MWW Group, LLC v. PraSaga LLC

Background

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

The court had previously ordered MWW Group to file a statement identifying its ownership. That statement said MWW Group’s members were citizens of New York, Washington, D.C., New Jersey, Florida, Illinois, and Maryland.

Jurisdictional Issue

For diversity jurisdiction, a limited liability company is treated as a citizen of every state where its members are citizens. If an LLC’s members include other non-corporate entities, the party invoking federal jurisdiction must identify and allege the citizenship of the ownership chain until the citizenship of every relevant individual and corporation is established.

MWW Group’s complaint did not allege the citizenship of PraSaga’s LLC members. As a result, the court could not determine whether it had subject-matter jurisdiction over the dispute.

Order

Judge Jennifer L. Rochon ordered MWW Group to file, no later than August 23, 2023, a letter supported by one or more sworn affidavits. The filing must provide the information needed for the court to exercise subject-matter jurisdiction, including the identity and citizenship of PraSaga’s members and, if necessary, the identity and citizenship of any members of PraSaga’s members that are themselves limited liability companies.

The order addresses only whether the court can establish federal jurisdiction. It does not decide the parties’ underlying dispute.