Knockout Holdings, LLC v. Arvinder Kakar

Court of Appeals for the Fourth Circuit·Decided June 29, 2026·No. 24-1625·Unpublished

Opinion

USCA4 Appeal: 24-1625 Doc: 64 Filed: 06/29/2026 Pg: 1 of 6

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-1625

KNOCKOUT HOLDINGS, LLC, f/k/a Octo Platform Equity Holdings, LLC,

Plaintiff – Appellant,

v.

ARVINDER KAKAR,

Defendant – Appellee.

Appeal from the United States District Court for the Eastern District of Virginia, at Alexandria. Claude M. Hilton, Senior District Judge. (1:23-cv-00944-CMH-WEF)

Argued: March 19, 2025 Decided: June 29, 2026

Before KING, AGEE, and HARRIS, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ARGUED: Paul Anthony Werner, III, SHEPPARD, MULLIN, RICHTER & HAMPTON, LLP, Washington, D.C., for Appellant. Joseph Michael Rainsbury, O’HAGAN MEYER PLLC, Richmond, Virginia, for Appellee. ON BRIEF: Imad Matini, Christopher Bauer, Kathryn Ryan, Angelo Pavone, SHEPPARD, MULLIN, RICHTER & HAMPTON LLP, Washington, D.C., for Appellant. Charles M. Sims, O’HAGAN MEYER, PLLC, Richmond, Virginia, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 24-1625 Doc: 64 Filed: 06/29/2026 Pg: 2 of 6

PER CURIAM:

In this appeal from the Eastern District of Virginia, plaintiff Knockout Holdings,

LLC, formerly known as Octo Platform Equity Holdings, LLC (hereinafter “Knockout”),

challenges the district court’s adverse July 2024 award of summary judgment to the

defendant Arvinder Kakar. See Knockout Holdings, LLC v. Kakar, No. 1:23-cv-00944

(E.D. Va. July 31, 2024), ECF No. 135 (the “Summary Judgment Ruling”). * By the

Summary Judgment Ruling, the court entered a judgment in favor of Kakar on Knockout’s

defamation and declaratory judgment claims. As background, those claims arise out of the

parties’ contentious and soured business relationship and, eventually, statements that Kakar

made in December 2022 to an employee of another business entity — that is, International

Business Machines Corporation (“IBM”) — regarding ongoing state court litigation in the

Commonwealth of Virginia and the State of Delaware between Kakar and Knockout.

On appeal, Knockout maintains — with respect to the Summary Judgment Ruling

— that the district court committed two errors that warrant a reversal: (1) that the court

erred in ruling that Kakar’s statements to the IBM employee were protected opinions under

the First Amendment of the Constitution and therefore not defamatory; and (2) that the

court erred in disposing of Knockout’s declaratory judgment claim. In addressing the

propriety of those merits-based contentions during the March 2025 oral argument of this

* At the time of the events giving rise to its complaint, Knockout was known as Octo Platform Equity Holdings, LLC (“Octo Platform”). And Octo Platform was the parent of two subsidiaries: Octo Consulting Group, LLC and Octo Equity Holdings Parent, LLC. For simplicity’s sake, we collectively refer to those Octo entities as “Knockout.”

2 USCA4 Appeal: 24-1625 Doc: 64 Filed: 06/29/2026 Pg: 3 of 6

appeal in Richmond, however, a threshold jurisdictional issue emerged concerning the

district court’s subject-matter jurisdiction. See, e.g., Steel Co. v. Citizens for a Better Env’t,

523 U.S. 83, 94-95 (1998) (specifying that “[e]very federal appellate court has a special

obligation to satisfy itself not only of its own jurisdiction, but also that of the lower courts

in a cause under review, even though the parties are prepared to concede it” (citation

modified)); accord Mansfield, C. & L.M. Ry. Co. v. Swan, 111 U.S. 379, 382 (1884).

To that end, following the March 2025 oral argument, our Court entered an Order

of Limited Remand later that month. See Knockout Holdings, LLC v. Kakar, No. 24-1625

(4th Cir. Mar. 25, 2025), ECF No. 58 (the “Remand Order”). Mindful that we are we a

“court of review, not of first view,” see Cutter v. Wilkinson, 544 U.S. 709, 718 n.7 (2005),

we therein “order[ed] a limited remand to the district court for resolution of [the]

jurisdictional issue” — specifically, whether “there was a lack of diversity jurisdiction in

the district court proceedings,” as required by 28 U.S.C. § 1332. See Remand Order 1.

During the remand proceedings, and by Order of September 30, 2025, the district

court concluded that there was complete diversity of parties at the time Knockout filed its

complaint against Kakar in the Virginia federal court in July 2023, thereby conferring

subject-matter jurisdiction pursuant to § 1332. See Knockout Holdings, LLC v. Kakar, No.

1:23-cv-00944 (E.D. Va. Sept. 30, 2025), ECF No. 176 (the “Subject-Matter Jurisdiction

Ruling”). As the court explained and articulated in its Subject-Matter Jurisdiction Ruling:

The facts as they existed at the time of filing — which followed after the IMB deal was consummated — were that [Knockout] had repurchased Kakar’s shares and those shares were subsequently sold to IBM. Thus, because Seva, a Maryland corporation and former member of [Knockout], and Kakar are citizens of Maryland, and none of [Knockout’s] members were

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or are citizens of Maryland, the parties were — and remain — completely diverse. 28 U.S.C. § 1332(a)(1). They were diverse then, and nothing that exists now, or happens in the future related to Kakar’s membership interests can change that because those interests no longer exist as they have been reduced to cash in the form of a note.

See Subject-Matter Jurisdiction Ruling 6-7.

In April 2026, our Court sought supplemental briefing from the parties concerning

the propriety of the district court’s Subject-Matter Jurisdiction Ruling. See Knockout

Holdings, LLC v. Kakar, No. 24-1625 (4th Cir. Apr. 8, 2026), ECF No. 59. As to the issue

of the court’s subject-matter jurisdiction, we “review the district court’s factual findings

with respect to jurisdiction for clear error and the legal conclusion that flows therefrom de

novo.” See Velasco v. Gov’t of Indonesia, 370 F.3d 392, 398 (4th Cir. 2004). In this

situation, having carefully considered the parties’ supplemental briefs — along with the

pertinent and controlling legal authorities — we are satisfied that the district court correctly

determined that the parties to this lawsuit were “completely diverse” at the time Knockout

commenced this action in July of 2023. Accordingly, we are content to affirm the Subject-

Matter Jurisdiction Ruling, for the reasons well-articulated by the district court.

Returning to the underlying merits of this appeal, our Court reviews de novo an

award of summary judgment. See, e.g., Tederick v. LoanCare, LLC, 168 F.4th 154, 162

(4th Cir. 2026); Palmer v. Liberty Univ., Inc., 72 F.4th 52, 62 (4th Cir. 2023). To that end,

summary judgment is only appropriate if — viewing the facts in the light most favorable

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