Keynetics Inc. v. Keynetics Shareholder Trust

CourtCourt of Chancery of Delaware
DecidedJanuary 27, 2025
DocketC.A. No. 2022-0006-JTL
StatusPublished

This text of Keynetics Inc. v. Keynetics Shareholder Trust (Keynetics Inc. v. Keynetics Shareholder Trust) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Keynetics Inc. v. Keynetics Shareholder Trust, (Del. Ct. App. 2025).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

KEYNETICS INC., ) ) Plaintiff, ) ) v. ) C.A. No. 2022-0006-JTL KEYNETICS SHAREHOLDER ) TRUST, ) ) Defendant. ) ) ) KEYNETICS SHAREHOLDER ) TRUST, ) Counterclaim Plaintiff, ) ) v. ) KEYNETICS INC., ) ) Counterclaim Defendant. ) OPINION IMPOSING SANCTIONS FOR CONTEMPT

Date Submitted: November 22, 2024 Date Decided: January 27, 2025

Susan W. Waesco, Jacob Perrone, MORRIS, NICHOLS, ARSHT & TUNNELL LLP, Wilmington, Delaware; Catherine D. Kevane, Marie C. Bafus, FENWICK & WEST LLP, California; Attorneys for Plaintiff.

David L. Finger, FINGER & SLANINA, LLC, Wilmington, Delaware; Attorney for Defendant and Non-Party Gary Lutin.

LASTER, V.C. A Delaware statutory trust holds shares in an S corporation. The individuals

who contributed the shares to the trust hold beneficial interests in the trust. The

company’s certificate of incorporation imposes transfer restrictions on its shares, and

the parties stipulated to an order applying those same restrictions to transfers of

beneficial interests in the trust. In violation of that order, the trustee has attempted

four transfers. Each time, the company sought relief. Each time, the court granted it.

The court has already held the trust in contempt twice and the trustee in contempt

once.

The trustee has again attempted to transfer beneficial interests in violation of

the transfer restrictions. The court again finds both the trust and trustee in contempt.

Because more limited sanctions have not been effective, this decision appoints a

receiver to dissolve the trust, issues an affirmative injunction requiring the trust to

withdraw its consent for a pending transfer, issues a prohibitive injunction barring

the trustee from managing any trust or other entity holding the company’s stock,

awards the company its expenses in connection with this motion, and holds the

trustee and the individual managing the trustee jointly and severally liable with the

trust for all amounts due.1

1 This decision uses the term “expenses” to refer collectively to attorneys’ fees

and amounts paid out of pocket that might colloquially be called expenses. This is how Section 145 of the Delaware General Corporation Law deploys the term. See, e.g., 8 Del C. § 145(a) (authorizing a corporation in a proceeding other than one brought by or in the right of the corporation to provide indemnification “against expenses (including attorneys’ fees), judgments, fines and amounts paid in settlement actually and reasonably incurred”); id. § 145(b) (authorizing a corporation in a proceeding I. FACTUAL BACKGROUND

The facts are drawn from the parties submissions, documents of record, and

matters suitable for judicial notice. The operative facts are undisputed. 2

A. The Company

Keynetics Inc. (the “Company”) is a Delaware corporation headquartered in

Boise, Idaho. For tax purposes, the Company has elected to operate as a small

business corporation under Subchapter S of the Internal Revenue Code of 1986, as

amended, commonly known as an S corporation.

brought by or in the right of the corporation to provide indemnification “against expenses including attorneys’ fees) actually and reasonably incurred”); id. § 145(c) (mandating corporation to indemnify a director or officer who was successful on the merits or otherwise in defending a proceeding “against expenses (including attorneys’ fees) actually and reasonably incurred”). The out-of-pocket expenses encompassed by Section 145 are broader than the restricted concept of costs in the statute that authorizes a prevailing party to recover them. See 10 Del. C. § 5106; Scion Breckenridge Managing Member, LLC v. ASB Allegiance Real Estate Fund, 68 A.3d 665, 686–88 (Del. 2013).

2 Citations in the form “Compl. ¶___” refer to paragraphs of the operative complaint. Citations to “First MTE” refer to Keynetics Inc.’s Motion to Enforce Order and Final Judgment and Motion for Contempt Against Keynetics Shareholder Trust. Citations to “Second MTE” refer to Keynetics Inc.’s Motion to Enforce Final Judgments and Fee Award and Motion for Contempt. Citations to “Third MTE” refer to Keynetics, Inc.’s Motion to Enforce Final Judgments, Fee Award and June 26, 2024 Order and Third Motion for Contempt.” Citations to “[Filing] Ex. [Number]” refer to exhibits submitted with filings. Citations in the form “Ord. ¶___” refer to paragraphs of the Order and Final Judgment granted on February 15, 2023. Citations in the form “Supp. Ord. ¶___” refer to paragraphs of the Supplemental Order and Final Judgment granted on January 5, 2024. Citations in the form “Second Supp. Ord. ¶___” refer to paragraphs of the Order Granting Keynetics Inc.’s Motion to Enforce Final Judgments and Fee Award and Motion for Contempt granted on June 26, 2024.

2 An S corporation is a pass-through entity for federal tax purposes.

Stockholders in an S corporation report the flow-through of income and losses on their

personal tax returns and pay tax at their individual income tax rates. The

stockholders in an S corporation thus avoid double taxation.

To qualify for S corporation status, a corporation must meet specific

requirements. See 26 U.S.C. § 1361(b). One requirement limits an S corporation to

not more than 100 stockholders. Id. § 1361(b)(1)(A). Another provides that an S

corporation cannot “have as a shareholder a person (other than an estate, a trust

described in subsection (c)(2), or an organization described in subsection (c)(6)) who

is not an individual. See id. § 1361(b)(1)(B); 26 C.F.R. § 1.1361-1(f). A transfer of stock

to an impermissible holder risks terminating a corporation’s S corporation status. See

id. § 1362(d)(4).

Under Section 1361(c)(2), one type of eligible stockholder is “[a] trust created

primarily to exercise the voting power of stock transferred to it.” 26 U.S.C. §

1361(c)(2)(A)(iv). This decision uses the term “IRS Voting Trust” to refer to a trust

that qualifies as a voting trust under the Internal Revenue Code.

For tax purposes, “each beneficiary of [an IRS Voting Trust] shall be treated

as a shareholder” in the S corporation. Id. § 1361(c)(2)(B)(iv). In other words, a

transfer of a beneficial interest in an IRS Voting Trust to an ineligible stockholder

can result in the termination of S corporation status.

To protect its S corporation status, the Company’s certificate of incorporation

(the “Charter”) imposes the following transfer restriction:

3 If the Corporation determines that a substantial purpose or effect of a proposed stock transfer would be reasonably likely to adversely affect the Corporation’s status as an electing small business corporation under Subchapter S of the Internal Revenue Code, the Corporation may prohibit such transfer by notice to the proposed transferor. Furthermore, to ensure compliance with the restrictions referred to herein, the Corporation may refuse to acknowledge transfers in its books and records that are made in violation of the foregoing and may issue appropriate “stop transfer” certificates or instructions.

Charter § 4.3 (the “Charter Restriction”). The Company has also entered into

stockholder agreements with individual stockholders that give the Company a right

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