Beijing Dayou Dingxin Investment Management Partnership, L.P. v. Wang

CourtDistrict Court, N.D. Ohio
DecidedJuly 9, 2024
Docket1:24-cv-00137
StatusUnknown

This text of Beijing Dayou Dingxin Investment Management Partnership, L.P. v. Wang (Beijing Dayou Dingxin Investment Management Partnership, L.P. v. Wang) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beijing Dayou Dingxin Investment Management Partnership, L.P. v. Wang, (N.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

BEIJING DAYOU DINGXIN ) CASE NO. 1:24-cv-137 INVESTMENT MANAGEMENT ) PARTNERSHIP, L.P., et al., ) JUDGE CHARLES E. FLEMING ) Petitioners, ) ) v. ) ) CHAN QIAN WANG, et al., ) ORDER ) Respondents.

I. FACTUAL AND PROCEDURAL BACKGROUND On January 24, 2024, Petitioners, Beijing Dayou Dingxin Investment Management Partnership, L.P. and Suzhou Youtou Cornerstone Enterprise Management Center, L.P. filed a Petition to Recognize and Enforce a Foreign Arbitration Award (the “Petition”) against Respondents Chan Qian Wang and Hao Zhou. (ECF No. 1). Petitioners sought enforcement of an August 18, 2022 arbitration award issued against Respondents by the China International Economic and Trade Arbitration Commission. (Id. at PageID #6–9). The Petition alleges the following facts relevant to the Petition and the underlying arbitration dispute: (i) Respondents are United States citizens and residents of Ohio; (ii) Petitioner and Respondents entered into a “Repurchase Agreement”; (iii) the Repurchase Agreement reflected that Petitioners had invested in and became shareholders of ZUGA Medical, Inc. (“ZUGA”); (iv) the parties anticipated a reorganization of ZUGA and the Repurchase Agreement provided for Respondents to make a lump sum payment of 15 million Chinese Yuan to Petitioners if certain conditions were satisfied; (v) the reorganization was finalized and the relevant conditions were satisfied but Respondents failed to fulfill their obligations and pay the lump sum to Petitioners; and (vi) after attempts to resolve the issue failed, Petitioners submitted the dispute to the China International Economic and Trade Arbitration Commission. (Id. at PageID #2–6). On April 16, 2024, Respondent Wang filed a Notice of Automatic Stay in Bankruptcy, informing the Court of the pendency of Chapter 7 bankruptcy proceedings in the United States Bankruptcy Court for the Northern District of Ohio and a corresponding automatic stay pursuant

to 11 U.S.C. § 362. (ECF No. 13). On April 25, 2024, Respondent Hao Zhou filed a pro se letter entitled “Answer to Summons In A Civil Action.” (ECF No 14). Zhou stated that: (i) the Court lacked personal jurisdiction over him; and (ii) the instant petition to enforce an arbitration award was premature. (Id.). In light of Respondents’ filings, the Court issued an order setting forth a briefing schedule for Petitioners to file responses to Respondent Wang’s notice and Respondent Zhou’s Answer, and for Respondents to file any corresponding replies. (ECF No. 15). On May 27, 2024, Petitioners filed their Response to Respondent Wang’s Notice of Automatic Stay in Bankruptcy. (ECF No. 16). The same day, Petitioners filed their Response to Respondent Zhou’s Answer. (ECF No. 17). On July 1, 2024, Respondent Zhou filed a reply.

(ECF No. 19). II. DISCUSSION A. Notice of Bankruptcy and the Automatic Stay Petitioners concede that the automatic stay applies to Respondent Wang. (Id. at PageID #119). They further argue that the automatic stay does not apply to Respondent Zhou because: (i) automatic stays are extended to non-bankrupt codefendants only in rare circumstances that do not exist in this case; and (ii) Respondent Zhou is jointly and severally liable for the full amount of the arbitration award resulting from his breaches of the underlying contract. (Id. at PageID #119–21). Respondents did not file any reply or arguments concerning this issue. The Notice of Automatic Stay in Bankruptcy confirms that Respondent Wang commenced Chapter 7 bankruptcy proceedings in the United States Bankruptcy Court for the Northern District of Ohio on April 15, 2024. (ECF No. 13; ECF No. 13-1). The parties do not dispute that the automatic stay applies to Respondent Wang and no party has presented arguments that the automatic stay should be extended to Respondent Zhou. The Sixth Circuit has established that the

automatic stay provision under 11 U.S.C. § 362 may be extended to non-debtors in “unusual circumstances.” Parry v. Mohawk Motors of Michigan, Inc., 236 F.3d 299, 314 (6th Cir. 2000) (quoting In re Eagle-Picher Indus., Inc., 963 F.2d 855, 861 (6th Cir. 1992)). But absent unusual circumstances, the stay “does not extend . . . to separate legal entities such as corporate affiliates, partners in debtor partnerships, or to codefendants in pending litigation.” Id. (quoting Patton v. Bearden, 8 F.3d 343, 349 (6th Cir. 1993)). Here, no evidence of “unusual circumstances” has been presented to justify extending the automatic stay to Respondent Zhou. Petitioners contend, with no opposition, that Respondent Zhou is independently liable, jointly and severally, for the full amount of the arbitration award.

Even if unusual circumstances were established, the bankruptcy court would need to extend the automatic stay under its equity jurisdiction pursuant to 11 U.S.C. § 105 before the Court could issue a stay as to Respondent Zhou. See Patton v. Bearden, 8 F.3d 343, 349 (6th Cir. 1993). That has not occurred. Accordingly, the automatic bankruptcy stay applies solely to Respondent Wang. B. Personal Jurisdiction as to Respondent Zhou In his answer, Respondent Zhou objects to personal jurisdiction because: (i) he moved out of Ohio in May 2023 and now resides in California; and (ii) he currently has no business or employment in Ohio. (ECF No. 6). In response, Petitioners argue that personal jurisdiction is proper and comports with the requirements of due process and Ohio’s long-arm statute because Respondent Zhou: (i) transacted business in Ohio that gave rise to the underlying arbitration dispute and Petitioner’s claim to enforce the arbitration award; (ii) breached the Repurchase Agreement in Ohio and engaged in conduct in his capacity as an officer for an Ohio-based corporation (ZUGA); and (iii) resided in Ohio during the pendency of the arbitration and breach of contract underlying the instant proceeding. (ECF No. 17, PageID #124–25). Respondent

Zhou’s reply does not address the issue of personal jurisdiction. (ECF No. 19). Fed. R. Civ. P. 12(b)(2) provides for the dismissal of a complaint based on a lack of personal jurisdiction. Fed. R. Civ. P. 12(b)(2). “The party seeking to assert personal jurisdiction bears the burden of demonstrating that such jurisdiction exists.” Bird v. Parsons, 289 F.3d 865, 871 (6th Cir. 2002) (citing Neogen Corp. v. Neo Gen Screening, Inc., 282 F.3d 883, 887–88 (6th Cir. 2002)). However, courts review a motion to dismiss for lack of personal jurisdiction under a burden-shifting framework: (i) first, the plaintiff makes a prima facie case for personal jurisdiction, which can be done solely through the complaint; (ii) if plaintiff makes a prima facie case, the burden shifts to the defendant, who must support its motion to dismiss with evidence; and (iii) if

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Beijing Dayou Dingxin Investment Management Partnership, L.P. v. Wang, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beijing-dayou-dingxin-investment-management-partnership-lp-v-wang-ohnd-2024.