Gryphon Digital Mining, Inc v. K&L Gates LLP
- Rochon
- 1:25-cv-03083
- U.S. District Court · Southern District of New York
- 2
In Gryphon Digital Mining v. K&L Gates, Judge Rochon ordered an amended complaint to properly allege citizenship for diversity jurisdiction.
Gryphon Digital Mining, Inc. must amend its complaint by April 22, 2025 to allege the citizenship of K&L Gates LLP and Robert Honeywell; otherwise, the court will dismiss the case without prejudice and without further notice.
What happened
Gryphon Digital Mining, Inc. sued K&L Gates LLP and Robert Honeywell in federal court, relying on diversity jurisdiction, which requires the parties to be citizens of different states. The complaint alleged Honeywell’s residence rather than citizenship and did not properly allege the citizenship of K&L Gates LLP’s partners.
The court said residence alone does not establish citizenship. It also explained that a limited liability partnership is considered a citizen of every state where its partners are citizens, so the firm’s alleged incorporation in Delaware and headquarters in Pennsylvania were not enough.
Judge Jennifer L. Rochon ordered Gryphon Digital Mining, Inc. to file an amended complaint establishing both defendants’ citizenship by April 22, 2025. The court said it will dismiss the case without prejudice and without further notice if the amended complaint is not filed by then; the order did not decide the underlying claims.
The detailed version
- Gryphon Digital Mining, Inc v. K&L Gates LLP · No. 1:25-cv-03083
- Rochon
- Apr. 15, 2025
Background
Gryphon Digital Mining, Inc. filed a complaint invoking the federal court’s diversity jurisdiction under 28 U.S.C. § 1332. The complaint stated that complete diversity existed but alleged only Robert Honeywell’s state of residence, not his state of citizenship.
The complaint also alleged that K&L Gates LLP was incorporated in Delaware and headquartered in Pennsylvania. The court explained that an LLP’s citizenship depends on the citizenship of its partners, and that an LLP is treated as a citizen of every state of which its partners are citizens. Gryphon had not alleged the citizenship of K&L Gates LLP’s partnership.
Ruling
The court concluded that the complaint did not adequately establish subject-matter jurisdiction. Residence alone is insufficient to establish an individual’s citizenship for diversity purposes, and an LLP’s place of incorporation and headquarters do not establish the citizenship of its partners.
Accordingly, the court ordered Gryphon Digital Mining, Inc. to file an amended complaint properly alleging both defendants’ citizenship no later than April 22, 2025. The court stated that if Gryphon does not file an amended complaint establishing subject-matter jurisdiction by that date, it will dismiss the case without prejudice and without further notice. The order did not reach the merits of Gryphon’s claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.