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📝 Page Status: Draft — sourced but not yet reviewed

  • Status: draft
  • Sources: 7
  • Relationships: 7
  • Research debt items: 5

Concord Music Group, Inc. v. Anthropic PBC¶

Summary¶

Concord Music Group, Inc. v. Anthropic PBC, No. 24-cv-03811 (N.D. Cal.) (Concord I), is music-publisher litigation over song lyrics and Anthropic’s Claude models. After an initial dismissal of secondary-infringement and DMCA claims with leave to amend, Judge Eumi K. Lee on October 6, 2025 denied Anthropic’s motion to dismiss the first amended complaint. Direct infringement, contributory and vicarious infringement, and DMCA copyright-management-information claims therefore proceeded past that pleading stage. The case is about musical compositions (lyrics), not sound-recording masters.

A second action, No. 5:26-cv-00880 (Concord II), was filed January 28, 2026, against Anthropic, Dario Amodei, and Benjamin Mann. Publishers allege torrenting of pirated books that contained their compositions after the court denied leave to add those claims to Concord I. On February 18, 2026, the court related Concord II to Concord I. Concord II is allegations only.

Verified Facts¶

  • The action pending in the Northern District of California as No. 5:24-cv-03811 reflects a complaint originally filed October 18, 2023 in the Middle District of Tennessee and later transferred; the N.D. Cal. docket date is June 26, 2024.2
  • Plaintiffs are eight music publishing companies: Concord Music Group, Inc., Capitol CMG, Inc., Universal Music Corp., Songs of Universal, Inc., Universal Music - MGB NA LLC, Polygram Publishing, Inc., Universal Music - Z Tunes LLC, and ABKCO Music, Inc.1
  • The first amended complaint alleges that the publishers own or control exclusive rights in millions of musical compositions, including 500 works listed in Exhibit A, and that Anthropic used those lyrics to train Claude and that Claude outputs the lyrics to users.1
  • Publishers allege that Anthropic curated training data from third-party datasets including Common Crawl and The Pile, and that it used the Newspaper algorithm in a way that removed copyright management information more effectively than available alternatives.1
  • Claims in the FAC are (I) direct copyright infringement, (II) contributory infringement, (III) vicarious infringement, and (IV) removal or alteration of CMI under the DMCA.1
  • On March 26, 2025, the court granted Anthropic’s first motion to dismiss the secondary-infringement and CMI claims, with leave to amend. Publishers filed the FAC on April 25, 2025. Anthropic moved again on May 9, 2025.1
  • On October 6, 2025, the court denied the second motion to dismiss in full, holding that the FAC plausibly alleged contributory infringement, vicarious infringement, and DMCA § 1202(b)(1) and (b)(3) claims, and ordered Anthropic to answer within 14 days after a ruling on plaintiffs’ motion for leave to file a second amended complaint.1
  • On January 28, 2026, the same publisher group filed Concord II, No. 5:26-cv-00880, against Anthropic PBC, Dario Amodei, and Benjamin Mann. The complaint alleges that publishers moved to amend Concord I to add torrenting claims after Bartz public filings revealed alleged LibGen and PiLiMi downloads, that Anthropic opposed amendment as transforming Concord I, and that publishers therefore brought a separate action.3
  • Concord II pleads (I) direct copyright infringement by torrenting against all defendants; (II) direct copyright infringement in training and output; (III) contributory infringement against Anthropic; (IV) vicarious infringement against Anthropic; and (V) removal or alteration of copyright management information.3
  • On February 18, 2026, Judge Lee found Concord II related to Concord I and reassigned No. 26-cv-00880 to herself.4

Historical Context¶

Concord is the leading U.S. publisher suit about lyrics in large language models, distinct from the label suits against Suno and Udio (sound recordings) and from Bartz v. Anthropic PBC (books and a pirated-library settlement). The October 2025 order is a pleading decision, not a fair-use holding. Concord II imports Bartz’s alleged torrenting facts into a composition catalog. BMG Rights Management (US) LLC v. Anthropic PBC later identified both Concord dockets as related, and Sony Music Publishing (US) LLC v. Anthropic PBC refers to Concord I and Concord II.56

Jurisdiction: Northern District of California. Authority level: Rule 12(b)(6) order in Concord I; complaint and related-case order in Concord II. The court accepted FAC allegations as true for the Concord I motion and did not decide § 107.1

Two points matter for the rest of the AI-copyright map. First, the works are short, highly memorable lyrics. Publishers allege regurgitation from simple prompts, which is closer to the output-substitution theory in Times v. OpenAI than to Bartz’s purchased-book training holding.1 Second, the court allowed DMCA CMI claims to proceed on allegations that Anthropic chose a stripping algorithm and distributed lyrics without CMI while concealing its own infringement, distinguishing Tremblay’s third-party-user framing.1

Concord II is a different theory: alleged pirated acquisition and distribution of books containing compositions, plus later training and output claims, with individual founder defendants. Naming Amodei and Mann is a pleading choice, not a finding of personal liability. This page does not treat alleged LibGen or PiLiMi downloads as found facts, and it does not record any later stay or merits order in Concord II.34

Relationships¶

  • CASE-CONCORD-V-ANTHROPIC cites SRC-CONCORD-V-ANTHROPIC-MTD-2025.
  • CASE-CONCORD-V-ANTHROPIC cites SRC-CONCORD-II-RELATED-2026.
  • CASE-CONCORD-V-ANTHROPIC related_to TOPIC-AI-MUSIC-COPYRIGHT.
  • CASE-CONCORD-V-ANTHROPIC related_to TOPIC-AI-COPYRIGHT.
  • CASE-CONCORD-V-ANTHROPIC related_to CASE-GEMA-V-OPENAI.
  • CASE-CONCORD-V-ANTHROPIC related_to CASE-SONY-V-ANTHROPIC.
  • CASE-CONCORD-V-ANTHROPIC related_to CASE-BMG-V-ANTHROPIC.

Sources¶

  1. SRC-CONCORD-V-ANTHROPIC-MTD-2025: Order denying motion to dismiss FAC (Oct. 6, 2025).
  2. SRC-CONCORD-V-ANTHROPIC-DOCKET: CourtListener docket for No. 5:24-cv-03811.
  3. SRC-CONCORD-II-COMPLAINT: Concord II complaint (Jan. 28, 2026).
  4. SRC-CONCORD-II-RELATED-2026: Related-case order (Feb. 18, 2026).
  5. SRC-BMG-V-ANTHROPIC-COMPLAINT: BMG complaint (Mar. 17, 2026).
  6. SRC-SONY-V-ANTHROPIC-COMPLAINT-2026: Sony/Warner publisher complaint (Aug. 28, 2026).

Additional sources (not yet cited in footnotes):

Research Debt¶

  • Add the original Tennessee complaint, the FAC, and any second amended complaint as operative-pleading sources.
  • Add the March 26, 2025 dismissal order and any preliminary-injunction ruling from primary PDFs.
  • Add Anthropic’s answer and any later merits order in Concord I or Concord II.
  • The later Sony/Warner publisher action is CASE-SONY-V-ANTHROPIC; BMG is CASE-BMG-V-ANTHROPIC.
  • Do not treat party joint-status letters as a holding that a stay was granted or denied.

Document metadata¶

  • Decision date: 2025-10-06
  • Last verified: 2026-09-02

  1. SRC-CONCORD-V-ANTHROPIC-MTD-2025 — Order denying MTD (Oct. 6, 2025). Primary for parties, claims, procedural history, alleged FAC facts, and Concord I holdings. â†©â†©â†©â†©â†©â†©â†©â†©â†©

  2. SRC-CONCORD-V-ANTHROPIC-DOCKET — CourtListener docket for No. 5:24-cv-03811. Primary for original Tennessee filing date and transfer caption. â†©

  3. SRC-CONCORD-II-COMPLAINT — Concord II complaint (Jan. 28, 2026). Primary for Concord II parties, counts, and alleged torrenting theory. â†©â†©â†©

  4. SRC-CONCORD-II-RELATED-2026 — Related-case order (Feb. 18, 2026). Primary for relation to Concord I. â†©â†©

  5. SRC-BMG-V-ANTHROPIC-COMPLAINT — BMG complaint (Mar. 17, 2026). Primary for BMG’s related-case allegation. â†©

  6. SRC-SONY-V-ANTHROPIC-COMPLAINT-2026 — Sony/Warner complaint (Aug. 28, 2026). Primary for that complaint’s reference to Concord I and Concord II. â†©