Ceratosaurus Invs., LLC v. B2C Alternative Equity, LLC

2025 NY Slip Op 50079(U)
CourtNew York Supreme Court, New York County
DecidedJanuary 27, 2025
DocketIndex No. 653758/2024
StatusUnpublished
Cited by1 cases

This text of 2025 NY Slip Op 50079(U) (Ceratosaurus Invs., LLC v. B2C Alternative Equity, LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ceratosaurus Invs., LLC v. B2C Alternative Equity, LLC, 2025 NY Slip Op 50079(U) (N.Y. Super. Ct. 2025).

Opinion

Ceratosaurus Invs., LLC v B2C Alternative Equity, LLC (2025 NY Slip Op 50079(U)) [*1]
Ceratosaurus Invs., LLC v B2C Alternative Equity, LLC
2025 NY Slip Op 50079(U)
Decided on January 27, 2025
Supreme Court, New York County
Borrok, J.
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and will not be published in the printed Official Reports.


Decided on January 27, 2025
Supreme Court, New York County


Ceratosaurus Investors, LLC, BOWAY HOLDINGS, LLC, Plaintiff,

against

B2C Alternative Equity, LLC, RON CHARNIS, Defendant.




Index No. 653758/2024

Counsel for Plaintiffs: Law Offices of Martin Eisenberg, 50 Main Street Suite 1000, White Plains, NY 10606-002

Counsel for Defendants: Jenner & Block LLP, 919 Third Avenue 37th Floor, New York, NY 10016
Andrew Borrok, J.

The following e-filed documents, listed by NYSCEF document number (Motion 001) 5, 6, 7, 8, 10, 11 were read on this motion to/for DISMISS.

The defendants in this case are not entitled to dismissal of this lawsuit based on their argument that the Trade Confirmation (NYSCEF Doc. No. 2; the Agreement) was not a binding agreement or that it was not binding because it was subject to an Assignment of Claim including customary terms.

The plain language of the Agreement undermines this position at this stage of the lawsuit. It says that upon execution (i.e., and not upon execution of the Assignment of Claim), the Agreement is binding. In fact, and to avoid confusion, the parties further agreed that fluctuations in market price could not form a predicate to relieving the parties of their obligations under the Agreement:

Binding Effect: Upon execution by Buyers and Seller, this Confirmation shall constitute a binding agreement among the parties; provided that any party may terminate this Confirmation at any time if it is not satisfied with the form of Assignment of Claim or any transaction document(s) contemplated by this Confirmation following a good faith negotiation with the other parties .. [sic] Seller and each Buyer agree and acknowledge that events occurring subsequent to the Trade Date, including movement in market price for the Claim as described in this Confirmation shall not relieve the parties of their obligations hereunder.
(Id. at 4).

To be sure, the parties to the Agreement could have indicated that it was a non-binding term sheet or that it was an agreement solely to enter into good faith negotiations or an agreement to use best efforts to reach an agreement or any such similar words. They did not do that. In fact, they did the opposite. They agreed that the Agreement was binding and "Accepted by" the Guarantor subject to execution of an Assignment of Claim on "customary terms" satisfactory to the buyer and the seller (not the Guarantor).[FN1]

Subject To: This transaction shall be subject to (i) the negotiation, execution and delivery of an acceptable assignment agreement for the Claim (an "Assignment of Claim") that is acceptable to the Buyers and the Seller in their sole and absolute discretion, containing customary representations, warranties, covenants, agreements, indemnities, recourse and other provisions for transactions of this type including on no withdrawals by Seller within 91 days of the petition date of Debtors (other than those disclosed during the confirmatory due diligence); provided that, Seller shall provide to Buyers "step-up" provisions for all such representations, warranties, covenants and agreements that would be made by prior sellers and owners of the Claim(s) ("Step-Up Provisions") and Guarantor shall guaranty all obligations and liabilities of Seller, including the Step-Up Provisions, and any prior sellers or owners of the Claim, (ii) each Buyer's satisfactory due diligence of the Claim, in its sole discretion (including the Claim Amount), (iii) satisfactory completion of each Buyer's KYC/AML process, in its sole discretion, with respect to Seller and Guarantor, and (iv) each Buyer's satisfactory review and approval, in its sole discretion, of the creditworthiness of Seller and Guarantor.
(Id. at 3 [emphasis in original]).

Indeed, the fact that the Agreement was "Accepted by" the Guarantor but the Assignment of Claim did not need to be in a form satisfactory to the Guarantor suggests the opposite of what the defendants argue — i.e., that there was a meeting of the minds as to the terms upon which the transaction contemplated by the Agreement was to be consummated and that the Guarantor was guaranteeing performance.[FN2]

For completeness, the Court notes that although the parties did have certain other conditions (i.e., other than execution of the assignment agreement), these other conditions all are for the benefit of the plaintiffs (e.g., satisfactory review of the creditworthiness of the Seller and the Guarantor).

The Agreement is specific and appears to have been highly negotiated. Pursuant to the terms of the Agreement, the parties agreed that (i) the purchase price was equal to the Claim Amount multiplied by the Purchase Rate, (ii) the Claim Amount was defined as $93,698,233.75 subject to adjustment, (iii) the Purchase Rate was equal to 77%, (iv) 50% of the Purchase Price [*2]was due within two days of execution of the assignment document,[FN3] and (iv) the parties were obligated to use their commercial best efforts not merely to enter an agreement, but to close the transaction contemplated by the Agreement:

Claim Amount/Type of Debt: Seller's valid and enforceable, undisputed customer entitlement claim against the Debtors in the Bankruptcy Case in the estimated outstanding principal amount of $93,698,233.75, subject to agreement and adjustment upon mutual agreement of the parties (the "Claim Amount") and any actions, claims and any rights to receive all payments in respect thereof, lawsuits or rights of any nature whatsoever, whether against Debtors or any other person or entity, arising out of or in connection with the Claim Amount, including, but not limited to, all of Seller's right, title and interest, whether legal, equitable or otherwise, in any recoveries arising from or related to any United States Department of Justice forfeiture fund established pursuant to C.F.R. Part 9 or otherwise or any other remission or mitigation process of fund operated or administered by any governmental entity foreign or domestic related to Debtors.
. . . .
Purchase Rate: 77%
Purchase Price: An amount is U.S. dollars equal to the product of the Claim Amount multiplied by Purchase Rate. Each of the Buyers agrees to pay 50% of the Purchase Price to Seller within 2 Business Days of the date of execution and delivery of the Assignment of Claim by wire transfer of immediately available funds.
. . . .
Settlement Date: Parties agree to use commercially best efforts to close the transaction as soon as practicable.

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Ceratosaurus Invs., LLC v. B2C Alternative Equity, LLC
2025 NY Slip Op 50079(U) (New York Supreme Court, New York County, 2025)

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Bluebook (online)
2025 NY Slip Op 50079(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/ceratosaurus-invs-llc-v-b2c-alternative-equity-llc-nysupctnewyork-2025.