Perpetual Royalty Agreement Satisfies Qualified Transaction and Amount-in-Controversy Requirements for Business Court Jurisdiction

In Yaun v. Battle & Sands Energy Corp., Judge Dorfman denied a motion to remand, holding that a perpetual royalty agreement on frac sand sales constitutes a qualified transaction under Section 25A.004(d)(1) where the plaintiff may be "entitled to receive" consideration exceeding $5 million, and that HB 40's reduced jurisdictional thresholds apply retroactively to actions commenced on or after September 1, 2024. The court applied the C Ten burden-shifting framework and found the removing defendants' pleadings—combined with plaintiff's own evidence projecting $6.4 million in royalties over three years of a perpetual agreement—established at least the plausibility that damages exceed the jurisdictional minimum.