# Flo Milli Wins Dismissal of Copyright Lawsuit Over ‘Never Lose Me’

Judge rules plaintiff lacks valid copyright ownership due to missing signatures on licensing agreements.

- **Source:** [Billboard](https://www.billboard.com)
- **Published:** 2026-11-07
- **Topic:** [politics](https://brifing.si/c/politics)
- **Original article:** <https://www.billboard.com/pro/flo-milli-wins-never-lose-me-copyright-lawsuit-dismissal/>
- **On Brifing:** https://brifing.si/s/f8327841-a017-4a0b-85b2-e3581ea610c5

## Court Dismisses Copyright Claims

Judge André Birotte Jr. dismissed a copyright infringement lawsuit against rapper Flo Milli regarding her 2023 hit song, Never Lose Me. The court ruled that the plaintiff, Shamar Deal, failed to prove legal ownership of the beat used in the track. The case was dismissed without any opportunity for the plaintiff to amend.

## Dispute Over Beat Licensing

Shamar Deal, a Baltimore-based artist, claimed he purchased an exclusive 10-year license for a beat titled Youu on the Traktrain marketplace in 2019 for $200. He alleged that producer Gerreaux Katana subsequently relicensed the same beat to other artists, leading to the unauthorized use of the sample in Flo Milli's popular song.

## Missing Legal Signatures

The court determined that the licensing agreement was invalid under copyright law because it lacked a signature from the original copyright holder, Gerreaux Katana. Judge Birotte emphasized that exclusive licenses require formal written consent from both parties, rejecting the argument that payment and digital platform uploads alone constitute a valid legal transfer.

## Standard for Copyright Transfers

Citing established appellate rulings, the judge maintained that copyright transfers must be documented with a signed piece of paper to be enforceable. Despite Deal’s assertion that the producer’s acceptance of funds and email confirmations validated the deal, the court found no room for ambiguity regarding the necessity of a formal written contract.

## Industry Risks in Marketplaces

This ruling highlights significant risks for independent artists who rely on online instrumental marketplaces to source production. While these platforms offer convenience, the lack of rigorous legal documentation can leave buyers vulnerable to infringement claims. The case underscores the critical importance of formalizing music industry transactions to ensure long-term legal protection.

## Plaintiff Plans to Appeal

Attorney Larry Zerner, representing Shamar Deal, expressed disagreement with the court's decision and confirmed plans to appeal to the Ninth Circuit. He argued that the ruling ignores the standard practices of thousands of independent artists who purchase beats online daily, asserting that their financial investments deserve robust legal recognition and contractual security.

## Defense and Industry Reaction

David Given, representing Babyface Ray and distributor EMPIRE, stated that his clients are grateful for the court’s carefully reasoned decision. Meanwhile, representatives for Flo Milli and 42 Dugg did not provide immediate comments regarding the ruling. The legal battle continues as the plaintiff seeks to challenge the court's interpretation of licensing.

## Broader Implications for Artists

The outcome serves as a cautionary tale for the digital music economy, where informal agreements often precede professional releases. As streaming hits frequently involve sampled beats from online marketplaces, this case may influence how platforms handle licensing contracts. Artists must now prioritize verified legal documentation to avoid future litigation over their intellectual property.

## Sources covering this story

- https://www.billboard.com/pro/flo-milli-wins-never-lose-me-copyright-lawsuit-dismissal/ — 

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_Summary written by Brifing from the original reporting. Copyright in the original article belongs to its publisher; read the full piece at the link above._
