Flo Milli's Beat License Lawsuit Dismissed: Why a Missing Signature Matters for Music Producers

A $200 beat purchase has become the center of a federal copyright dispute involving one of hip-hop's most recognizable recent hits.

On November 6, 2026, a federal judge in California dismissed a copyright infringement lawsuit involving rapper Flo Milli's 2023 single Never Lose Me.

The lawsuit was brought by independent artist Shamar Deal, who alleged that he purchased exclusive rights to an instrumental through an online beat marketplace in 2019.

Deal claimed that the producer later licensed the same instrumental to other artists, eventually resulting in its use in Never Lose Me.

But the court did not decide whether the later recordings infringed Deal's claimed rights.

Instead, the lawsuit failed because of a more fundamental issue: Deal had not established that the producer validly transferred the exclusive copyright rights he claimed to own.

The decision provides an important lesson for independent producers, recording artists, and anyone buying or selling exclusive beats online.

A payment confirmation, marketplace listing, or document labeled exclusive license may not be sufficient to establish an enforceable transfer of exclusive copyright rights.

Understanding why requires examining the difference between purchasing permission to use a beat and acquiring an exclusive copyright interest.

What Happened in the Flo Milli Beat License Lawsuit?

The dispute began with a beat titled Youu, created by producer Gerreaux Katana, whose legal name is Gerald Henry.

According to Deal's lawsuit, the producer uploaded the instrumental to Traktrain, an online marketplace where producers sell and license beats.

Deal alleged that he purchased a 10-year exclusive license to the instrumental in September 2019 for $200.

The arrangement allegedly gave him the exclusive right to use the beat to create new recordings during the license period.

Deal later claimed that Gerreaux licensed the same instrumental to rappers Babyface Ray and 42 Dugg.

The instrumental was allegedly incorporated into their 2023 recording Ron Artest.

Flo Milli subsequently sampled Ron Artest in Never Lose Me.

Deal argued that these subsequent uses infringed the exclusive rights he believed he had acquired in 2019.

His lawsuit named multiple defendants, including the artists, producer, and companies involved in distributing the recordings.

The dispute eventually involved claims concerning both the underlying musical composition and the sound recording.

The federal court's November 6 ruling dismissed the copyright claims without resolving whether the later recordings infringed the underlying works. Music Business Worldwide

Why Did the Judge Dismiss the Lawsuit?

The case turned on a provision of U.S. copyright law governing transfers of ownership.

Under Section 204(a) of the Copyright Act, a voluntary transfer of copyright ownership generally must be documented in writing and signed by the rights owner or an authorized agent.

An exclusive copyright license is considered a transfer of copyright ownership for this purpose.

That distinction is critical.

Deal alleged that he had purchased an exclusive license.

However, the court concluded that he had not sufficiently established that Gerreaux signed or otherwise validly executed the transfer.

Deal argued that the producer's conduct demonstrated agreement to the sale.

According to the court's order, the alleged evidence included the producer listing the beat for sale, setting the price, accepting payment, acknowledging the purchase through email, and changing the marketplace listing to show that the beat had been sold.

Deal also relied on a written licensing agreement generated through the marketplace.

But the agreement was signed by the marketplace operator rather than Gerreaux, and Deal had not adequately alleged that the operator possessed authority to sign the transfer on the producer's behalf.

The judge concluded that these circumstances did not establish the required signature or adoption of the relevant written agreement.

Because Deal had not shown that he held the exclusive rights necessary to bring the infringement claims, the court dismissed the case.

The ruling was issued with prejudice and without further permission to amend the complaint.

Deal's attorney has indicated an intention to appeal. As of November 11, an appellate reversal has not been established. Music Business Worldwide

What Does U.S. Copyright Law Require for an Exclusive Beat License?

The governing provision is 17 U.S.C. § 204(a).

It requires a transfer of copyright ownership to be evidenced by a written instrument or memorandum signed by the owner of the rights being transferred, or by that owner's duly authorized agent.

An exclusive license falls within the Copyright Act's definition of a copyright ownership transfer.

A nonexclusive license generally does not.

This creates an important difference between two common beat-licensing arrangements.

Nonexclusive Beat Licenses

A nonexclusive license typically allows an artist to use a beat while the producer retains the ability to license the same instrumental to other customers.

For example, a producer might sell multiple MP3 or WAV leases for the same instrumental.

Each customer receives permission to use the music within the limits of their respective agreements.

A nonexclusive license does not necessarily require the same signed writing as a transfer of exclusive copyright ownership.

However, written terms remain strongly advisable.

Exclusive Beat Licenses

An exclusive license grants specified rights exclusively to one licensee.

The precise scope depends on the contract.

For example, an exclusive license might prohibit the producer from granting additional licenses for certain uses during a defined period.

But exclusivity is not the same as automatically owning every copyright associated with the instrumental.

An exclusive license may be limited by duration, territory, permitted uses, or the particular rights transferred.

Because an exclusive copyright license constitutes a transfer of ownership under U.S. copyright law, the statutory signature requirement becomes relevant.

The Flo Milli dispute illustrates the consequences of failing to establish that requirement.

The official text of Section 204 provides the governing statutory language.

Does an Exclusive Beat License Need a Physical Signature?

Not necessarily.

Electronic signatures can satisfy legal signature requirements when the applicable conditions are met.

The issue in Deal's case was not simply that the producer had failed to sign a paper document with a pen.

Instead, the court examined whether the producer's alleged electronic conduct demonstrated that he had executed or adopted the relevant agreement with the required intent.

The judge concluded that Deal's allegations did not establish that connection.

An email acknowledging payment is not necessarily equivalent to signing a particular contract transferring exclusive rights.

Likewise, marking a beat as sold on a marketplace does not automatically establish that the producer executed the written transfer.

For online beat marketplaces, the practical lesson is that electronic contract systems should clearly identify the parties, the rights being transferred, and the action constituting the rights owner's signature.

A properly implemented electronic-signature process may satisfy the law.

But a platform should not assume that generating a contract automatically establishes a valid exclusive transfer.

What Does This Mean for Producers Selling Exclusive Beats?

The ruling highlights several issues producers should address before selling exclusive rights.

Clearly Identify the Rights Being Licensed

A producer should specify whether the agreement is nonexclusive or exclusive.

If exclusive, the contract should identify the particular rights covered.

For example, does the agreement grant exclusive rights to create new recordings using the instrumental?

Does it include the underlying composition, the master recording, or both?

Does it restrict future licensing?

These questions should not be left to assumptions.

Establish the License Duration

Some exclusive licenses operate for a defined period.

Others may be perpetual, subject to their terms.

A producer selling a 10-year exclusive license should understand what happens when that period ends.

The agreement should address expiration, renewal, and any continuing rights associated with recordings created during the license period.

Document the Transaction Properly

A producer should ensure that the relevant agreement is properly executed.

For an exclusive copyright transfer, that includes satisfying the applicable signature requirement.

A marketplace-generated PDF may be useful, but its legal effectiveness depends on the circumstances.

Maintain Accurate Licensing Records

Producers should retain copies of agreements, payment records, and relevant communications.

They should also track which beats have been licensed exclusively.

If a beat is no longer available for additional licenses, the producer should update the listing accordingly.

Understand Existing Licenses

Selling an exclusive license does not necessarily eliminate previously granted nonexclusive licenses.

The treatment of earlier licenses depends on the relevant agreements and legal circumstances.

Producers should disclose and address existing licenses when negotiating exclusivity.

The most important lesson is that exclusive licensing requires more than selecting an exclusive pricing option on a marketplace.

It requires a legally effective agreement defining the rights involved.

What Should Artists Check Before Buying an Exclusive Beat?

Artists purchasing exclusive instrumentals should also exercise care.

An exclusive beat can become part of a commercially important recording.

If the song later attracts substantial attention, uncertainty about the underlying rights can create expensive disputes.

Before relying on an exclusive license, an artist should verify that the agreement identifies the correct producer or rights holder.

The artist should also understand whether the seller actually controls the rights being transferred.

If the instrumental contains samples or contributions from other creators, the producer may not possess unrestricted authority to license every element.

The agreement should specify what the artist is allowed to do with the beat.

That may include recording vocals, distributing the resulting song, creating music videos, performing the song live, or licensing the recording for other uses.

Artists should also verify that the agreement is properly executed.

For exclusive transfers, the signature of the relevant rights owner or authorized agent is particularly important.

Finally, artists should preserve their records.

A receipt can establish that payment occurred.

It does not necessarily establish the full scope or validity of an exclusive copyright transfer.

Why the Difference Between Master Rights and Publishing Rights Matters

Beat licensing can involve more than one category of copyright.

The underlying musical composition and the sound recording are legally distinct.

A producer might own both.

Alternatively, different parties may control different interests.

For example, a beat could contain an original composition created by multiple writers.

The finished instrumental recording could also involve separate master ownership.

When an artist records vocals over the beat, the resulting song may introduce additional songwriting and recording interests.

An exclusive license should therefore identify which rights are being transferred or licensed.

A contract granting permission to use the master recording does not automatically resolve every question concerning the underlying composition.

Similarly, a producer's songwriting credit does not necessarily establish that the producer owns the finished master.

These distinctions become especially important when music is sampled, remixed, licensed for advertising, or incorporated into another recording.

The Flo Milli lawsuit involved allegations concerning both sound-recording and composition rights.

The court's ruling focused on Deal's failure to establish a valid exclusive transfer, rather than deciding the merits of the alleged infringement.

Does the Ruling Mean Flo Milli's Song Was Not Infringing?

No.

That would be an inaccurate interpretation.

The court did not determine that the recordings were entirely different or that every use of the underlying material was authorized.

Instead, it concluded that Deal had not established the exclusive copyright ownership necessary to pursue his infringement claims.

This is a procedural and ownership-related distinction.

A plaintiff generally must possess the relevant enforceable rights to bring a copyright infringement action.

If the plaintiff cannot establish those rights, the court may dismiss the case without deciding whether the challenged recording actually infringes.

That is what makes this ruling particularly significant.

The alleged licensing dispute could not proceed to a determination of infringement because the claimed exclusive transfer had not been adequately established.

Could This Affect Other Online Beat Marketplaces?

The ruling does not automatically invalidate exclusive licenses sold through online marketplaces.

Nor does it establish that electronic beat licensing is inherently unreliable.

Instead, it illustrates a risk that can arise when contract execution is unclear.

A marketplace may provide a convenient way for producers and artists to agree on licensing terms.

However, the legal effectiveness of an exclusive copyright transfer depends on satisfying the applicable requirements.

Platforms facilitating these transactions should consider whether their systems clearly establish the identity and authority of the rights holder, record the specific agreement accepted, and preserve reliable evidence of execution.

For example, a platform might use an electronic-signature workflow tied to the final contract.

It might also retain an audit trail showing when the rights holder reviewed and executed the agreement.

Those practices can help create better evidence of the transaction.

However, the presence of an electronic signature or audit trail does not guarantee that every contract is legally enforceable.

The parties must still possess the relevant rights and agree to valid terms.

What About Beat Leases, WAV Licenses, and Stem Licenses?

The Flo Milli ruling concerns an alleged exclusive copyright transfer.

That should not be confused with the different file formats commonly offered in beat stores.

An MP3 lease, WAV lease, or trackout license often describes the type of audio deliverable and the accompanying contractual permissions.

For example, a WAV license may provide a higher-quality audio file than an MP3 license.

A trackout license may provide separate stems that allow an artist or engineer to adjust individual elements.

But file quality does not determine copyright ownership.

A customer who receives stems does not automatically own the underlying composition.

Likewise, purchasing a WAV file does not automatically provide exclusive rights.

The legal distinction depends on the license terms, not merely the file format.

Producers should make these differences clear when presenting licensing options.

Artists should review the agreement rather than relying solely on product labels.

What This Means for AudToro's Beat Marketplace

The ruling is particularly relevant to marketplaces connecting independent artists and producers.

AudToro allows producers to offer beats while also providing services such as recording, mixing, and mastering.

For a marketplace offering exclusive beat licenses, the case highlights the importance of clearly documented transactions.

A strong licensing workflow should distinguish between nonexclusive and exclusive permissions.

It should also identify the relevant rights holder and provide an appropriate method for executing exclusive transfers.

For producers, the marketplace experience should make it clear which rights they are granting.

For artists, the purchase process should provide understandable terms and reliable records.

A beat marketplace can facilitate the transaction, but it should not imply that a payment confirmation alone guarantees the validity of every exclusive copyright transfer.

The same principle applies to producers selling beats independently.

The goal is to make rights and responsibilities clear before a recording becomes commercially successful.

Five Practical Lessons From the Flo Milli Ruling

First, exclusive rights require careful documentation. A producer and artist should not assume that selecting an exclusive product option automatically completes a valid copyright transfer.

Second, electronic signatures can be valid, but their implementation matters. The relevant rights holder or authorized agent must properly execute the transfer.

Third, payment records and licensing agreements serve different purposes. A receipt proves a transaction occurred; it does not necessarily establish the full legal scope of the rights acquired.

Fourth, producers should maintain accurate records of previous licenses. Selling exclusivity without accounting for earlier grants can create conflicts.

Fifth, artists should review licensing terms before releasing commercially important recordings. Uncertainty about beat ownership may become much more consequential after a song gains traction.

These lessons are relevant whether a beat costs $20, $200, or substantially more.

The price does not determine whether an exclusive copyright transfer satisfies the law.

Frequently Asked Questions

Why was the Flo Milli copyright lawsuit dismissed?

The federal court concluded that Shamar Deal had not established a valid transfer of the exclusive rights he claimed to own.

The producer had not signed the relevant agreement, and the alleged electronic conduct did not satisfy the court's requirements.

When was the ruling issued?

The court issued its dismissal order on November 6, 2026.

The decision was reported by music-industry publications on November 10.

How much did the disputed beat license cost?

Deal alleged that he paid $200 for a 10-year exclusive license to the instrumental Youu in 2019.

Does an exclusive beat license need to be signed?

Under U.S. copyright law, an exclusive copyright transfer generally must be evidenced by a writing signed by the rights owner or an authorized agent.

Can electronic signatures be used for exclusive beat licenses?

Yes, electronic signatures may satisfy the requirement when properly executed under applicable law.

The specific circumstances matter.

Does buying an exclusive beat mean owning the copyright?

Not necessarily.

An exclusive license can transfer specified exclusive rights without transferring every copyright interest in the underlying work.

The agreement determines the scope.

Can producers sell the same beat multiple times?

Producers can generally offer multiple nonexclusive licenses when they control the relevant rights and their agreements permit it.

An exclusive license may restrict additional licensing within its scope.

Does receiving WAV stems mean an artist owns the beat?

No.

Receiving audio files or stems does not automatically transfer copyright ownership.

The applicable license governs the customer's rights.

Did the judge decide that Never Lose Me was not infringing?

No.

The ruling addressed Deal's ability to bring the infringement claims, not whether the challenged recordings infringed the underlying works.

Can the decision be appealed?

Deal's attorney has indicated an intention to appeal.

An intended appeal does not mean that an appellate court has reversed the ruling.

The Bottom Line

The November 6 dismissal of the copyright lawsuit involving Flo Milli's Never Lose Me offers an important lesson for the independent music industry.

A beat license can appear straightforward when a producer uploads an instrumental and an artist completes a purchase.

But exclusive copyright rights involve legal requirements that go beyond payment processing.

The court concluded that Deal had not established a valid exclusive transfer because the necessary signature requirement had not been satisfied.

For independent producers and artists, the implications are significant.

An exclusive beat license should be supported by a properly executed agreement that clearly identifies the rights being transferred.

As online beat marketplaces continue connecting creators, clear licensing terms, reliable records, and legally effective execution will remain essential.

The goal is not to make music collaboration unnecessarily complicated.

It is to ensure that the agreements creators rely on can support the rights they believe they have acquired.

Verified Sources and Further Reading

Primary legal source — November 6, 2026

U.S. District Court: Shamar Deal v. Gerald Henry, Order Granting Motion to Dismiss

Official federal copyright law

17 U.S.C. § 204 — Execution of Copyright Ownership Transfers

U.S. Copyright Office — Copyright Ownership Transfers and Recordation

Independent industry reporting — November 10, 2026

Music Business Worldwide — Judge Dismisses Flo Milli Beat License Lawsuit

Digital Music News — Flo Milli Copyright Lawsuit Dismissed Over Unsigned License