JBAAM Special Opportunities Fund II LLC v. Rezolve AI plc
- Ronnie Abrams
- 1:25-cv-06762
- U.S. District Court · Southern District of New York
- 2
In JBAAM v. Rezolve AI, Judge Abrams remanded the case because the court lacked diversity jurisdiction.
The plaintiffs and defendants are affected because the case will proceed in New York State court rather than federal court; the federal court did not decide the underlying claims.
What happened
JBAAM Special Opportunities Fund II LLC v. Rezolve AI plc was removed from New York State court to federal court. The federal court questioned whether diversity jurisdiction existed because the parties included foreign parties on both sides, and the defendants conceded that jurisdiction was lacking.
The defendants asked for more time to respond to the complaint, permission to withdraw their removal notice, and a return to state court. The federal court said it could not take further action once it determined that it lacked subject-matter jurisdiction.
Judge Ronnie Abrams remanded the case to New York State court and directed the clerk to close the federal action in its entirety. The order did not decide the underlying claims.
The detailed version
- JBAAM Special Opportunities Fund II LLC v. Rezolve AI plc · No. 1:25-cv-06762
- Ronnie Abrams
- Aug. 21, 2025
Background
The plaintiffs, JBAAM Special Opportunities Fund II LLC and YA II PN, LTD., sued Rezolve AI plc and Dan Wagner in New York State court. The defendants removed the case to the U.S. District Court for the Southern District of New York on August 15, 2025.
On August 20, the federal court ordered the defendants to explain why diversity jurisdiction existed. Diversity jurisdiction is a form of federal jurisdiction based on the parties’ citizenship and the amount in dispute. The court noted that the presence of a foreign plaintiff appeared to eliminate complete diversity because the defendants were also foreign.
The defendants then conceded that diversity jurisdiction was lacking. They asked the court to extend their deadline to respond to the complaint, allow them to withdraw their notice of removal, and remand the case to New York State court.
Court’s reasoning
The court held that it lacked subject-matter jurisdiction, meaning authority to hear the case. It explained that federal law requires remand when a district court determines before final judgment that it lacks subject-matter jurisdiction. The court also stated that, without jurisdiction, it could not take other action in the case.
The court applied the rule that diversity jurisdiction is destroyed when one side includes both citizens and aliens while the opposing side includes only aliens. Based on the parties’ citizenship, the court concluded that this rule applied here.
Disposition
The court remanded the case to New York State court and directed the clerk to close the federal action in its entirety. It did not decide the underlying claims or separately rule on the defendants’ other requests. Judge Ronnie Abrams signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.