Ramani v. Warner Music Group Corp

Background

Valmiki Ramani sued Warner Music Group Corp. (“WMG”), alleging that WMG wrongfully obtained royalties from a music video he produced. Ramani alleged that he purchased a license for the song “Secret Love,” wrote “My Mystery Love” using that song’s melody, filmed a music video, and uploaded it to his Facebook channel. He later learned that WMG was receiving royalties from the video because WMG owned the “Secret Love” melody. Ramani asserted that paying the licensing fee gave him total ownership of the video and barred anyone from using or monetizing it.

Earlier Orders and Motion

The court had previously determined that Ramani’s claims concerned the interpretation of a licensing agreement and therefore sounded in contract. It dismissed the action for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3) and gave Ramani 30 days to file an amended complaint stating facts showing that his claims arose under federal law. Ramani filed a document titled “Replead,” but the court concluded that it still did not establish federal-question jurisdiction and again dismissed the action on June 26, 2025.

On July 28, 2025, Ramani filed a letter requesting a “motion package.” The court interpreted the letter as seeking relief from the June 26 order under Federal Rule of Civil Procedure 60(b), which permits a court to provide relief from an order or judgment for specified reasons, including mistake, newly discovered evidence, fraud, or extraordinary circumstances.

Court’s Reasoning

The court denied relief under the first five parts of Rule 60(b). Even assuming Ramani argued that the court had mistakenly treated the dispute as a state-law contract matter rather than a copyright-infringement case, the court found that he alleged no facts suggesting WMG infringed a copyright. The court explained that a copyright-infringement claim requires allegations that the plaintiff owns a valid copyright and that the defendant infringed it. Ramani’s allegations instead showed a disagreement about the licensing agreement and whether WMG was entitled to royalties. The court specifically noted that Ramani did not allege that WMG copied his music video.

The court also denied relief under Rule 60(b)(6), which applies only for reasons different from those listed in the first five parts of the rule. That provision requires a timely motion and extraordinary circumstances warranting relief. The court found that Ramani had not shown extraordinary circumstances.

The court noted that Ramani attached an order from the New York State Supreme Court, Queens County, denying his application to waive court costs, fees, and expenses. The attached material appeared to include a statement that state courts lacked jurisdiction over copyright claims, but the federal court said it was unclear whether the state court had included that statement or whether Ramani had added it. Ramani did not attach his state-court complaint.

Disposition

The court denied Ramani’s motion for reconsideration, which he brought through his July 28 letter. The Clerk was directed to terminate all motions, and the case was closed. The order states that no further documents may be filed except a notice of appeal to the United States Court of Appeals for the Second Circuit. The court certified that any appeal would not be taken in good faith and denied permission to appeal without paying filing fees.