Judge Dismisses Copyright Suit Over Flo Milli Song
A federal judge threw out a Baltimore artist's claim that Flo Milli's hit 'Never Lose Me' infringed his rights to a beat he licensed.
Updated on Nov. 7, 2026 in Hip-Hop and Rap
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A federal judge dismissed copyright claims brought by Baltimore-based artist Shamar Deal against rapper Flo Milli over her song 'Never Lose Me.' Deal's attorney said he intends to appeal the ruling.
Why it matters
The ruling turns on whether an exclusive beat license is valid without the copyright holder's signature, a requirement that determines who actually owns rights to a sampled production. It is a reminder that rappers and producers can face sample disputes that hinge on paperwork rather than the music itself.
The lawsuit centers on a $200, 10-year exclusive license for the beat 'Youu' purchased in 2019, which was later sampled on a song that peaked at No. 15 on the Billboard Hot 100. The court's order, entered without leave to amend, leaves open whether Deal will pursue the planned appeal to the Ninth Circuit.
The players
Flo Milli
Flo Milli is an Alabama rapper known for her viral hits and her 2023 single 'Never Lose Me,' which was the subject of the lawsuit.
André Birotte Jr.
André Birotte Jr. is a federal judge in the U.S. District Court for the Central District of California who presided over the case and issued the dismissal.
The details
Judge André Birotte Jr. found that the producer, Gerreaux Katana, never signed the license transferring the beat from Traktrain to Deal, as copyright law requires for exclusive licenses. Katana later relicensed the same beat, under the title 'Ron Artest,' to rappers Babyface Ray and 42 Dugg, and Flo Milli sampled it on 'Never Lose Me.'
Timeline
2019: Shamar Deal purchased the beat 'Youu' on Traktrain.
2023: 'Never Lose Me' was released, sampling the relicensed 'Ron Artest.'
2025: Deal filed the copyright lawsuit.
November 6, 2026: The court dismissed the lawsuit.
Industry Dynamics
The ruling applies the Copyright Act of 1976's requirement that exclusive transfers be signed by the copyright holder to a beat-licensing dispute in hip-hop. It reinforces that the informal marketplace for beats, where producers sell the same instrumental to multiple artists, can create ownership conflicts that only surface when a hit song samples the track.
For listeners, the dismissal means 'Never Lose Me' remains available on streaming platforms without any pending court action against its use of the sample. Producers and artists buying beats should confirm that any exclusive license is signed by both parties before relying on it.
The takeaway
Exclusive beat deals are only as strong as their paperwork. Artists and producers should get both signatures on any exclusive license before a track is released, since a missing signature can unravel ownership years later.
What happens next
Deal's attorney has said the plaintiff intends to appeal the dismissal to the Ninth Circuit.
Further reading
For more on how sampling and beat licensing work in the genre, see Hip-Hop and Rap coverage.
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