MWW Group, LLC v. PraSaga LLC

Background

MWW Group, LLC filed a complaint against PraSaga LLC on August 1, 2023. The complaint alleges that the court has subject-matter jurisdiction based on diversity of citizenship. It alleges that MWW Group is a limited liability company existing under Delaware law with its principal place of business in New York, and that PraSaga is a limited liability company existing under Nevada law with its principal place of business in Nevada.

Issue

The court noted that, for diversity jurisdiction, a limited liability company is a citizen of every state where its members are citizens. If an LLC’s members include other non-corporate entities, the party must identify the members and their citizenship through the ownership chain until it identifies every individual and corporation with a direct or indirect interest in the LLC.

Federal Rule of Civil Procedure 7.1 requires a party to file a disclosure statement with its first appearance or pleading. The required form calls for a plaintiff to identify the citizenship of each LLC member. MWW Group had not filed the required disclosure statement.

Ruling

The court ordered MWW Group to file a completed Rule 7.1 disclosure statement by August 15, 2023. The statement must include the information necessary to establish subject-matter jurisdiction based on diversity. Judge Jennifer L. Rochon did not decide the underlying claims in this order.