The RIAA sued Suno and Udio in June 2024, representing Universal Music Group, Sony Music, and Warner Music in what became the defining copyright battle over AI-generated music. The cases split in October 2025 when UMG settled with Udio, creating the first major-label licensing template for AI music generation. Sony and Warner are still litigating against Udio. Suno refuses to settle and is fighting the case on fair use grounds, citing the Second Circuit's Bartz decision.

Meanwhile, independent musicians filed separate class actions against both companies, arguing that the major-label settlements don't protect smaller rights holders. What's emerging isn't a single legal answer — it's a two-tier licensing regime where major labels cut deals and independent artists get left behind. Every entertainment lawyer needs to understand this landscape.


RIAA v Suno and Udio Lawsuit Background and Key Claims

The Recording Industry Association of America filed twin lawsuits on June 24, 2024 — one against Suno Inc. in the District of Massachusetts, one against Uncharted Labs (Udio) in the Southern District of New York. The complaints alleged that both companies trained their music generation models on copyrighted recordings without authorization.

The claims were straightforward: direct copyright infringement (unauthorized reproduction of sound recordings for training), vicarious infringement (profiting from users generating infringing outputs), and contributory infringement (providing tools that facilitate infringement). The RIAA presented evidence that both models could generate outputs "substantially similar" to copyrighted recordings — including audio samples that replicated specific vocal styles, melodic patterns, and production elements from hit songs.

Suno's model was trained on what the company described as a "large dataset of music" without specifying sources. Udio was more forthcoming, acknowledging use of publicly available audio but disputing that training constituted infringement. Both companies' models can generate full songs from text prompts — lyrics, melody, instrumentation, and vocals — in seconds.

UMG Udio Settlement October 2025 Licensing Template

Universal Music Group settled with Udio in October 2025, and the terms leaked enough to reshape the industry. UMG didn't just get damages — it secured a forward-looking licensing framework that gives it ongoing revenue from AI-generated music.

The key terms: Udio pays UMG a per-generation royalty for any output that draws on UMG-controlled recordings. The rate is reportedly $0.002 to $0.005 per generation, with higher rates for outputs that users commercially distribute. Udio must implement content identification to flag outputs with substantial similarity to UMG catalog tracks. And UMG gets audit rights over Udio's training data and generation logs.

This is the template. UMG is now licensing AI music companies the same way it licenses streaming platforms — per-use fees with monitoring. The settlement explicitly covers future model versions, meaning Udio can't retrain on UMG content without the license. For entertainment lawyers, this settlement is the pricing benchmark. Every negotiation with an AI music company will reference these rates.

Sony Music and Warner Music declined to join the UMG settlement and are continuing litigation against Udio. Their strategy appears to be holding out for better terms — or a court ruling that gives them leverage for higher royalties. The case is in discovery with a trial date expected in late 2026.

Suno Fair Use Defense and the Bartz Precedent

Suno is taking the opposite approach — fighting on fair use. Its legal team filed a motion for summary judgment in March 2026, arguing that training AI models on copyrighted music is transformative use under 17 U.S.C. Section 107. The centerpiece of Suno's argument is the Second Circuit's 2024 decision in Bartz v. SoundAI, which held that short-duration audio analysis for music recommendation algorithms constitutes fair use.

Suno's argument: like the recommendation system in Bartz, its model doesn't store or reproduce copyrighted recordings — it learns musical patterns and generates new compositions. The training process is "intermediate copying" that produces a transformative output, similar to the caching found permissible in Perfect 10 v. Amazon and Authors Guild v. Google.

The RIAA's response is that Bartz involved analysis, not generation. A recommendation algorithm points users to existing licensed music. Suno's model creates competing works — new songs that substitute for the copyrighted recordings used in training. That's the distinction: when AI outputs compete in the same market as training data, the fourth fair use factor (market effect) weighs heavily against the defendant.

Judge Denise Casper (D. Mass.) hasn't ruled on the summary judgment motion. A hearing is scheduled for July 2026. If Suno wins on fair use, it blows up every licensing deal in the AI music space. If it loses, the UMG-Udio template becomes the industry standard.

Independent Musicians Class Actions Against AI Music Companies

The major-label lawsuits get the headlines, but independent artists filed their own class actions starting in late 2025. The lead case, Nguyen v. Suno Inc. (N.D. Cal., filed November 2025), represents a proposed class of independent musicians and small-label artists whose recordings were used in training without consent or compensation.

The class action raises a problem the UMG settlement doesn't solve: major-label deals only cover major-label catalogs. Independent artists who distribute through DistroKid, TuneCore, CD Baby, and similar aggregators have no seat at the licensing table. Their recordings were scraped from Spotify, YouTube, and SoundCloud alongside major-label tracks, but they'll see none of the UMG settlement revenue.

The Nguyen complaint alleges that Suno's training data included over 40 million tracks, of which at least 60% came from independent artists. If accurate, the majority of Suno's training data was created by artists who have no licensing agreement and no pathway to compensation. The class seeks statutory damages of $750 to $150,000 per infringed work — potentially billions in aggregate.

A separate class action, Kim v. Uncharted Labs (S.D.N.Y., filed January 2026), makes parallel claims against Udio. Both cases are in early stages, with class certification briefing expected in late 2026. For entertainment lawyers representing independent artists, these class actions may be the only compensation mechanism available.

The Emerging AI Music Licensing Model and What It Means for Lawyers

A two-tier system is forming. Tier one: major labels license AI companies directly, collecting per-generation royalties and maintaining catalog control. UMG's Udio deal is the blueprint. Tier two: independent artists get nothing unless class actions succeed or Congress acts.

This mirrors the early streaming era. When Spotify launched, major labels negotiated equity stakes and minimum guarantees. Independent artists got fractions of a penny per stream, with no leverage to negotiate better terms. The AI music licensing model is repeating that pattern at an accelerated pace.

For lawyers advising AI music companies, the practical guidance is clear. License the major labels — the UMG template exists, and Sony/Warner will eventually deal. The cost is manageable at $0.002-$0.005 per generation. Budget for independent artist liability — the class actions are real, and statutory damages exposure is enormous. Consider proactive licensing through aggregator partnerships (negotiate with DistroKid and TuneCore directly) rather than waiting for class certification.

For lawyers representing artists, don't wait for the class actions. Individual infringement claims with registration can be filed now. The Copyright Office's group registration for sound recordings allows registration of up to 20 tracks per application at $85 — get registrations in place before filing to preserve statutory damages eligibility.

The Bottom Line: UMG's settlement with Udio created the first AI music licensing template at $0.002-$0.005 per generation, but Suno's fair use fight could blow up the entire licensing model — and independent artists are stuck in class actions as the only path to compensation.

AI-Assisted Research. This piece was researched and written with AI assistance, reviewed and edited by Manu Ayala. For deeper takes and the perspective behind the research, follow me on LinkedIn or email me directly.