Flo Milli has prevailed in a copyright lawsuit aimed at “Never Lose Me,” the breakthrough track that became her first Billboard Hot 100 entry and ultimately reached the Top 20. A judge dismissed songwriter Shamar Deal’s infringement claim after determining that Deal did not own the beat central to the dispute.
The ownership finding was the decisive issue. Deal’s complaint traced an alleged chain of infringement from producer Gerreaux Katana’s instrumental “Youu,” to Babyface Ray and 42 Dugg’s 2023 track “Ron Artest,” and then to Flo Milli’s “Never Lose Me,” which sampled “Ron Artest.” But that theory depended on Deal holding the copyright rights he claimed to have acquired years earlier. The court found that his agreement did not make him the owner of the underlying beat.
That conclusion ended Deal’s copyright claim against Flo Milli and the other defendants named in the suit: Babyface Ray, 42 Dugg, Katana, Sony Music Entertainment and EMPIRE Distribution. The complaint sought at least $1 million in damages.
The disputed path from beat license to hit song
Deal filed suit in June 2025. His argument centered on a 2019 transaction through the instrumental marketplace Traktrain, where he said he purchased an exclusive 10-year license to Katana’s beat “Youu.” He maintained that the later uses of the beat conflicted with rights he believed came with that license.
The sequence matters because this was not presented as a simple allegation that Flo Milli directly took Deal’s work. Instead, the claim was built in stages:
- Deal said he obtained an exclusive license for “Youu” in 2019.
- Katana later licensed the beat for “Ron Artest,” the Babyface Ray and 42 Dugg song released in 2023.
- Flo Milli sampled “Ron Artest” for “Never Lose Me.”
- Deal argued that the alleged violation therefore extended through each subsequent use.
In practical terms, the lawsuit required Deal to establish the first link before the court needed to reach the later ones. Judge Andre Birotte Jr. found that Deal was not the copyright owner of the beat. Without that ownership, the infringement claim could not proceed through the later recording and sampling path described in the complaint.
Why an “exclusive” license was not enough here
The word exclusive can sound definitive in a music-beat transaction, but exclusivity and copyright ownership are not automatically the same thing. An exclusive license may describe who may use a work, or the extent to which others may be excluded from particular uses. Copyright ownership, meanwhile, concerns who holds the legal rights in the protected work itself.
Those distinctions are especially important in disputes involving instrumental marketplaces, where participants may use broadly familiar shorthand such as “buying a beat.” That phrase can describe many different arrangements. The controlling question in this case was not simply whether Deal had entered an agreement or whether that agreement was characterized as exclusive. It was whether the agreement made him the owner of the copyright rights needed to bring this infringement action.
The ruling said it did not. Once that threshold was resolved, the rest of the claim no longer had a foundation. Deal could not use the later recordings as the basis for a copyright case because the court found he lacked ownership of the underlying composition at the start of the asserted chain.
A few terms that clarify the dispute
- Beat: In this context, the instrumental work at the center of the licensing dispute, identified as “Youu.”
- Underlying composition: The musical work from which the claim began. The court’s ownership finding concerned this foundational work rather than merely a later released recording.
- License: Permission or a grant of defined rights to use a work. Its precise language can determine whether it transfers ownership or only authorizes use.
- Sample: Use of material from an earlier recording in a later song. “Never Lose Me” sampled “Ron Artest,” which itself used the beat Deal claimed rights in.
- Copyright infringement claim: A legal claim asserting unauthorized use of protected material. As this dismissal shows, a claimant must first have the required copyright interest to pursue that claim.
The dismissal turns on the first step, not the song’s success
“Never Lose Me” had a great deal at stake culturally and commercially because it was a defining release in Flo Milli’s rise. Released in late 2023, it expanded the Mobile, Alabama artist’s reach beyond the audience she had developed with projects including Ho, Why Is You Here? and You Still Here, Ho?. The record’s momentum later carried into a remix featuring SZA and Cardi B, and it helped anchor the album Fine Ho, Stay.
None of those achievements decided the case. The court’s ruling was narrower and more basic: Deal did not own the beat as alleged, so he could not take an infringement theory from “Youu” through “Ron Artest” and on to “Never Lose Me.” The dismissal therefore does not require a finding about the popularity, quality or cultural impact of Flo Milli’s song. It rests on the legal status of the earlier agreement.
That distinction is useful for listeners, since music disputes can easily become framed as arguments over whether two songs sound related or whether a sample was identifiable. Those questions may be relevant in some cases. Here, however, the ownership issue stopped the lawsuit before Deal could carry his argument further down the sample chain.
What the ruling means for the named parties
For Flo Milli, the immediate result is that the reported copyright claim over “Never Lose Me” has been dismissed. The decision also cuts off the same theory as it applied to Babyface Ray, 42 Dugg, Katana, Sony Music Entertainment and EMPIRE Distribution, all of whom Deal named as defendants.
For the song’s history, the outcome leaves its release and chart record intact. “Never Lose Me” remains the song that delivered Flo Milli’s first appearance on the Billboard Hot 100 and a Top 20 peak, while marking a major point of expansion for her radio, streaming and mainstream visibility.
For creators and people navigating beat licenses, the case illustrates why the actual allocation of rights is more consequential than a marketplace label alone. A deal described as exclusive may still raise a separate question about who owns the copyrighted work and what legal claims that person may bring. When later recordings, licenses and samples enter the picture, that original contract can become the hinge for every claim that follows.
It is also a reminder that multiple parties can become involved when a work moves from an instrumental listing to a released song and then to a sampled hit. The lawsuit named artists, a producer, a major music company and a distributor, reflecting the number of participants who may be connected to a release. Yet the court’s ruling shows that a complex set of downstream relationships can still be resolved by a threshold issue at the beginning of the chain.
A business-rights dispute with an unusually layered structure
Music copyright disputes often attract attention at their most visible endpoint: the well-known artist and the hit record. This case began much earlier, with the rights associated with an instrumental. Its layered nature is what made the ownership ruling so consequential. If Deal had needed to prove his case through each stage, the dispute could have involved the scope of the 2019 license, the later licensing of “Youu” for “Ron Artest,” and the sampling connection to “Never Lose Me.”
Instead, the court’s finding on ownership meant the claim did not clear its initial legal requirement. The result emphasizes a core principle in rights disputes: before arguing that someone else used a work without permission, a claimant must establish the rights that permit them to make that accusation.
That focus on contractual and ownership foundations also places the case within the broader business side of entertainment, where rights arrangements can matter as much as the public-facing release. Other disputes in that wider industry space likewise turn on the terms and structure of an agreement, as seen in this report on a settlement involving equity and conditional public shares.
In Flo Milli’s case, the court has dismissed the claim seeking at least $1 million over “Never Lose Me.” The determining factor was not a ruling that followed the sample chain to its final stop, but the finding that Deal’s 2019 agreement did not give him ownership of the beat from which that chain began.
