The defense argues this is a victory for legal precision, noting that the court’s decision was 'carefully reasoned' and correctly identified that the plaintiff lacked standing to sue.
Insiders are calling this a wake-up call for the 'beat economy.' If you’re paying for exclusives online, your contract might be worthless if the paperwork isn’t signed, a messy reality for independent artists.
Judge André Birotte Jr. dismissed the case on Nov. 6, 2026, citing that exclusive licenses require signatures. Shamar Deal bought the beat 'Youu' for $200 in 2019, but producer Gerreaux Katana never signed the transfer.
Flo Milli wins the battle, but the war over online beat licensing just got a lot more expensive for everyone involved.
The courtroom drama surrounding Flo Milli’s 2023 smash hit "Never Lose Me" took a sharp turn this Friday when Judge André Birotte Jr. dismissed the copyright lawsuit brought against the rapper and her collaborators. The plaintiff, Baltimore-based artist Shamar Deal, claimed he owned the rights to a beat called "Youu" that was sampled in the track. However, the judge ruled that Deal did not technically own the beat because the exclusive license he purchased in 2019 lacked a crucial element: a signature from the producer.
The dismissal came without any opportunity to amend, signaling the judge’s confidence in the legal technicality. Deal had purchased the beat from producer Gerreaux Katana on the online marketplace Traktrain for $200, securing what he believed was a 10-year exclusive license. The conflict arose when Katana allegedly relicensed the same beat to Babyface Ray and 42 Dugg for their song "Ron Artest," which Flo Milli then sampled.
Deal sued all three rappers, arguing that Katana’s acceptance of the payment and confirmation emails validated the license. But Judge Birotte had none of it, quoting a decades-old appellate ruling that emphasizes the necessity of physical signatures for copyright transfers: "If the copyright holder agrees to transfer ownership to another party, that party must get the copyright holder to sign a piece of paper saying so." The ruling has sent shockwaves through the independent music scene, highlighting the precarious nature of online instrumental marketplaces.
David Given, the attorney representing Babyface Ray and his distributor EMPIRE, expressed gratitude for the decision, calling it "carefully reasoned." Meanwhile, Deal’s attorney, Larry Zerner, fired back in a statement to Billboard, arguing that the online beat economy relies on these casual digital confirmations. "Shamar Deal paid for an exclusive license to this beat," Zerner said, asserting that the producer’s emails and the platform’s confirmation should suffice. "That’s how thousands of independent artists buy beats online every single day, and they deserve to know that the licenses they pay for will hold up." While Flo Milli’s representatives did not immediately return requests for comment, the legal battle is far from over.
Zerner confirmed that Deal intends to appeal the decision to the Ninth Circuit, arguing that the court’s strict interpretation of copyright law ignores the practical realities of modern digital transactions. This case serves as a stark reminder for aspiring rappers and producers alike: in the high-stakes world of music licensing, a $200 transaction can unravel a multi-million dollar hit if the paperwork isn’t perfect. The internet is buzzing with debates about whether the law needs to catch up with the digital age, or if artists need to get better at reading the fine print.
