Business Court Remands for Lack of Qualified Transaction: Unconsummated Bids and Forecasts Insufficient to Establish Jurisdiction

In G-Force & Associates v. Bloecher, Judge Bullard remanded a trade secrets and non-compete dispute, holding that construction-project bids and revenue forecasts do not constitute a "qualified transaction" under Section 25A.001(d)(1) because they involve no consummated agreement obligating consideration of at least $10 million. The court further held that Section 25A.004(e) injunctive-relief jurisdiction is contingent on first establishing subsection (d)(1) jurisdiction.