A judge dismissed copyright claims over Flo Milli’s 2023 single ‘Never Lose Me’ on Friday, November 6, 2026, after ruling that the plaintiff, Shamar Deal, does not own the rights to a beat sampled in the track. The court dismissed the lawsuit without an opportunity to amend, according to a ruling first reported by Billboard.
Deal, a Baltimore-based artist, said he purchased a beat called ‘Youu’ on the Traktrain instrumental marketplace in 2019. He said he paid $200 for a 10-year exclusive license. He alleged that producer Gerreaux Katana later relicensed the same beat to Babyface Ray and 42 Dugg for their 2023 song ‘Ron Artest.’ Flo Milli sampled ‘Ron Artest’ on ‘Never Lose Me,’ which peaked at No. 15 on the Billboard Hot 100. Deal sued all three rappers for copyright infringement.
Ruling on license validity
Judge André Birotte Jr. found that Deal does not own the rights to ‘Youu’ because copyright law requires exclusive licenses to be signed by both parties. Traktrain did not obtain Katana’s signature for the sale to Deal. Deal argued that Katana’s upload of the beat to Traktrain and acceptance of the $200 payment should be enough to validate the license. Birotte rejected that argument, citing a decades-old appellate ruling on transfers of copyright ownership.
The ruling highlights a potential pitfall of online instrumental marketplaces, which have become a common source of beats for aspiring rappers in recent years. Experts have previously told Billboard that casual licensing arrangements can later create problems for artists and producers.
Appeal and responses
Deal’s attorney, Larry Zerner, told Billboard on Friday that the plaintiff respectfully disagrees with the decision and plans to appeal. Zerner said he is confident the Ninth Circuit will see it the plaintiff’s way. David Given, a lawyer representing Babyface Ray and his distributor EMPIRE, said his clients were grateful for the court’s decision dismissing the case against them. Representatives for Flo Milli and 42 Dugg did not immediately respond to requests for comment.
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Source: Billboard
