Really all birds make “noise,” we are the ones that classify some as song and others as not. It’s all about peoples perception of the bird calls. That said some bird calls are more complex then others and this is due primarily to sexual selection. Most bird songs as we know them are actually mating calls to attract females and warn competitors. In some species the females prefer more complex calls as a demonstration of the males capacity as a mate while in other species this preference has not evolved. The same is true about mating dances and certain colorful plumage.
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