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25-BC01B-0006 Riverside Strategic Capital Fund I v. CLG Investments
Analysis
Discovery Rule and Inquiry Notice Bar Fraud Claims Against Healthcare Investment Defendants Despite Alleged Concealment
In Riverside Strategic Capital Fund I v. CLG Investments, 2025 Tex. Bus. 35, the Business Court of Texas granted traditional summary judgment on statute of limitations grounds, holding that inquiry notice more than four years before suit was filed barred fraud, money had and received, and conspiracy claims arising from a securities purchase agreement. The court found that summary judgment evidence conclusively established plaintiffs were aware of facts that would cause a reasonably prudent person to make an inquiry leading to discovery of their causes of action.
Personal Jurisdiction Requires More Than Investment in Texas-Based Company: Business Court Grants Special Appearance
In Riverside Strategic Capital Fund I v. CLG Investments, 2025 Tex. Bus. 33, Judge Whitehill granted a special appearance by nineteen out-of-state defendants, holding that plaintiffs failed to establish minimum contacts where defendants invested in a Delaware entity governed by Delaware law and made no purposeful contacts with Texas. The court rejected arguments that knowledge of the company's Texas operations, designation of a Texas-based agent, or participation in prior Texas litigation established specific jurisdiction over passive investors.