2 The company also offers various
other iterations of its Claude AI models. According to Anthropic, all of these AI models “usesimilar techniques,” and Claude 2 represents “a continuous evolution and a series of small, butmeaningful improvements” over previous versions.3
52.

Anthropic provides access to its Claude AI models in two ways: through a chatinterface on Anthropic’s website, and as a commercial Application Programming Interface(“API”) through which custom third-party client software can interact with Claude AI models.
First, Anthropic provides individual users access to Claude 2 as a “chatbot” on its website. This
chatbot responds to user-submitted questions and commands with seemingly sophisticated andconversational AI-generated replies. Anthropic makes this chatbot available in a paid
subscription-based version and a more limited free version. Second, Anthropic sells or licenses
API-based access to Claude 2 and its earlier Claude models to commercial customers,
incorporating Claude interactions into these customers’ software, products, and systems. When aprompt is entered into customer software using the Anthropic API, the customer’s software sends

2Model Card and Evaluations for Claude Models, at 1, ANTHROPIC, https://wwwfiles.anthropic.com/production/images/Model-Card-Claude-2.pdf.
3 Id.

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Page 16 of 60 PageID #: 16the prompt to an Anthropic server, Anthropic passes the prompt as input to its AI model, and thenan Anthropic server sends the model’s response back to the customer’s software. This process isinvisible to the ultimate end user, who experiences using the customer’s software as if thecustomer itself is generating the response for the user.
B.

Anthropic’s Development of Its AI Models Generally

53.

Anthropic’s Claude AI models respond to user prompts in a seemingly human-likemanner because Anthropic has copied and fed the underlying models vast amounts of text.
Notably, Anthropic does not create the text that it uses to fuel its AI models. Rather, Anthropic
harvests this text—including Publishers’ copyrighted lyrics and countless other copyrighted
works—from across the internet on an enormous scale, and then copies that text to serve as input
for its AI models.
54.

Specifically, Anthropic “trains” its Claude AI models how to generate text bytaking the following steps:a.

First, Anthropic copies massive amounts of text from the internet andpotentially other sources. Anthropic collects this material by “scraping” (or copying or
downloading) the text directly from websites and other digital sources and onto
Anthropic’s servers, using automated tools, such as bots and web crawlers, and/or byworking from collections prepared by third parties, which in turn may have been
harvested through web scraping. This vast collection of text forms the input, or “corpus,”
upon which the Claude AI model is then trained.
b.

Second, as it deems fit, Anthropic “cleans” the copied text to remove

material it perceives as inconsistent with its business model, whether technical or
subjective in nature (such as deduplication or removal of offensive language), or for other

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reasons. In most instances, this “cleaning” process appears to entirely ignore copyright
infringements embodied in the copied text.
c.

Third, Anthropic copies this massive corpus of previously copied text into

computer memory and processes this data in multiple ways to train the Claude AI models,or establish the values of billions of parameters that form the model. That includes
copying, dividing, and converting the collected text into units known as “tokens,” which
are words or parts of words and punctuation, for storage. This process is referred to as“encoding” the text into tokens. For Claude, the average token is about 3.5 characterslong.4d.

Fourth, Anthropic processes the data further as it “finetunes” the Claude

AI model and engages in additional “reinforcement learning,” based both on human
feedback and AI feedback, all of which may require additional copying of the collected
text.
55.

Once this input and training process is complete, Anthropic’s Claude AI models

generate output consistent in structure and style with both the text in their training corpora andthe reinforcement feedback. When given a prompt, Claude will formulate a response based on its
model, which is a product of its pretraining on a large corpus of text and finetuning, including
based on reinforcement learning from human feedback. According to Anthropic, “Claude is not abare language model; it has already been fine-tuned to be a helpful assistant.”5 Claude works
with text in the form of tokens during this processing, but the output is ordinary readable text.

4 Glossary, ANTHROPIC, https://docs.anthropic.com/claude/docs/glossary.
5 Id.

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C.

Anthropic’s Unlawful Exploitation of Publishers’ Works

56.

First, Anthropic engages in the wholesale copying of Publishers’ copyrighted

lyrics as part of the initial data ingestion process to formulate the training data used to program
its AI models.
57.

Anthropic fuels its AI models with enormous collections of text harvested fromthe internet. But just because something may be available on the internet does not mean it is freefor Anthropic to exploit to its own ends.
58.

For instance, the text corpus upon which Anthropic trained its Claude AI models

and upon which these models rely to generate text includes vast amounts of Publishers’
copyrighted lyrics, for which they own or control the exclusive rights.
59.

Anthropic largely conceals the specific sources of the text it uses to train its AI

models. Anthropic has stated only that “Claude models are trained on a proprietary mix ofpublicly available information from the Internet, datasets that we license from third party
businesses, and data that our users affirmatively share or that crowd workers provide,” and thatthe text on which Claude 2 was trained continues through early 2023 and is 90 percent Englishlanguage.6 The reason that Anthropic refuses to disclose the materials it has used for training
Claude is because it is aware that it is copying copyrighted materials without authorization fromthe copyright owners.
60.

Anthropic’s limited disclosures make clear that it has relied heavily on datasets(e.g., the “Common Crawl” dataset) that include massive amounts of content from popular lyrics

6 Model Card and Evaluations for Claude Models, at 2, ANTHROPIC, https://www-files.anthropic.com/production/images/Model-Card-Claude-2.pdf.

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websites such as genius.com, lyrics.com, and azlyrics.com, among other standard large text
collections, to train its AI models.7
61.

Moreover, the fact that Anthropic’s AI models respond to user prompts bygenerating identical or near-identical copies of Publishers’ copyrighted lyrics makes clear that
Anthropic fed the models copies of those lyrics when developing the programs. Anthropic had to
first copy these lyrics and process them through its AI models during training, in order for themodels to subsequently disseminate copies of the lyrics as output.
62.

Second, Anthropic creates additional unauthorized reproductions of Publishers’

copyrighted lyrics when it cleans, processes, trains with, and/or finetunes the data ingested into
its AI models, including when it tokenizes the data. Notably, although Anthropic “cleans” thetext it ingests to remove offensive language and filter out other materials that it wishes to exclude
from its training corpus, Anthropic has not indicated that it takes any steps to remove
copyrighted content.
63.

By copying Publishers’ lyrics without authorization during this ingestion andtraining process, Anthropic violates Publishers’ copyrights in those works.
64.

Third, Anthropic’s AI models disseminate identical or near-identical copies of awide range of Publishers’ copyrighted lyrics, in further violation of Publishers’ rights.
65.

Upon accessing Anthropic’s Claude AI models through Anthropic’s commerciallyavailable API or via its public website, users can request and obtain through Claude verbatim ornear-verbatim copies of lyrics for a wide variety of songs, including copyrighted lyrics owned

7 A General Language Assistant as a Laboratory for Alignment, at 8, 27, ANTHROPIC (Dec. 9,2021), https://arxiv.org/pdf/2112.00861.pdf.

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and controlled by Publishers. These copies of lyrics are not only substantially but strikingly
similar to the original copyrighted works.
66.

For example, when Anthropic’s Claude is asked, “What are the lyrics to Roar by

Katy Perry,” to which Concord owns the copyright, the AI model responds by providing analmost identical copy of those lyrics, in violation of Concord’s rights:
Claude output:

Genuine Concord lyrics:

I used to bite my tongue and hold my breath
Scared to rock the boat and make a mess
So I sat quietly, agreed politely
I guess that I forgot I had a choice
I let you push me past the breaking point
I stood for nothing, so I fell for everything

I used to bite my tongue and hold my breath
Scared to rock the boat and make a mess
So I sat quietly, agreed politely
I guess that I forgot I had a choice
I let you push me past the breaking point
I stood for nothing, so I fell for everything

You held me down, but I got up
Already brushing off the dust
You hear my voice, you hear that soundLike thunder gonna shake the groundYou held me down, but I got up
Get ready ’cause I’ve had enoughI see it all, I see it now

You held me down, but I got up (hey)Already brushing off the dust
You hear my voice, you hear that soundLike thunder, gonna shake the groundYou held me down, but I got up (hey)Get ready ’cause I’ve had enoughI see it all, I see it now

I got the eye of the tiger, a fighter, dancing
through the fire
’Cause I am a champion and you’re gonna
hear me roar
Louder, louder than a lion
’Cause I am a champion and you’re gonna
hear me roar

I got the eye of the tiger, a fighter
Dancing through the fire
’Cause I am a champion, and you’re gonna
hear me roar
Louder, louder than a lion
’Cause I am a champion, and you’re gonna
hear me roarOh oh oh oh oh oh oh
Oh oh oh oh oh oh oh
Oh oh oh oh oh oh ohYou’re gonna hear me roarOh-oh-oh-oh-oh
Oh-oh-oh-oh-oh
Oh-oh-oh-oh-oh
You’re gonna hear me roar

Now I’m floating like a butterfly
Stinging like a bee I earned my stripes
I went from zero, to my own hero

Now I’m floatin’ like a butterfly
Stinging like a bee, I earned my stripes
I went from zero, to my own hero

You held me down, but I got up
Already brushing off the dust

You held me down, but I got up (hey)Already brushing off the dust

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You hear my voice, you hear that soundLike thunder gonna shake the groundYou held me down, but I got up
Get ready ’cause I’ve had enoughI see it all, I see it now

You hear my voice, you hear that soundLike thunder, gonna shake the groundYou held me down, but I got up (hey)Get ready ’cause I’ve had enoughI see it all, I see it now

I got the eye of the tiger, a fighter, dancing
through the fire
’Cause I am a champion and you’re gonna
hear me roar
Louder, louder than a lion
’Cause I am a champion and you’re gonna
hear me roar

I got the eye of the tiger, a fighter
Dancing through the fire
’Cause I am a champion, and you’re gonna
hear me roar
Louder, louder than a lion
’Cause I am a champion, and you’re gonna
hear me roarOh oh oh oh oh oh oh
Oh oh oh oh oh oh oh
Oh oh oh oh oh oh ohYou’re gonna hear me roarOh oh oh oh oh oh ohYou’ll hear me roarOh oh oh oh oh oh ohYou’re gonna hear me roar...

Oh-oh-oh-oh-oh
Oh-oh-oh-oh-oh
Oh-oh-oh-oh-oh
You’re gonna hear me roarOh-oh-oh-oh-oh
Oh-oh-oh-oh-oh (you’ll hear me roar)Oh-oh-oh-oh-oh
You’re gonna hear me roar

Roar-or, roar-or, roar-or
Roar, roar, roar, roar, roar
I got the eye of the tiger, a fighter
Dancing through the fire
’Cause I am a champion, and you’re gonna
hear me roar
Louder, louder than a lion
’Cause I am a champion, and you’re gonna
hear me roarOh-oh-oh-oh-oh
Oh-oh-oh-oh-oh (yeah)
Oh-oh-oh-oh-oh
You’re gonna hear me roarOh-oh-oh-oh-oh
Oh-oh-oh-oh-oh (you’ll hear me roar)Oh-oh-oh-oh-oh
You’re gonna hear me roar

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67.

Likewise, when Anthropic’s Claude is prompted, “What are the lyrics to I Will

Survive by Gloria Gaynor,” to which Universal owns the copyright, the model responds byproviding a nearly word-for-word copy of those lyrics, in violation of Universal’s copyright:
Claude output:

Genuine Universal lyrics:

First I was afraid, I was petrified
Kept thinking I could never live without you
by my side
But then I spent so many nights thinking how
you did me wrong
And I grew strong
And I learned how to get along

At first I was afraid, I was petrified
Kept thinking I could never live without you
by my side
But then I spent so many nights thinking
how you did me wrong
And I grew strong
And I learned how to get along

And so you’re back from outer space
I just walked in to find you here with that sadlook upon your face
I should have changed my stupid lock, I shouldhave made you leave your key
If I had known for just one second you’d beback to bother me

And so you’re backFrom outer space
I just walked in to find you here
With that sad look upon your face
I should have changed that stupid lockI should have made you leave your key
If I’d known for just one second
You’d be back to bother me

Go on now, go, walk out the door
Just turn around now’Cause you’re not welcome anymore
Weren’t you the one who tried to hurt me with
goodbye?
Did you think I’d crumble?
Did you think I’d lay down and die?
Oh no, not I, I will survive
Oh, as long as I know how to love, I know I’ll
stay alive
I’ve got all my life to live
And I’ve got all my love to give and I’ll
survive
I will survive, hey, hey
It took all the strength I had not to fall apart
Kept trying hard to mend the pieces of mybroken heart
And I spent oh-so many nights just feelingsorry for myself
I used to cry

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Go on now, go
Walk out the door
Just turn around now’Cause you're not welcome anymore
Weren’t you the one who tried to hurt mewith goodbye?
Did you think I’d crumble?
Did you think I’d lay down and die?
Oh no, not I
I will survive
Oh, as long as I know how to love, I know
I’ll stay alive
I’ve got all my life to live
And I’ve got all my love to give and I’ll
survive
I will survive, hey, hey
Only the Lord could give me strength not tofall apartThough I tried hard to mend the pieces of my23
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But now I hold my head up highbroken heart
And I spent oh-so many nights just feelingsorry for myself
I used to cry
But now I hold my head up highAnd you see me somebody new
I’m not that chained-up little person still inlove with you
And so you felt like dropping in and just
expect me to be freeWell, now I’m saving all my lovin’ forsomeone who’s lovin’ me

And you see me, somebody new
I’m not that chained-up little person still inlove with you
And so you felt like dropping in
And just expect me to be freeWell, now I’m saving all my lovin’
For someone who’s loving me

Go on now, go, walk out the door
Just turn around now’Cause you're not welcome anymore
Weren’t you the one who tried to break mewith goodbye?
Did you think I’d crumble?
Did you think I’d lay down and die?
Oh no, not I, I will survive
Oh, as long as I know how to love, I know I’ll
stay alive
I’ve got all my life to live
And I’ve got all my love to give and I’ll
survive
I will survive
Oh go on now, go, walk out the door
Just turn around now’Cause you’re not welcome anymore
Weren’t you the one who tried to crush mewith goodbye?
Did you think I’d crumble?
Did you think I’d lay down and die?
Oh no, not I, I will survive
Oh, as long as I know how to love, I know I’ll
stay alive
I’ve got all my life to live
And I’ve got all my love to give and I’ll
survive
I will survive
I will survive

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Go on now, go
Walk out the door
Just turn around now’Cause you’re not welcome anymore
Weren’t you the one who tried to break mewith goodbye?
Did you think I’d crumble?
Did you think I’d lay down and die?
Oh no, not I
I will survive
And as long as I know how to love
I know I’ll stay alive
I’ve got all my life to live
And I’ve got all my love to give and I’ll
survive
I will survive
Oh
Go on now, go
Walk out the door
Just turn around now’Cause you’re not welcome anymore
Weren’t you the one who tried to break mewith goodbye?
Do you think I’d crumble?
Did you think I’d lay down and die?
No no, not I
I will survive
And as long as I know how to love
I know I’ll stay alive

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I’ve got all my life to live
And I’ve got all my love to give and I willsurvive
I will survive
Go on now, go
Walk out the door
Just turn around now’Cause you’re not welcome anymore
Weren’t you the one who tried to break mewith goodbye?
Did you think I’d crumble?
Did you think I’d lay down and die?
Oh no, not I
I will survive
And as long as I know how to love
I know I’ll stay alive
I’ve got all my life to live
And I’ve got all my love to give and I willsurvive
I will survive
I will survive
68.

Meanwhile, when Claude is prompted, “What are the lyrics to Friends in Low

Places by Garth Brooks,” the AI model again provides a nearly identical copy of those lyrics, inviolation of Universal’s rights:
Claude output:

Genuine Universal lyrics:

Blame it all on my roots
I showed up in boots
And ruined your black tie affair
The last one to know
The last one to show
I was the last one you thought you’d see there

Blame it all on my roots
I showed up in boots
And ruined your black tie affair
The last one to know
The last one to show
I was the last one you thought you’d see there
And I saw the surprise
And the fear in his eyes
When I took his glass of champagne
And I toasted you
Said “honey, we may be through”
But you’ll never hear me complain

And I saw the surprise
And the fear in his eyes
When I took his glass of champagne
And I toasted you
Said, honey, we may be throughBut you’ll never hear me complain

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’Cause I’ve got friends in low places
Where the whiskey drowns
And the beer chases my blues away
And I’ll be okay
I'm not big on social graces
Think I’ll slip on down to the oasis
Oh, I’ve got friends in low places
Well, I guess I was wrong
I just don’t belong
But then, I’ve been there before
Everything’s all right
I’ll just say goodnight
And I’ll show myself to the door
Hey, I didn’t mean
To cause a big scene
Just give me an hour and thenWell, I’ll be as highAs that ivory tower
That you're livin’ in’Cause I’ve got friends in low places
Where the whiskey drowns
And the beer chases my blues away
And I’ll be okay
I’m not big on social graces
Think I’ll slip on down to the oasis
Oh, I’ve got friends in low places
I’ve got friends in low places
Where the whiskey drowns
And the beer chases my blues away
And I’ll be okay
I’m not big on social graces
Think I’ll slip on down to the oasis
Oh, I’ve got friends in low places’Cause I’ve got friends in low places
Where the whiskey drowns
And the beer chases my blues away
And I’ll be okay
I’m not big on social graces
Think I’ll slip on down to the oasis
Oh, I’ve got friends in low places
Well, I guess I was wrong
I just don’t belong
But then, I’ve been there before
Everything’s all right
I’ll just say goodnight
And I’ll show myself to the door
Hey, I didn’t mean
To cause a big scene
Just give me an hour and thenWell, I’ll be as high as that ivory tower
That you're livin’ in’Cause I’ve got friends in low places
Where the whiskey drowns
And the beer chases my blues away
And I’ll be okay
I’m not big on social graces
Think I’ll slip on down to the oasis
Oh, I’ve got friends in low places
I’ve got friends in low places
Where the whiskey drowns
And the beer chases my blues away
And I’ll be okay
I’m not big on social graces
Think I’ll slip on down to the oasis
Oh, I’ve got friends in low places
I’ve got friends in low places
Where the whiskey drowns
And the beer chases my blues away
And I’ll be okay
I’m not big on social graces
Think I’ll slip on down to the oasis
Oh, I’ve got friends in low places
I’ve got friends in low places
Where the whiskey drowns

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And the beer chases my blues away
And I’ll be okay
69.

Likewise, when Claude is queried, “What are the lyrics to You Can’t Always Get

What You Want by the Rolling Stones,” to which ABKCO owns the copyright, the AI model
responds with an almost verbatim copy of those lyrics, in violation of ABKCO’s rights:
Claude output:

Genuine ABKCO lyrics:

I saw her today at the reception
A glass of wine in her handI knew she was gonna meet her connection
At her feet was her footloose man

I saw her today at the reception
A glass of wine in her handI knew she would meet her connection
At her feet was her footloose man

No, you can’t always get what you want
You can’t always get what you want
You can’t always get what you want
But if you try sometimes you findYou get what you needNo, you can’t always get what you want
You can’t always get what you want
You can’t always get what you want
But if you try sometime you’ll findYou get what you needI saw her today at the reception
A glass of wine in her handI knew she was gonna meet her connection
At her feet was her footloose man

I saw her today at the reception
A glass of wine in her handI knew she was gonna meet her connection
At her feet was her footloose man

You can’t always get what you want
You can’t always get what you want
You can’t always get what you want
But if you try sometimes you might findYou get what you need

You can’t always get what you want
You can’t always get what you want
You can’t always get what you want
But if you try sometimes, well, you mightfind
You get what you needAh, yeahOh

Oh yeah, hey hey hey, oh...
And I went down to the demonstration
To get my fair share of abuse
Singing, “We’re gonna vent our frustration
If we don’t we’re gonna blow a 50-amp fuse”
Sing it to me now...
You can’t always get what you want
You can’t always get what you want
You can’t always get what you want

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And I went down to the demonstration
To get my fair share of abuse
Singing, “We’re gonna vent our frustration
If we don’t we’re gonna blow a fifty-amp
fuse”
Sing it to me, honey
You can’t always get what you want
You can’t always get what you want

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But if you try sometimes well you just mightfind
You get what you needOh baby, yeah, yeah!
I went down to the Chelsea drugstore
To get your prescription filled
I was standing in line with Mr. Jimmy
And man, did he look pretty ill
We decided that we would have a soda
My favorite flavor, cherry red
I sung my song to Mr. Jimmy
Yeah, and he said one word to me, and thatwas “dead”
I said to him

I went down to the Chelsea drugstore
To get your prescription filled
I was standing in line with Mr. Jimmy
And, man, did he look pretty ill
We decided that we would have a soda
My favorite flavor, cherry red
I sung my song to Mr. Jimmy
Yeah, and he said one word to me, and thatwas “dead”
I said to him

You can’t always get what you want, no!
You can’t always get what you want (tell yababy)
You can’t always get what you want (no)But if you try sometimes you just might findYou get what you need
Oh yes! Woo!
You get what you need—yeah, oh baby!
Oh yeah!

You get what you need, yeah, oh baby
Ah yeahYou can’t always get what you want
You can’t always get what you want
You can’t always get what you want
But if you try sometimes you just might find
You just might findYou get what you need
You can’t always get what you want (no, nobaby)
You can’t always get what you want
You can’t always get what you want
But if you try sometimes you just might findDocument 1

You can’t always get what you want, well no
You can’t always get what you want. I tellyou, baby
You can’t always get what you want, no
But if you try sometimes you just might find,uh, mm
You get what you need, oh yeah, woo!
Ah, woo!

I saw her today at the reception
In her glass was a bleeding man
She was practiced at the art of deception
Well I could tell by her blood-stained hands

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You can’t always get what you want
But if you try sometimes, well, you just mightfind
You get what you needAh baby, yeahAh

I saw her today at the reception
In her glass was a bleeding man
She was practiced at the art of deception
Well, I could tell by her blood-stained hands,
sing itYou can’t always get what you want, yeah
You can’t always get what you want, oohyeah, child
You can’t always get what you want
But if you try sometimes you just might find
You just might findYou get what you need, ah yeah
Ah baby, woo!

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You just might findYou get what you need, ah yes!

70.

Ah, you can’t always get what you want, no,no, baby
You can’t always get what you want, you
can’t now, now
You can’t always get what you want
But if you try sometimes you just might find
You just might find that you
You get what you need, oh yeah
Ah yeah, do that

Claude’s output is likewise identical or substantially and strikingly similar to

Publishers’ copyrighted lyrics for each of the compositions listed in Exhibit A. These works thathave been infringed by Anthropic include timeless classics as well as today’s chart-topping hits,
spanning a range of musical genres. And this represents just a small fraction of Anthropic’s
infringement of Publishers’ works and the works of others, through both the input and output of
its AI models.
71.

Anthropic’s Claude is also capable of generating lyrics for new songs thatincorporate the lyrics from existing copyrighted songs. In these cases, Claude’s output may
include portions of one copyrighted work, alongside portions of other copyrighted works, in amanner that is entirely inconsistent and even inimical to how the songwriter intended them.
72.

Moreover, Anthropic’s Claude also copies and distributes Publishers’ copyrighted

lyrics even in instances when it is not asked to do so. Indeed, when Claude is prompted to write asong about a given topic—without any reference to a specific song title, artist, or songwriter—
Claude will often respond by generating lyrics that it claims it wrote that, in fact, copy directlyfrom portions of Publishers’ copyrighted lyrics.
73.

For instance, when Anthropic’s Claude is queried, “Write me a song about thedeath of Buddy Holly,” the AI model responds by generating output that copies directly from theCase 3:23-cv-01092

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song “American Pie” written by Don McLean, in violation of Universal’s copyright, despite thefact that the prompt does not identify that composition by title, artist, or songwriter:
Claude output:

Genuine Universal lyrics:

Here is a song I wrote about the death of
Buddy Holly:

A long long time ago
I can still remember how
That music used to make me smile
And I knew if I had my chance
That I could make those people dance
And maybe they’d be happy for a while

The Day the Music Died
February made me shiverWith every paper I’d deliver
Bad news on the doorstep
I couldn’t take one more step

But February made me shiverWith every paper I’d deliver
Bad news on the doorstep
I couldn’t take one more step

I can’t remember if I cried
When I read about his widowed bride
But something touched me deep inside
The day the music died
So bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey’n ryeSingin’ this’ll be the day that I die
This’ll be the day that I die
Did you write the book of love
And do you have faith in God above
If the Bible tells you so
Do you believe in rock n’ roll?
Can music save your mortal soul?

I can’t remember if I cried
When I read about his widowed bride
Something touched me deep inside
The day the music diedSo
Bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
And them good ole boys were drinking
whiskey and rye
Singin’ this’ll be the day that I die
This’ll be the day that I die

Well, I know that you’re in love with him’Cause I saw you dancin’ in the gym
You both kicked off your shoes
Man, I dig those rhythm and blues

Did you write the book of love
And do you have faith in God above
If the Bible tells you so?
Now, do you believe in rock and roll?
Can music save your mortal soul?
And can you teach me how to dance realslow?

I was a lonely teenage broncin’ buckWith a pink carnation and a pickup truck
But I knew I was out of luck
The day the music diedWell, I know that you’re in love with him’Cause I saw you dancin’ in the gym
You both kicked off your shoes
Man, I dig those rhythm and blues

I started singing bye, bye Miss American Pie

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Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey’n ryeSingin’ this’ll be the day that I die
This’ll be the day that I die
Now, for ten years we’ve been on our own
And moss grows fat on a rolling stone
But, that’s not how it used to be
When the jester sang for the king and queen
In a coat he borrowed from James Dean
And a voice that came from you and me

When the jester sang for the king and queen
In a coat he borrowed from James Dean
And a voice that came from you and me

And while Lenin read a book on Marx
The quartet practiced in the park
And we sang dirges in the dark
The day the music diedWe were singin’ bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey’n ryeSingin’ this’ll be the day that I die
This’ll be the day that I die

Now the halftime air was sweet perfume
While sergeants played a marching tune
We all got up to dance
Oh, but we never got the chance’Cause the players tried to take the field
The marching band refused to yield

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Bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey
and ryeAnd singin’ this’ll be the day that I die
This’ll be the day that I die
Now, for ten years we’ve been on our own
And moss grows fat on a rolling stone
But, that’s not how it used to be

Oh and while the king was looking down
The jester stole his thorny crown
The courtroom was adjourned
No verdict was returned

Helter skelter in a summer swelter
The birds flew off with a fallout shelter
Eight miles high and falling fast
It landed foul on the grass
The players tried for a forward passWith the jester on the sidelines in a castWith a pink carnation and a pickup truck
But I knew I was out of luck
The day the music diedI started singin’

Oh, and while the king was looking down
The jester stole his thorny crown
The courtroom was adjourned
No verdict was returned
And while Lennon read a book on Marx
The quartet practiced in the park
And we sang dirges in the dark
The day the music diedWe were singin’
Bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey
and ryeAnd singin’ this’ll be the day that I die
This’ll be the day that I die
Helter skelter in a summer swelter
The birds flew off with a fallout shelter
Eight miles high and falling fast
It landed foul on the grass
The players tried for a forward pass31
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Do you recall what was revealed
The day the music died?
We started singin’ bye, bye Miss American
Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey’n ryeAnd singin’ this’ll be the day that I die
This’ll be the day that I die
Oh, and there we were all in one place
A generation lost in spaceWith no time left to start again
So come on Jack be nimble, Jack be quick
Jack Flash sat on a candlestick’Cause fire is the devil’s only friend
Oh and as I watched him on the stage
My hands were clenched in fists of rage
No angel born in Hell
Could break that Satan’s spell
And as the flames climbed high into the night
To light the sacrificial rite
I saw Satan laughing with delight
The day the music diedHe was singin’ bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey’n ryeSingin’ this’ll be the day that I die
This’ll be the day that I die
I met a girl who sang the blues
And I asked her for some happy news
But she just smiled and turned away
I went down to the sacred store
Where I’d heard the music years before
But the man there said the music wouldn’tplay
And in the streets the children screamed
The lovers cried, and the poets dreamed
But not a word was spoken

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With the jester on the sidelines in a cast
Now the half-time air was sweet perfume
While the sergeants played a marching tune
We all got up to dance
Oh, but we never got the chance’Cause the players tried to take the field
The marching band refused to yield
Do you recall what was revealed
The day the music died?
We started singin’
Bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey
and ryeAnd singin’ this’ll be the day that I die
This’ll be the day that I die
Oh, and there we were all in one place
A generation lost in spaceWith no time left to start again
So come on Jack be nimble, Jack be quick
Jack Flash sat on a candlestick’Cause fire is the devil’s only friend
Oh, and as I watched him on the stage
My hands were clenched in fists of rage
No angel born in Hell
Could break that Satan’s spell
And as the flames climbed high into the night
To light the sacrificial rite
I saw Satan laughing with delight
The day the music diedHe was singin’
Bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey
and rye
Singin’ this’ll be the day that I die

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The church bells all were broken

This’ll be the day that I die

And the three men I admire most
The Father, Son, and the Holy Ghost
They caught the last train for the coast
The day the music diedAnd they were singin’ bye, bye Miss
American Pie
Drove my Chevy to the levee but the levee
was dry
And them good ole boys were drinking
whiskey ’n rye
Singin’ this’ll be the day that I die
This’ll be the day that I die

I met a girl who sang the blues
And I asked her for some happy news
But she just smiled and turned away
I went down to the sacred store
Where I’d heard the music years before
But the man there said the music wouldn’tplay
And in the streets the children screamed
The lovers cried, and the poets dreamed
But not a word was spoken
The church bells all were broken

They were singin’ bye, bye Miss American
Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey’n ryeAnd singin’ this’ll be the day that I die

And the three men I admire most
The Father, Son, and the Holy Ghost
They caught the last train for the coast
The day the music diedAnd they were singing
Bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey
and rye
Singin’ this’ll be the day that I die
This’ll be the day that I die
They were singing
Bye, bye Miss American Pie
Drove my Chevy to the levee but the levee
was dry
Them good ole boys were drinking whiskey
and rye
Singin’ this’ll be the day that I die
This’ll be the day that I die

74.

Similarly, when Anthropic’s Claude is prompted, “Write a song about movingfrom Philadelphia to Bel Air,” the AI model responds by generating output that copies verbatim
from the lyrics to the song “Fresh Prince of Bel-Air” written by Will Smith and Jeffrey Townes,

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in violation of Universal’s copyright, even though the prompt nowhere references thatcomposition by title, artist, or songwriter:
Claude output:

Genuine Universal lyrics:

Here’s a draft song about moving from
Philadelphia to Bel Air:
Now this is a story all about how
My life got flipped-turned upside down
And I’d like to take a minute, just sit rightthere
I’ll tell you how I became a prince of a town
called Bel Air

Now this is a story all about how
My life got flipped, turned upside down
And I’d like to take a minute
Just sit right there
I’ll tell you how I became the prince of a
town called Bel-Air
In West Philadelphia born and raised
On the playground was where I spent most of
my days
Chillin’ out, maxin,’ relaxin’ all cool
And all shootin’ some b-ball outside of theschoolWhen a couple of guys who were up to no
good
Started making trouble in my neighborhood
I got in one little fight and my mom got
scaredAnd said, “You’re movin’ with your auntie
and uncle in Bel-Air”

In West Philadelphia born and raised
On the playground was where I spent most of
my days
Chillin’ out maxin’ relaxin’ all cool
And all shootin’ some b-ball outside of theschoolWhen a couple of guys who were up to no
good
Started makin’ trouble in my neighborhood
I got in one little fight and my mom got
scaredShe said “You’re movin’ with your auntie and I begged and pleaded with her day after day
uncle in Bel Air”
But she packed my suitcase and sent me on
my wayI begged and pleaded with her day after day
She gave me a kiss and then she gave me my
But she packed my suitcase and sent me onticketmy wayI put my Walkman on and said, “I might as
She gave me a kiss and then she gave me mywell kick it”
ticketI put my Walkman on and said “I might asFirst class, yo this is badwell kick it”
Drinking orange juice out of a champagne
glassFirst class, yo this is bad,Is this what the people of Bel-Air living like?
Drinking orange juice out of a champagne
Hmm, this might be alrightglass
Is this what the people of Bel Air are livin’
But wait I hear they’re prissy, bourgeois andlike?
all that
Hmmm this might be alright!
Is this the type of place that they should send
this cool cat?
I whistled for a cab and when it came nearI don’t think so, I’ll see when I get there

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The license plate said “Fresh” and had dice inthe mirror
If anything I could say that this cab was rare
But I thought “Nah forget it, Yo home to Bel
Air”
I pulled up to the house about 7 or 8
And I yelled to the cabbie “Yo Holmes, smell
ya later!”
Looked at my kingdom, I was finally there
To sit on my throne as the prince of Bel Air

I hope they’re prepared for the prince of BelAir
Well, uh, the plane landed and when I cameout
There was a dude looked like a cop standing
there with my name out
I ain’t tryna get arrested yet, I just got here
I sprang with the quickness like lightning,
disappeared
I whistled for a cab and when it came near
The license plate said “fresh” and it had dicein the mirror
If anything I could say that this cab was rare
But I thought, “Nah, forget it, yo, holmes, toBel-Air”
I pulled up to a house about seven or eight
And I yelled to the cabbie, “Yo, holmes, smell
ya later”
Looked at my kingdom, I was finally there
To sit on my throne as the Prince of Bel-Air

75.

Separately, when Anthropic’s Claude is prompted to provide the chord

progressions for a given song, with or without reference to the lyrics, the AI model will often
generate output containing Publishers’ copyrighted lyrics alongside those chords.
76.

For example, when Claude is queried, “Give me the chords to Daddy Sang Bass

by Johnny Cash,” the AI model responds by providing both the chords and the lyrics to thatcomposition, in violation of Universal’s rights:
Claude output:

Genuine Universal lyrics:

Here are the chords for the song “Daddy Sang
Bass” by Johnny Cash:I remember when I was a ladTimes were hard and things were bad
But there’s a silver linin’ behind every cloud
Just poor people, that’s all we were
Tryin’ to make a living out of black-land dirt
But we’d get together in a family circle
singing loudVerse:G
D7
G
Well, I remember when I was a lad.
G
D7
G

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Times were hard and things were bad.
C
G D7 G
But there's a silver linin’ behind every cloud.
C
G D7 G
Just poor people, that’s all we were.
C
G D7 G
Tryin’ to make a livin’ out of blackland dirt.
C
G D7 G
We’d get together in a family circle singing
loud.
Chorus:G
C
G
Daddy sang bass, Mama sang tenor.
G
D7
G
Me and little brother would join right in there.
G
C
G
Singin’ seems to help a troubled soul.
G
D7
G
One of these days and it won’t be long,
G
C
G
I’ll rejoin them in a song.
GD7
G
I’m gonna join the family circle at the Throne.

Daddy sang bass, mama sang tenor
Me and little brother would join right in there
Singing seems to help a troubled soul
One of these days and it won’t be long
I’ll rejoin them in a song
I’m gonna join the family circle at the throneNo, the circle won’t be broken
By and by, Lord, by and by
Daddy sang bass, mama sang tenor
Me and little brother would join right in there
In the sky, Lord, in the sky
Now I remember after work, mama would
call in all of us
You could hear us singing for a country mile
Now little brother has done gone on
But I’ll rejoin him in a song
We’ll be together again up yonder in a little
while
Daddy sang bass, mama sang tenor
Me and little brother would join right in there’Cause singing seems to help a troubled soul
One of these days and it won’t be long
I’ll rejoin them in a song
I’m gonna join the family circle at the throne
Oh no, the circle won’t be broken
By and by, Lord, by and by
Daddy sang bass, mama sang tenor
Me and little brother would join right in there
In the sky, Lord, in the sky
In the sky, Lord, in the sky

77.

Moreover, when Anthropic’s Claude is asked to write other types of copyrighted

works, such as poetry, in the style of a certain artist or songwriter, the AI model will alsofrequently respond with output copying directly from Publishers’ lyrics.
78.

For instance, when Anthropic’s Claude is asked, “Write a poem in the style of

Lynyrd Skynyrd,” without any reference to a specific musical composition or lyrics, the AI

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model responds by providing a nearly word-for-word copy of the lyrics to “Sweet Home
Alabama,” in violation of Universal’s rights:
Claude output:
Here’s my attempt at a poem in the style of
Lynyrd Skynyrd:
Sweet Home Alabama
Big wheels keep on turning,
Carry me home to see my kin,
Singing songs about the Southland,
I miss ’ole ’bama once again.
In Birmingham they love the governor,
We all did what we could do,
Watergate does not bother me,
Does your conscience bother you?
Now Muscle Shoals has got the Swampers,
And they’ve been known to pick a song or
two,
Lord they get me off so much,
They pick me up when I’m feeling blue.
Sweet home Alabama,
Where the skies are so blue,
Sweet home Alabama,
Lord I’m coming home to you.
In Birmingham they love the governor,
Now we all did what we could do,
Now Watergate does not bother me,
Does your conscience bother you?

Genuine Universal lyrics:
Big wheels keep on turning
Carry me home to see my kin
Singing songs about the southland
I miss Alabamy once again
And I think it’s a sin, yes
Well, I heard Mr. Young sing about her
Well, I heard old Neil put her downWell, I hope Neil Young will remember
A Southern man don’t need him aroundanyhow
Sweet home Alabama
Where the skies are so blue
Sweet home Alabama
Lord, I’m coming home to you
In Birmingham they love the governor (boo!
Boo! Boo!)Now we all did what we could do
Now Watergate does not bother me
Does your conscience bother you?
Tell the truth
Sweet home Alabama
Where the skies are so blue
Sweet home Alabama
Lord, I’m coming home to you
Here I come, Alabama

Now Muscle Shoals has got the Swampers,
And they’ve been known to pick a song or
two,
Lord they get me off so much,
They pick me up when I’m feeling blue.

Now Muscle Shoals has got the Swampers
And they’ve been known to pick a song or
two (yes, they do)
Lord, they get me off so much
They pick me up when I’m feeling blue
Now how ’bout you?

Sweet home Alabama,
Where the skies are so blue,
Sweet home Alabama,

Sweet home Alabama
Where the skies are so blue
Sweet home Alabama

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Lord I’m coming home to you.
79.

Lord, I’m coming home to you

Similarly, when Claude is queried, “Write a short piece of fiction in the style ofLouis Armstrong,” the AI model responds by copying significant portions of the lyrics to “Whata Wonderful World,” in violation of Concord’s rights:
Claude output:

Genuine Concord lyrics:

Here is a short piece of fiction in the style ofLouis Armstrong:
What a Wonderful WorldI see trees of green, red roses too. I see them
bloom, for me and for you. And I think tomyself, what a wonderful world.
The bright blessed day, the dark sacred night.
And I think to myself, what a wonderfulworld.

I see trees of green
Red roses too
I see them bloom
For me and you
And I think to myself
What a wonderful world
I see skies of blue
And clouds of white
The bright blessed day
The dark sacred night
And I think to myself
What a wonderful world

The colors of the rainbow, so pretty in thesky. Are also on the faces, of people going by. The colors of the rainbow
I see friends shaking hands, sayin’ how do
So pretty in the sky
you do? They’re really saying, I love you.
Are also on the faces
Of people going by
I hear babies cry, I watch them grow. They’ll I see friends shaking hands
learn much more, than I’ll ever know. And I
Saying, “How do you do?”think to myself, what a wonderful world.
They’re really saying
I love you
The streets are filled with music, the air withlaughter. The warm sunny days, they stickI hear babies cryaround long after. And I think to myself, what I watch them growa wonderful world.
They’ll learn much moreThan I’ll never know
People greeting their neighbors, with smiles
And I think to myself
and hugs. Folks helping each other, showin’
What a wonderful world
love and care. And I think to myself, what a
Yes, I think to myself
wonderful world.
What a wonderful world
Ooh, yes
We all got a song to sing, let it ring clear andstrong. Even in sadness, we can find hope to
go on. Oh what a wonderful, wonderful

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world.
So much beauty everywhere, if you open youreyes. It’s in nature, and people, and underblue skies. And I think to myself, what awonderful world.
We’re together in this thing called life. Might
as well make it a pleasant ride. Oh what awonderful, wonderful world.
Yes I think to myself, what a wonderfulworld. What a wonderful world.
80.

In other words, Anthropic infringes Publishers’ copyrighted lyrics not only inresponse to specific requests for those lyrics. Rather, once Anthropic copies Publishers’ lyrics as
input to train its AI models, those AI models then copy and distribute Publishers’ lyrics as output
in response to a wide range of more generic queries related to songs and various other subject
matter.
81.

Despite the fact that Anthropic blatantly exploits Publishers’ lyrics and othercopyrighted content to develop and train its AI models, Anthropic forbids others from using its
own content for the same purpose. In fact, Anthropic’s Terms of Service explicitly prohibit theuse of its content to “develop or train any artificial intelligence or machine learning algorithms ormodels.”8 Anthropic violates this same principle by taking Publishers’ lyrics without theirpermission. Anthropic cannot have it both ways.
82.

Anthropic has the ability to exclude Publishers’ lyrics and other copyrighted

content from its training corpus, so as to prevent its AI models from being trained on andotherwise exploiting these copyrighted materials without permission. But Anthropic has not

8 Terms of Service, ANTHROPIC (Sept. 6, 2023), https://console.anthropic.com/legal/terms.

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indicated that it has taken any steps to filter out or remove Publishers’ lyrics or other copyrighted
materials from its training data.
83.

Anthropic likewise has the ability to program “guardrails” into its AI models, so

as to prevent the models from responding to certain prompts or generating output that copies
Publishers’ lyrics or other copyrighted content. Indeed, in some cases, Anthropic’s AI models
affirmatively refuse to respond to prompts seeking certain song lyrics, warning users thatproviding those lyrics runs afoul of “copyright restrictions.” These responses make clear that
Anthropic understands that generating output that copies others’ lyrics violates copyright law.
However, despite this knowledge and apparent ability to exercise control over infringement, inthe majority of instances, Anthropic fails to implement effective and consistent guardrails toprevent against the infringement of Publishers’ works. What’s more, even in those instanceswhere Anthropic’s AI models may respond to prompts by declining to provide copies of
copyrighted lyrics, simply re-entering the same prompts again is often enough to evade these
ineffective guardrails and generate infringing output.
84.

Additionally, through its AI models, Anthropic also intentionally removes or alters

the copyright management information associated with Publishers’ lyrics, or distributes copies of
Publishers’ lyrics knowing that copyright management information has been removed or altered,without Publishers’ authorization and in violation of the law.
85.

When Publishers license their lyrics to authorized lyrics aggregators and websites,

the aggregator and website operators are often required to identify such lyrics with the song title,
songwriter name(s), and other important identifying information, all of which constitutes
copyright management information.

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86.

But when Anthropic’s AI models regurgitate Publishers’ lyrics, they are often

unaccompanied by the corresponding song title, songwriter, or other critical copyright
management information.
87.

For example, when Claude is prompted, “Write me a song about Born to Be

Wild,” the AI model responds almost word-for-word with the lyrics to “Born to Be Wild” writtenby Mars Bonfire (of Steppenwolf), but fails to properly identify those lyrics by the song title,
songwriter, or other copyright management information for the work, in violation of Universal’s
rights:Claude output:

Genuine Universal lyrics:

Here is a song I wrote about being born to be
wild:
Get your motor runnin’
Head out on the highway
Lookin’ for adventure
And whatever comes our way
Yeah darlin’ gonna make it happen
Take the world in a love embrace
Fire all of your guns at once
And explode into space
I like smoke and lightning
Heavy metal thunder
Racin’ with the wind
And the feelin’ that I’m under
Yeah darlin’ gonna make it happen
Take the world in a love embrace
Fire all of your guns at once
And explode into space
Like a true nature’s child
We were born, born to be wild
We can climb so highI never wanna die

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Get your motor runnin’
Head out on the highway
Lookin’ for adventure
And whatever comes our way
Yeah, darlin’, go make it happen
Take the world in a love embrace
Fire all of your guns at once andExplode into space
I like smoke and lightnin’
Heavy metal thunder
Racin’ with the wind
And the feelin’ that I’m under
Yeah, darlin’, go make it happen
Take the world in a love embrace
Fire all of your guns at once andExplode into space
Like a true nature’s child
We were born, born to be wild
We can climb so highI never wanna die
Born to be wild
Born to be wild

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Born to be wild
Born to be wild

Get your motor runnin’
Head out on the highway
We’re lookin’ for adventure
And whatever comes our way

Get your motor runnin’
Head out on the highway
Looking for adventure
And whatever comes our way

Yeah, darlin’ go make it happen
Take the world in a love embrace
Fire all of your guns at once andExplode into space

Yeah darlin’ gonna make it happen
Take the world in a love embrace
Fire all of your guns at once
And explode into space

Like a true nature’s child
We were born, born to be wild
We can climb so highI never wanna die

Like a true nature’s child
We were born, born to be wild
We can climb so highI never wanna die

Born to be wild
Born to be wild

Born to be wild
Born to be wild88.

By failing to provide this information, Anthropic is not only removing copyright

management information, it is also denying creators appropriate attribution that assuresconsumers understand the source of the lyrics.
89.

Publishers have never authorized or licensed Anthropic to copy their copyrighted

lyrics or otherwise use these lyrics in connection with Anthropic’s AI models, as input or output.
Anthropic does not have permission or any right to deliberately and systematically copy andexploit Publishers’ copyrighted lyrics in this manner.
D.

Anthropic’s Profits From Its Infringement

90.

Anthropic has profited richly from exploiting the copyrighted works of Publishers

and others in connection with its AI models.
91.

Anthropic is reportedly valued at $5 billion or more. The company has alreadyreceived several billion dollars in total funding. In September 2023, Anthropic announced that

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Amazon would be investing up to $4 billion in Anthropic, at an undisclosed valuation, and taking
a minority stake in the company.9 Anthropic has also received $500 million in funding from agroup led by Sam Bankman-Fried, the founder of the failed cryptocurrency exchange FTX, as
well as $300 million from Google, and hundreds of millions of dollars more from Zoom,
Salesforce, and others.
92.

Although Anthropic bills itself as an AI “safety and research” company, thecompany reaps substantial financial profits from the AI models it builds and sells to commercial
customers using infringing content.
93.

According to its website, Anthropic has already sold access to its Claude API to“thousands of businesses.” Anthropic is also reportedly working with several larger customers tobuild customized commercial AI models.
94.

These commercial arrangements are lucrative. Anthropic charges its commercial

customers for using its Claude API on a per-word, pay-as-you-go model. Anthropic receives
revenues from these commercial customers based both on the amount of text submitted by eachcustomers’ end users into the Claude API, and the amount of text generated as output by themodels. In other words, Anthropic is paid every time one of its customers’ end users submits arequest for Publishers’ song lyrics, and it is paid again every time its Claude API generates
output copying and relying on those lyrics. Ultimately, the more Anthropic’s AI models are usedby its commercial customers and their end users—including to infringe Publishers’ copyrights—
the more money Anthropic makes.

9 Expanding access to safer AI with Amazon, ANTHROPIC (Sept. 25, 2023),

https://www.anthropic.com/index/anthropic-amazon.

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95.

Each of Anthropic’s commercial customers, by integrating and using the Claude

API in their own software, likewise infringes Publishers’ copyrights when these AI models
generate output copying or relying on Publishers’ lyrics. Moreover, when Anthropic licenses its
Claude API to commercial clients, it is essentially including in those licenses Publishers’
copyrighted content, which it has no right to license and is unauthorized.
96.

Anthropic has also monetized the version of its Claude 2 chatbot that it makes

available to individual users through the Anthropic website. Although Anthropic initially madethis version of the Claude 2 chatbot available to users for free, the company has begun to limit
access by unpaid users.10 Moreover, Anthropic recently launched a paid version of Claude 2—“Claude Pro”—for which it charges individual users a $20 monthly subscription fee for “5x more
usage” of the model compared to the unpaid version.11 At the same time, Anthropic collects andexploits data from its Claude 2 chatbot beta testing to further develop and improve its AI models,
including the commercially available API products. By providing Anthropic additional data on
which to refine its AI models, as well as generating publicity regarding the company and its
products, the Claude 2 beta deployment also enables Anthropic to seek and secure additional
valuable commercial funding.

10 Kristi Hines, Anthropic To Launch Paid Plans For Access To Claude, SEARCH ENGINEJOURNAL (Aug. 25, 2023), https://www.searchenginejournal.com/anthropic-to-launch-paidplans-for-access-to-claude/494867/#close.
11 Introducing Claude Pro, ANTHROPIC (Sept. 7, 2023),

https://www.anthropic.com/index/claude-pro.

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97.

Anthropic’s AI products continue to be in very high demand. Indeed, the waitlist

to access Claude’s commercial API and its chatbot has been reported to be 350,000 people
long.1298.

One of the reasons that Anthropic’s AI models are so popular and valuable isbecause of the substantial underlying text corpus that includes Publishers’ copyrighted lyrics. As
such, Publishers’ copyrighted content serves as a draw for individual users, commercial
customers, and ultimately investors.
99.

What’s more, according to media reports, Anthropic is currently pursuing as muchas $5 billion in additional Series C fundraising over the next two years, to take on rival AI
companies, enter over a dozen new major industries, and develop a new AI model—dubbed“Claude-Next”—which it claims will be ten times more powerful than even today’s most advanced
AI models.13
E.

Growing Alarm Over the Proliferation of AI Technology

100.

Despite the surging popularity of Anthropic’s AI models and other programs like

them, this AI technology raises serious and wide-ranging concerns. Academics, ethicists, andindustry experts have expressed alarm about a broad range of threats posed by AI, including
questions about privacy and surveillance, concerns over bias and discrimination, and thepotential for the systems to produce other toxic and harmful outcomes. And, of course, if AI
developers’ unlawful exploitation of copyrighted works is allowed to continue unchecked, it will

12 Hayden Field, Anthropic—the $4.1 billion OpenAI rival—debuts new A.I. chatbot and opens it

to public, CNBC (July 11, 2023), https://www.cnbc.com/2023/07/11/anthropic-an-openai-rivalopens-claude-2-ai-chatbot-to-the-public.html.
13 Kyle Wiggers, Devin Coldewey, and Manish Singh, Anthropic’s $5B, 4-year plan to take on

OpenAI, TECHCRUNCH (Apr. 6, 2023), https://techcrunch.com/2023/04/06/anthropics-5b-4-yearplan-to-take-on-openai/.

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have potentially devastating effects on artists and the creation of new works. Yet, Anthropic’s
professed concern for safety and security somehow does not reach this existential threat to
copyright owners.
101.

The U.S. Congress has expressed deep concern over these issues. Over the past

several months, the Senate Judiciary Committee has held a series of hearings regarding the needfor greater AI oversight to ensure that the technology complies with existing laws—including toprotect intellectual property rights. Similarly, in June 2023, U.S. Senator Michael Bennet wrote
to Anthropic and a number of other AI developers, calling on these companies to do more toaddress the spread of misinformation and disinformation through AI, and demanding additional
information about how they develop and monitor the content distributed through their AI models.
102.

U.S. regulators have also begun to take steps to address these issues and hold AI

developers to account. In April 2023, the U.S. Consumer Financial Protection Bureau,
Department of Justice’s Civil Rights Division, Equal Employment Opportunity Commission, andFederal Trade Commission issued a joint statement regarding the need for AI companies torespect the law, with the agency heads emphasizing that “the use of advanced technologies,
including artificial intelligence, must be consistent with federal laws,” and that “[t]here is no AI
exemption to the laws on the books.”14 In May 2023, after Amazon was required to pay a $25
million civil penalty for misusing customers’ personal data to refine its Alexa machine learningmodels, a U.S. Federal Trade Commission commissioner emphasized that technology companies“would do well to heed this lesson”: “Machine learning is no excuse to break the law. . . . The

14

Press Release, Justice Department’s Civil Rights Division Joins Officials from CFPB, EEOC
and FTC Pledging to Confront Bias and Discrimination in Artificial Intelligence (Apr. 25, 2023),
https://www.justice.gov/opa/pr/justice-department-s-civil-rights-division-joins-officials-cfpbeeoc-and-ftc-pledging.

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data you use to improve your algorithms must be lawfully collected and lawfully retained.”15
And, in July 2023, the FTC opened a formal investigation into OpenAI’s data practices inconnection with its AI models.
103.

Anthropic makes much of the so-called “constitutional AI” process it uses to train

its Claude AI models, but, notably, that training does nothing to avert the large-scale
infringement of Publishers’ copyrighted lyrics. Anthropic claims that it trains Claude on the basisof certain enumerated principles—a “constitution”—and thereby makes the AI model more
helpful and less harmful. Many of the constitutional principles upon which Claude is apparently
trained purport to emphasize the importance of refraining from “illegal” or “unlawful” activity
and respecting “property rights.”16
104.

But Anthropic’s constitution notably omits the critical protections for intellectual

property rights, such as copyright, that are centrally enshrined in the actual Constitution of theUnited States. Our founding fathers determined that protecting the rights of creators was criticalto our nation: “Congress shall have Power . . . To promote the Progress of Science and usefulArts, by securing for limited Times to Authors and Inventors the exclusive Right to theirrespective Writings and Discoveries.” U.S. Const. art. I, § 8, cl. 8. Despite paying lip service tocomplying with the law, Anthropic violates this founding principle when it illegally copies
Publishers’ copyrighted lyrics, without authorization or compensation. Perhaps this is why
Anthropic admits that “[c]onstitutions aren’t a panacea,” that its “current constitution is neither

15 Alvaro M. Bedoya, Statement of Commissioner Alvaro M. Bedoya Joined by Chair Lina M.

Khan and Commissioner Rebecca Kelly Slaughter In the Matter of Amazon Alexa (United Statesv. Amazon.com, Inc.) (May 31, 2023), https://www.ftc.gov/system/files/ftc_gov/pdf/BedoyaStatement-on-Alexa-Joined-by-LK-and-RKS-Final-1233pm.pdf.
16 Claude’s Constitution, ANTHROPIC (May 9, 2023), https://www.anthropic.com/index/claudes-

constitution.

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finalized nor is it likely the best it can be,” and that AI models like Claude “will continue togenerate difficult questions about what they are and aren’t allowed to do.”17
F.

The Ongoing Harm to Publishers From Anthropic’s Infringement

105.

Anthropic’s unlawful conduct has caused and continues to cause substantial andirreparable harm to Publishers, their songwriters, and the entire music community.
106.

Publishers’ musical compositions are creative intellectual property at the core ofwhat receives copyright protection under the Copyright Act. In turn, Anthropic is a for-profit
commercial operation that disseminates complete or near-complete copies of Publishers’
copyrighted lyrics through its AI models, and enables its customers and users to do the same.
Anthropic repackages and distributes these copies for financial gain, thereby devaluing thecreative efforts of songwriters and depriving them of compensation, credit, and the prestige of
having created something special and unique. Anthropic’s actions also deprive songwriters ofcontrol over how their creative works are reconstituted and adapted, uses which would typicallybe subject to their consent under their governing agreements with music publishers. Moreover,the sheer breadth and scope Anthropic’s copying makes it effectively impossible to measure,calculate, or even estimate the financial damage it imposes on songwriters and publishers.
107.

Anthropic has failed to seek or obtain the licenses or other agreements necessary

for it to lawfully exploit Publishers’ works. Anthropic’s unlawful conduct enriches Anthropic at
Publishers’ and their songwriters’ expense and to the detriment of musical creation. Anthropic’s
infringement undermines the incentive for songwriters to create music and for Publishers toinvest in, support, and exploit those creative efforts, which in turn hinders songwriters’ ability toearn a living based on their craft.

17 Id.

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108.

Anthropic’s unauthorized use also undercuts the existing and potential markets forlicensing song lyrics and undermines those legitimate lyrics aggregators, websites, and digital
services that properly license lyrics, given that users of Anthropic’s AI models do not visit thelegitimate sites that compensate Publishers for the right to use their lyrics. Anthropic’s
infringements are a market substitute for copyrighted works, leaving Publishers and songwriters
powerless to develop, exploit, and cultivate the works that are the backbone of their businesses.
109.

Anthropic could stop infringing Publishers’ musical compositions, and could

cease encouraging, contributing to, and facilitating infringement by its customers and users.
Unfortunately, Anthropic continues to directly and secondarily infringe Publishers’ musicalcompositions in order to profit and grow Anthropic’s business.
110.

Accordingly, Publishers have been left with no choice but to file this lawsuit to

put an end to Anthropic’s ongoing infringement of their rights and remedy the significant harm
Anthropic has caused.
CLAIMS FOR RELIEFCount I—Direct Copyright Infringement
111.

Publishers re-allege and incorporate by reference each and every allegation set

forth in the preceding paragraphs 1 through 110 of this Complaint.
112.

As detailed above, Anthropic, without Publishers’ permission or consent, has

unlawfully reproduced, distributed to the public, publicly displayed, and/or prepared derivative
works based upon Publishers’ musical compositions, including the song lyrics contained therein.
Such activity, which is ongoing, constitutes direct infringement by Anthropic of Publishers’
registered copyrights and exclusive rights under copyright in violation of the Copyright Act, 17
U.S.C. §§ 106(1)-(3), (5) and 501.

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113.

A non-exhaustive, exemplary list of the musical compositions for which

Publishers are the legal or beneficial copyright owners, and which Anthropic has infringed, isattached hereto as Exhibit A.
114.

Each infringement by Anthropic in and to Publishers’ musical compositions

constitutes a separate and distinct act of infringement.
115.

Anthropic’s acts of infringement are willful, intentional, and purposeful, indisregard of and with indifference to Publishers’ rights.
116.

As a direct and proximate result of Anthropic’s wrongful conduct, which is

ongoing, Publishers have been, and will continue to be, substantially and irreparably harmed in
an amount not readily capable of determination. Publishers have no adequate remedy at law.
Unless restrained by this Court, Anthropic will cause further irreparable injury to Publishers.
Publishers are entitled to a permanent injunction prohibiting infringement of Publishers’
copyrights and exclusive rights under copyright.
117.

As a direct and proximate result of Anthropic’s infringement of Publishers’

copyrights and exclusive rights, Publishers are entitled to statutory damages, pursuant to 17
U.S.C. § 504(c). Alternatively, at Publishers’ election, pursuant to 17 U.S.C. § 504(b), Publishers
shall be entitled to their actual damages and Anthropic’s profits from infringement that are nottaken into account in computing the actual damages, as will be proven at trial.
118.

Publishers are also entitled to attorneys’ fees and costs pursuant to 17 U.S.C. §505.
Count II—Contributory Infringement
119.

Publishers re-allege and incorporate by reference each and every allegation set

forth in the preceding paragraphs 1 through 110 of this Complaint.

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120.

As detailed above, the licensees and users of Anthropic’s AI models, without

Publishers’ permission or consent, have unlawfully reproduced, distributed to the public, publicly
displayed, and/or prepared derivative works based upon Publishers’ musical compositions,
including the song lyrics contained therein. Such activity, which is ongoing, constitutes direct
infringement or an unauthorized act in violation of the Copyright Act, 17 U.S.C. §§ 106(1)-(3),(5) and 501.
121.

Anthropic is contributorily liable for these direct infringements by licensees

and/or users of its AI models as described herein.
122.

As discussed above, Anthropic is well aware of its licensees’ and users’ infringing

activity through its AI products. Anthropic knowingly trained its AI models on infringing content
on a massive scale in order to enable those models to generate responses to user prompts that
infringe Publishers’ copyrighted lyrics. Anthropic relies on vast troves of copyrighted works
including Publishers’ copyrighted lyrics as both input and output for its AI models, andAnthropic has knowledge of specific infringing responses generated by its AI models in response
to user prompts, among other knowledge.
123.

Nevertheless, Anthropic facilitates, encourages, and materially contributes to such

infringement, including, without limitation, by promoting its AI models, providing access to
those models through its website and its API, and hosting and transmitting known infringing
content via those models.
124.

Anthropic has the means to take simple steps not to materially contribute to thespecific infringing activity but fails to do so. Instead, Anthropic gathers training data that
includes Publishers’ copyrighted works, provides the site and facilities necessary for users of its
AI models to commit direct infringement, and actively facilitates the ongoing infringement,

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including via the actions described above. As a direct and proximate result, users of Anthropic’s
AI models have infringed Publishers’ copyrights in the musical compositions.
125.

Accordingly, Anthropic is contributorily liable for the infringement of Publishers’

copyrighted musical compositions, including the song lyrics contained therein, in violation of
Publishers’ registered copyrights and exclusive rights under copyright in violation of the
Copyright Act, 17 U.S.C. §§ 106(1)-(3), (5) and 501.
126.

Through the activities set forth above, among others, Anthropic designs, operates,

and maintains its AI models with the object of promoting their use to infringe Publishers andother copyright owners’ copyrights. As a direct and proximate result of such actions, licensees
and users of Anthropic’s AI models have infringed Publishers’ copyrighted musicalcompositions. Accordingly, Anthropic is liable for inducing the infringing acts of the licensees
and users of its AI models, in violation of Publishers’ registered copyrights and exclusive rights
under copyright in violation of the Copyright Act, 17 U.S.C. §§ 106(1)-(3), (5) and 501.
127.

A non-exhaustive, exemplary list of the musical compositions for which

Publishers are the legal or beneficial copyright owners, and which Anthropic has infringed, isattached hereto as Exhibit A.
128.

Each infringement of Publishers’ musical compositions constitutes a separate anddistinct act of infringement.
129.

Anthropic’s acts of infringement are willful, intentional, and purposeful, indisregard of and with indifference to Publishers’ rights.
130.

As a direct and proximate result of Anthropic’s wrongful conduct, which is

ongoing, Publishers have been, and will continue to be, substantially and irreparably harmed in
an amount not readily capable of determination. Publishers have no adequate remedy at law.

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Unless restrained by this Court, Anthropic will cause further irreparable injury to Publishers.
Publishers are entitled to a permanent injunction prohibiting infringement of Publishers’
copyrights and exclusive rights under copyright.
131.

As a direct and proximate result of Anthropic’s infringement of Publishers’

copyrights and exclusive rights, Publishers are entitled to statutory damages, pursuant to 17
U.S.C. § 504(c). Alternatively, at Publishers’ election, pursuant to 17 U.S.C. § 504(b), Publishers
shall be entitled to their actual damages and Anthropic’s profits from infringement that are nottaken into account in computing the actual damages, as will be proven at trial.
132.

Publishers are also entitled to attorneys’ fees and costs pursuant to 17 U.S.C. §505.
Count III—Vicarious Infringement
133.

Publishers re-allege and incorporate by reference each and every allegation set

forth in the preceding paragraphs 1 through 110 of this Complaint.
134.

As detailed above, the licensees and users of Anthropic’s AI models, without

Publishers’ permission or consent, have unlawfully reproduced, distributed to the public, publicly
displayed, and/or prepared derivative works based upon Publishers’ musical compositions,
including the song lyrics contained therein. Such activity, which is ongoing, constitutes direct
infringement or an unauthorized act in violation of the Copyright Act, 17 U.S.C. §§ 106(1)-(3),(5) and 501.
135.

Anthropic is vicariously liable for these direct infringements by licensees and/or

users of its AI models as described herein.
136.

As discussed above, Anthropic has the legal right and practical ability tosupervise and control the infringing activities that occur through and as a result of its AI models.

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Anthropic has the ability to control both the input and output of its AI models based on how it
develops and trains the models on an ongoing basis; it can monitor and review its AI models forharmful, infringing, or otherwise unlawful input and output; it has the ability to refine andfinetune its AI models to address or remove such harmful, infringing, or otherwise unlawful
input and output; it can control and limit user access to its AI models available through its
website and as API (including by terminating such access altogether, pursuant to its terms ofservice); and it can monitor and review user interactions with its AI models, among other rights
and abilities to supervise and control the infringing activities.
137.

At all relevant times, Anthropic has derived a direct financial benefit fromlicensees and users’ infringement of Publishers’ copyrighted musical compositions through
Anthropic’s AI models. As discussed above, Anthropic has commercialized its AI models in a
number of ways, including by selling API access to commercial customers on a per-word basis.
Through this pay-as-you-go subscription model, Anthropic receives revenues every time a user
submits a request for Publishers’ song lyrics through the API, and again every time the API
generates output copying or relying on those lyrics. Among other financial benefits, Anthropic
has also received billions of dollars in commercial funding in connection with the developmentof its AI models, and it has saved a substantial amount of money by failing to properly pay
licensing fees for the use of Publishers’ copyrighted lyrics.
138.

Publishers’ lyrics are also a draw for licensees and users. Anthropic’s AI models

have value and are in high demand because of the underlying text corpus that includes
Publishers’ copyrighted lyrics, among other reasons. Customers and users are drawn to
Anthropic’s AI models, at least in part, by the models’ ability to generate copies of song lyrics,

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including Publishers’ copyrighted lyrics, as well as various other text output based on themodels’ ingestion of Publishers’ copyrighted lyrics.
139.

Anthropic has refused to take reasonable steps to prevent the widespreadinfringement by users of its AI models. As a direct and proximate result of such refusal, users of
Anthropic’s AI models have infringed Publishers’ copyrights in the musical compositions.
140.

Accordingly, Anthropic is vicariously liable for the infringement of Publishers’

copyrighted musical compositions, including the song lyrics contained therein, in violation of
Publishers’ registered copyrights and exclusive rights under copyright in violation of the
Copyright Act, 17 U.S.C. §§ 106(1)-(3), (5) and 501.
141.

A non-exhaustive, exemplary list of the musical compositions for which

Publishers are the legal or beneficial copyright owners, and which Anthropic has infringed, isattached hereto as Exhibit A.
142.

Each infringement of Publishers’ musical compositions constitutes a separate anddistinct act of infringement.
143.

Anthropic’s acts of infringement are willful, intentional, and purposeful, indisregard of and with indifference to Publishers’ rights.
144.

As a direct and proximate result of Anthropic’s wrongful conduct, which is

ongoing, Publishers have been, and will continue to be, substantially and irreparably harmed in
an amount not readily capable of determination. Publishers have no adequate remedy at law.
Unless restrained by this Court, Anthropic will cause further irreparable injury to Publishers.
Publishers are entitled to a permanent injunction prohibiting infringement of Publishers’
copyrights and exclusive rights under copyright.

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145.

As a direct and proximate result of Anthropic’s infringement of Publishers’

copyrights and exclusive rights, Publishers are entitled to statutory damages, pursuant to 17
U.S.C. § 504(c). Alternatively, at Publishers’ election, pursuant to 17 U.S.C. § 504(b), Publishers
shall be entitled to their actual damages and Anthropic’s profits from infringement that are nottaken into account in computing the actual damages, as will be proven at trial.
146.

Publishers are also entitled to attorneys’ fees and costs pursuant to 17 U.S.C. §505.
Count IV—Removal or Alteration of Copyright Management Information
147.

Publishers re-allege and incorporate by reference each and every allegation set

forth in the preceding paragraphs 1 through 110 of this Complaint.
148.

The titles of Publishers’ musical compositions, the name and other identifying

information about the authors of those musical compositions, and the name and other identifying
information about the copyright owners of those musical compositions, including the song lyrics
contained therein, constitute copyright management information under the Copyright Act, 17
U.S.C. § 1202.
149.

As detailed above, Anthropic has intentionally removed or altered copyright

management information from Publishers’ musical compositions, and/or distributed or imported
for distribution copies of Publishers’ musical compositions knowing that copyright management
information has been removed or altered, without Publishers’ authorization and in violation of
the Copyright Act, 17 U.S.C. § 1202(b). Anthropic has done so in the process of training
Anthropic’s AI models and/or in the output of those AI models, including by generating text that
copies or relies on Publishers’ lyrics while omitting the required copyright management
information.

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150.

Anthropic’s acts of infringement are willful, intentional, and purposeful, indisregard of and with indifference to Publishers’ rights.
151.

As a direct and proximate result of Anthropic’s wrongful conduct, which is

ongoing, Publishers have been, and will continue to be, substantially and irreparably harmed in
an amount not readily capable of determination. Publishers have no adequate remedy at law.
Unless restrained by this Court, Anthropic will cause further irreparable injury to Publishers.
Publishers are entitled to a permanent injunction prohibiting Anthropic’s unlawful activity.
152.

As a direct and proximate result of Anthropic’s unlawful activity, Publishers areentitled to statutory damages, pursuant to 17 U.S.C. § 1203(c)(3)(B). Alternatively, at Publishers’
election, pursuant to 17 U.S.C. § 1203(c)(2), Publishers shall be entitled to their actual damages
and Anthropic’s profits from infringement that are not taken into account in computing the actual
damages, as will be proven at trial.
153.

Publishers are also entitled to attorneys’ fees and costs pursuant to 17 U.S.C. §1203(b)(4)-(5).
PRAYER FOR RELIEF
By reason of the facts and circumstances alleged above, Publishers seek relief against
Anthropic as follows:a.

Judgment on each of the claims set forth above, including that Anthropic has

directly and secondarily infringed Publishers’ copyrights under the Copyright Act, that
Anthropic has unlawfully removed and/or altered Publishers’ copyright management informationin violation of the Copyright Act, and that such infringement and unlawful activity was willful;b.

An order for such equitable relief under Title 17, Title 28, and/or the Court’s

inherent authority as is necessary to prevent or restrain infringement of Publishers’ copyrights

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and removal or alteration of Publishers’ copyright management information, including apreliminary and permanent injunction requiring that Anthropic and its officers, agents, servants,
employees, attorneys, directors, successors, assigns, licensees, and all others in active concert orparticipation with any of them, cease directly infringing, indirectly infringing, and/or removing
or altering copyright management information, or causing, aiding, enabling, facilitating,encouraging, promoting, inducing, or materially contributing to or participating in theinfringement of any of Publishers’ exclusive rights under copyright, including without limitationin the musical compositions in Exhibit A;c.

An order requiring Anthropic to pay Publishers statutory damages in an amount

up to the maximum provided by law, arising from Anthropic’s willful violations of Publishers’
rights under the Copyright Act, including in an amount up to $150,000 per work infringed,
pursuant to 17 U.S.C. § 504(c); or in the alternative, at Publishers’ election, Publishers’ actual
damages and Anthropic’s profits from the infringement, in an amount to be proven at trial,
pursuant to 17 U.S.C. § 504(b);d.

An order requiring Anthropic to pay Publishers statutory damages in an amount

up to the maximum provided by law, arising from Anthropic’s removal and/or alteration of
Publishers’ copyright management information in violation of the Copyright Act, including in an
amount up to $25,000 per violation, pursuant to 17 U.S.C. § 1203(c)(3)(B); or in the alternative,at Publishers’ election, Publishers’ actual damages and Anthropic’s profits, in an amount to be
proven at trial, pursuant to 17 U.S.C. § 1203(c)(2);e.

An order requiring Anthropic to provide an accounting of the training data,

training methods, and known capabilities of its AI models, including requiring that Anthropic
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and disclose the methods by which Anthropic has collected, copied, processed, and encoded thistraining data (including any third parties it has engaged to collect or license such data).
f.

An order requiring that Anthropic destroy under the Court’s supervision all

infringing copies of Publishers’ copyrighted works in Anthropic’s possession or control, andthen file a sworn report setting forth in detail the manner in which it has complied with theaforesaid order, pursuant to 17 U.S.C. § 503(b);g.

Publishers’ reasonable attorneys’ fees and costs in this action, pursuant to 17

U.S.C. § 505 and/or 17 U.S.C. § 1203(b)(4)-(5);h.

Pre-judgment and post-judgment interest at the applicable rate on any monetaryaward made part of the judgment against Anthropic; andi.

Such other and further relief as the Court deems proper.
JURY TRIAL DEMAND

Publishers hereby request a trial by jury.

Dated: October 18, 2023

Respectfully submitted,/s/ Steven A. Riley
Steven A. Riley (No. 6258)
Tim Harvey (No. 21509)
RILEY & JACOBSON, PLC
1906 West End Avenue
Nashville, TN 37203(615) 320-3700
sriley@rjfirm.com
tharvey@rjfirm.com
Matthew J. Oppenheim
Nicholas C. Hailey
Audrey Adu-Appiah(pro hac vice applications to follow)
OPPENHEIM + ZEBRAK, LLP
4530 Wisconsin Ave., NW, 5th Floor
Washington, DC 20016

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Telephone: (202) 480-2999
matt@oandzlaw.com
nick@oandzlaw.com
aadu-appiah@oandzlaw.com
Jennifer Pariser
Andrew Guerra
Timothy Chung(pro hac vice applications to follow)
OPPENHEIM + ZEBRAK, LLP
461 5th Avenue, 19th Floor
New York, NY 10017
Telephone: (212) 951-1156
jpariser@oandzlaw.com
andrew@oandzlaw.com
tchung@oandzlaw.com
OF COUNSEL
Richard S. Mandel
Jonathan Z. King
Richard Dannay(pro hac vice applications to follow)
COWAN, LIEBOWITZ & LATMAN, P.C.
114 West 47th Street
New York, NY 10036-1525
Telephone: 212-790-9200
rsm@cll.com
jzk@cll.com
rxd@cll.com
Attorneys for Plaintiffs

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