Doppelt v. Spectrum Exchange, LLC
- Sidney Stein
- 1:25-cv-05684
- U.S. District Court · Southern District of New York
- 2
Doppelt v. Spectrum Exchange: Judge Stein ordered more ownership-citizenship information because the complaint did not establish complete diversity jurisdiction.
Max Doppelt must provide the identities and citizenships of all members of Xtremis Holdings, LLC and Zylinium Research LLC so the court can assess whether complete diversity jurisdiction exists. Spectrum Exchange, LLC is affected because its citizenship depends on that ownership information.
What happened
In Doppelt v. Spectrum Exchange, LLC, Max Doppelt brought a case relying on diversity jurisdiction, but the complaint did not provide enough information to determine whether the parties were citizens of different states as required.
The court explained that a limited liability company is treated as a citizen of every state where its members are citizens. Spectrum Exchange, LLC was alleged to have Xtremis Holdings, LLC and Zylinium Research LLC as members, but the complaint did not identify all members of those two companies or their citizenships.
Judge Sidney H. Stein directed Doppelt to file a document identifying and stating the citizenship of all members of Xtremis and Zylinium by July 25, 2025. The order did not decide whether complete diversity exists or address the merits of the case.
The detailed version
- Doppelt v. Spectrum Exchange, LLC · No. 1:25-cv-05684
- Sidney Stein
- July 11, 2025
Background
Max Doppelt’s complaint invoked the federal court’s diversity jurisdiction under 28 U.S.C. § 1332. The complaint alleged that Spectrum Exchange, LLC had two members: Xtremis Holdings, LLC and Zylinium Research LLC.
Jurisdictional Issue
For diversity jurisdiction, an unincorporated entity such as a limited liability company is considered a citizen of every state of which its members are citizens. The court stated that a complaint must specifically identify the members of an LLC and their citizenships. If an LLC member is itself a non-corporate entity, the citizenship inquiry continues through that entity’s ownership chain until the citizenship of every individual or entity with a direct or indirect interest has been identified.
The complaint did not identify all members of Xtremis and Zylinium or state their citizenships. Because Spectrum’s citizenship depends on the citizenship of those members, the court could not determine from the complaint whether complete diversity existed between the parties.
Order
The court directed Doppelt to file a document setting forth the identity and citizenship of all members of Xtremis Holdings, LLC and Zylinium Research LLC by July 25, 2025. The order did not decide whether the court has diversity jurisdiction and did not address the underlying legal claims.
Disposition
This was a jurisdictional and pleading-related order requiring additional information. The opinion does not state that the case was dismissed or that any motion was granted or denied.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.