Sequoia Media v. Redbird Content Corporation
- Valerie Caproni
- 1:24-cv-00342
- U.S. District Court · Southern District of New York
- 2
In Sequoia Media v. Redbird Content, Judge Caproni ordered an amended complaint clarifying LLC citizenship or dismissal without prejudice for lack of jurisdiction.
Sequoia Media must provide information about its LLC members and their citizenships in an amended complaint, or its complaint will be dismissed without prejudice for lack of subject matter jurisdiction. Redbird Content Corporation and Tiff Winton are the named defendants.
What happened
Sequoia Media sued Redbird Content Corporation and Tiff Winton and said the federal court had jurisdiction because the parties were citizens of different states.
The court explained that a limited liability company’s citizenship depends on the citizenship of its members. Sequoia Media identified itself as a Wyoming-based limited liability company but did not identify its members or their citizenships.
The court ordered Sequoia Media to file an amended complaint by January 26, 2024, correcting those deficiencies. Otherwise, the complaint would be dismissed without prejudice for lack of subject matter jurisdiction, Judge Valerie Caproni ruled.
The detailed version
- Sequoia Media v. Redbird Content Corporation · No. 1:24-cv-00342
- Valerie Caproni
- Jan. 18, 2024
Background
Sequoia Media filed a complaint against Redbird Content Corporation and Tiff Winton. The complaint alleged that the court had subject matter jurisdiction based on diversity of citizenship, which generally requires the relevant parties to be citizens of different states.
Jurisdictional Deficiency
The court stated that a limited liability company has the citizenship of its members. A complaint relying on diversity jurisdiction must therefore identify the citizenship of the LLC’s members. If an LLC member is itself an LLC, the complaint must also identify the citizenship of that entity’s members. For corporate members, the complaint must allege the place of incorporation and principal place of business.
Sequoia Media alleged that it was a limited liability company based in Wyoming, but it did not identify its members or their citizenships. The order identified that omission as a deficiency in the complaint.
Order
The court ordered Sequoia Media to file an amended complaint curing the identified deficiencies no later than Friday, January 26, 2024. The court stated that the complaint would be dismissed without prejudice for lack of subject matter jurisdiction if Sequoia Media did not do so. The order addressed the court’s jurisdictional requirements and did not decide the underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.