Ramani v. Warner Music Group Corp
- Kimba Wood
- 1:24-cv-07445
- U.S. District Court · Southern District of New York
- 8
Ramani v. Warner Music, Judge Wood dismissed the complaint for lack of jurisdiction but allowed 30 days to amend.
Valmiki Ramani's complaint against Warner Music Group Corp. was dismissed for lack of subject-matter jurisdiction, but Ramani was given 30 days to file an amended complaint.
What happened
In Valmiki Ramani v. Warner Music Group Corp., Valmiki Ramani, who represented himself, claimed Warner wrongfully collected royalties from his music video after he licensed a melody used in it. He sought $500,000.
The court found no basis for federal-question jurisdiction because the complaint did not identify a federal-law claim and appeared to concern a licensing agreement under state law. It also found no diversity jurisdiction because Ramani stated that both he and Warner reside in New York.
Judge Kimba M. Wood dismissed the complaint for lack of subject-matter jurisdiction and granted Ramani 30 days to file an amended complaint. The court also denied fee-free status for any appeal and said judgment would be entered if no amended complaint was filed.
The detailed version
- Ramani v. Warner Music Group Corp · No. 1:24-cv-07445
- Kimba Wood
- June 5, 2025
Background
Valmiki Ramani, proceeding without a lawyer, sued Warner Music Group Corp. He alleged that he wrote and produced a music video called “My Mystery Love,” using a melody from “Secret Love” after paying for a license. Ramani alleged that Warner nevertheless monetized the video worldwide, gave him 20% of the income, and had no right to exploit his property without permission. He sought $500,000 in damages.
The court had previously allowed Ramani to proceed without paying filing fees. The opinion also states that Ramani had separately been barred from filing new civil actions without paying fees unless he first obtained court permission, but that restriction was issued after this action was filed.
Jurisdictional Analysis
The court explained that federal district courts generally have jurisdiction over claims arising under federal law or over disputes between citizens of different states when more than $75,000 is at stake.
The court found no federal-question jurisdiction. Ramani did not allege that Warner violated a federal law. Instead, his allegations appeared to concern the meaning and effect of a licensing agreement—specifically, whether the agreement allowed him to use the “Secret Love” melody without paying royalties to Warner. The court characterized that as an apparent state-law claim.
The court also found no diversity jurisdiction. The complaint stated that both Ramani and Warner reside in New York, which the court said prevented the required complete diversity for state-law claims. The opinion does not provide additional citizenship information that would change that analysis.
Disposition
The court dismissed the complaint for lack of subject-matter jurisdiction under Rule 12(h)(3) of the Federal Rules of Civil Procedure. This was a jurisdictional dismissal rather than a decision on whether Warner actually had the right to collect royalties.
The court granted Ramani 30 days’ leave to replead, meaning he could file an amended complaint with facts showing that his claims arise under federal law. The court said it could not conclude that amendment would be futile. If Ramani did not file an amended complaint within the permitted time, the clerk would be directed to enter judgment.
The court certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. It directed the clerk to keep the action open until a civil judgment was entered.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.