Global Media Network v. iHeartRadio
- Laura Swain
- 1:25-cv-05554
- U.S. District Court · Southern District of New York
- 2
In Global Media Network v. iHeartRadio, Judge Swain dismissed the complaint without prejudice because the entity could not proceed without paying filing fees.
Global Media Network's complaint was dismissed without prejudice because it could not proceed under the federal fee-waiver process without paying the $405 filing fee. The order also denied fee-waiver status for an appeal and stated that the entity would need counsel to proceed.
What happened
Global Media Network sued iHeartRadio, but the court had ordered Global Media Network to pay the $405 filing fee because an artificial entity cannot proceed without paying through the program that waives fees for people. Global Media Network instead submitted an application saying it had earned only $75 in the past year.
The court ruled that Global Media Network could not use that fee-waiver program and dismissed the complaint without prejudice. The court directed the Clerk of Court to enter judgment.
Judge Laura Taylor Swain also ruled that an appeal would not be taken in good faith and denied fee-waiver status for an appeal. The order said Global Media Network could move to reopen the case if it paid the filing fee within the deadline, but it would also need a lawyer because an artificial entity cannot proceed without counsel.
The detailed version
- Global Media Network v. iHeartRadio · No. 1:25-cv-05554
- Laura Swain
- July 17, 2025
Background
The court had previously ordered Plaintiff Global Media Network to pay the $405 fee required to file a civil action. The court explained that only a natural person—not an artificial entity such as a corporation—can proceed under the federal fee-waiver process, commonly called proceeding without prepaying filing fees.
Global Media Network submitted an application stating that it was “in the startup phases” and had earned only $75 during the previous year. The court concluded that the plaintiff could not proceed under that fee-waiver process.
Ruling
The court dismissed the complaint without prejudice under 28 U.S.C. §§ 1914 and 1915. It directed the Clerk of Court to enter judgment. “Without prejudice” means the dismissal did not bar refiling, subject to the requirements stated by the court.
The order stated that if Global Media Network paid the $405 fee within the 30-day deadline, it could move to reopen the action. The court also stated that a corporation or other artificial entity cannot proceed without counsel.
The court certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith and denied fee-waiver status for purposes of an appeal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.