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Home Cases 25-BC01B-0006 Riverside Strategic Capital Fund I v. CLG Investments

25-BC01B-0006 Riverside Strategic Capital Fund I v. CLG Investments

Texas Business Court, 1st Division 25-BC01B-0006 active

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.

Joel Reese  |  Jul 28, 2026
Private Equity Summary Judgment Statute of Limitations Discovery Rule Inquiry Notice Fraudulent Concealment Securities Purchase Agreement Healthcare

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.

Joel Reese  |  Jul 28, 2026
Personal Jurisdiction Special Appearance Private Equity Minimum Contacts Long-Arm Statute