Pinnacle IV, L.P. v. Cyberlabs AI Holdings Limited

CourtSuperior Court of Delaware
DecidedJuly 1, 2024
DocketN23C-04-021 MAA CCLD
StatusPublished

This text of Pinnacle IV, L.P. v. Cyberlabs AI Holdings Limited (Pinnacle IV, L.P. v. Cyberlabs AI Holdings Limited) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pinnacle IV, L.P. v. Cyberlabs AI Holdings Limited, (Del. Ct. App. 2024).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE PINNACLE IV, L.P., ) ) Plaintiff/Counterclaim ) C.A. No. N23C-04-021 MAA CCLD Defendant, ) ) v. ) ) CYBERLABS AI HOLDINGS ) LIMITED, PSAFE TECHNOLOGY ) HOLDING LLC n/k/a AI Technology ) LLC, and PSAFE TECHNOLOGY, INC., ) ) ) Defendants/Counterclaim ) Plaintiffs. )

Submitted: May 1, 2024 Decided: July 1, 2024

Plaintiff's Motion to Dismiss Counterclaims, Strike Affirmative Defenses and for Judgment on the Pleadings: GRANTED.

MEMORANDUM OPINION

Andrew D. Cordo, Esquire (Argued), Andrew D. Berni, Esquire, and Joshua A. Manning, Esquire, of WILSON SONSINI GOODRICH & ROSATI, P.C., Wilmington, DE, Attorneys for Plaintiff/Counterclaim Defendant Pinnacle IV, L.P.

Berton W. Ashman, Jr., Esquire, Jesse L. Noa, Esquire, and Justin T. Hymes, Esquire, of POTTER ANDERSON & CORROON LLP, Wilmington, DE, and Michael J. Baratz, Esquire (Argued) and Patrick F. Linehan, Esquire of STEPTOE LLP, Washington, DC, Attorneys for Defendants/Counterclaimants.

Adams, J.1

1 Sitting as a Vice Chancellor of the Court of Chancery of the State of Delaware by designation of the Chief Justice of the Supreme Court of Delaware pursuant to In re Designation of Actions Filed 1 I. INTRODUCTION

Seller filed a complaint seeking enforcement of a note it received in exchange

for the sale of its interests in a company. Buyer counterclaimed arguing that the note

is unenforceable because of seller’s fraud in connection with the sale. To adequately

plead fraud, a party must identify an actionable misrepresentation or omission. Here,

the pleadings do not identify a single misrepresentation made by seller. To salvage

this deficiency, buyer resorts to a theory that seller deputized management of the

company, thereby seeking to impute management’s conduct onto seller.

The buyer’s agency theory fails. As a result, buyer’s claims for fraud and

negligent misrepresentation also fall short. Therefore, seller’s Motion to Dismiss

the Counterclaims and to Strike the Affirmative Defenses is granted. Because buyer

lacks any viable affirmative defenses, the Court also grants seller’s Motion for

Judgment on the Pleadings to Enforce the Note.

Pursuant to In re: DESIGNATION OF THE HONORABLE MEGHAN A. ADAMS under Del. Const. art. IV § 13(2) dated September 18, 2023. According to the Supreme Court’s August 18, 2023 Order, the Chief Justice cross designated the undersigned “to sit as a Vice Chancellor on the Court of Chancery for the purpose of hearing and deciding all issues in Pinnacle IV, L.P. v. CyberLabs AI Holdings Ltd., et al., C.A. No. N23C-04-021 MAA (CCLD), once the action is transferred to the Court of Chancery.” The action has not yet been “transferred” to the Court of Chancery, but the undersigned interprets the Supreme Court’s order that Judge Adams has the authority to hear both legal and equitable claims in this case due to the cross-designation. 2 II. FACTUAL BACKGROUND2

A. PSafe and the use of MIT

PSafe Technology Holding, LLC (“PSafe” or the “Company”) developed

consumer-oriented cybersecurity products, predominantly serving customers in

Brazil.3 Marco A. De Mello and Benjamin A. Myers (the “Founders”) founded the

Company in 2011, and served as CEO and CFO of the Company, respectively.4

As part of its growth strategy, PSafe sought to acquire new users who installed

its mobile apps.5 To do so, PSafe worked with third-party media sources that

promoted app installations through advertising with third parties (the “Installation

Partners”).6 The Installation Partners then worked with publishers to place

advertisements on the web.7

PSafe paid the Installation Partners based on the number of user installations

in accordance with certain criteria.8 For example, an approved installation required

that the user was a real person and not a bot, and that the user was in an approved

2 The facts are drawn from the well-pleaded allegations in the Amended Complaint for Breach of Promissory Note and to Enforce Guaranty (“Amended Complaint” or “AC”) (D.I. 15) and Answer and Defenses of Defendants Cyberlabs AI Holdings Limited, PSafe Technology Holding LLC, n/k/a AI Technology LLC, and PSafe Technology, Inc. to Amended Complaint for Breach of Promissory Note and to Enforce Guaranty Counterclaims for Fraudulent Inducement and Negligent Misrepresentation (“Counterclaim” or “CC”) (D.I. 19). 3 CC ¶¶ 45, 46. 4 Id. ¶¶ 3, 45, 175. 5 Id. ¶ 52. 6 Id. ¶ 53. 7 Id. 8 Id. 3 country.9 PSafe could then “scrub” reported data for any installations that did not

meet the criteria set forth in the Installation Partners’ contracts based on reports

generated by a third party.10 By reducing the number of installations, PSafe lowered

the commission the Installation Partners would otherwise be owed for their

advertising efforts.11

PSafe also developed a proprietary software program called “Marketing

Install Tool” (“MIT”) that used a “filtering process” initiated on PSafe’s back-end

servers once a user installed a PSafe product.12 The use of MIT was allegedly a less

“transparent” way of reducing ineligible installations than the practice of

“scrubbing” the data directly from the third-party reports.13

B. Pinnacle Demands Repayment and PSafe Implements Cost-Savings Plan

In 2015, Pinnacle IV, L.P. (“Pinnacle”), a venture capital firm, became a

primary creditor to PSafe.14 Through 2017, Pinnacle continued to provide financial

support through an affiliate of PSafe, PSafe Technology, Inc. (“PSafe, Inc.”).15 In

2018, Pinnacle demanded repayment of its loans after PSafe failed to meet its

9 Id. ¶ 56. PSafe and Installation Partners relied on AppsFlyer to verify accurate installation counts. Id. ¶ 57. 10 Id. ¶ 61. 11 Id. ¶ 54. 12 Id. ¶¶ 64, 66. 13 Id. ¶ 66. 14 Id. ¶ 76. 15 Id. ¶ 77. 4 financial targets.16 Following the demand for repayment, PSafe revised its business

plan to include additional expense reductions.17

To meet these new cost-saving targets, PSafe, through the Founders, allegedly

manipulated MIT to underreport eligible installations.18 Email correspondence

among the Founders and other employees suggest misuse of MIT.19 There is no

allegation, however, that any Pinnacle-designated manager of PSafe or employee of

Pinnacle were on these communications. Indeed, the Founders and PSafe’s User

Acquisition team controlled MIT’s filters.20

C. Sale to Pinnacle, and Later, to Cyberlabs

After failing to find alternative buyers21 in the fall of 2020, PSafe, through an

affiliate, sold its membership interests to Pinnacle with modifications to the loan

agreement between them.22 After the sale, and as PSafe’s new owner, Pinnacle

worked with PSafe’s management to sell the Company to a third party. During this

time, the Founders allegedly continued to misuse MIT.23

16 Id. ¶ 82. 17 Id. ¶ 83. 18 Id. ¶ 84. 19 Id. ¶¶ 98-110, 126-31. 20 Id. ¶ 126. 21 Id. ¶ 95. 22 Id. ¶ 111. 23 Id. ¶¶ 112-117. 5 At the start of 2021, Pinnacle sold its equity interests in PSafe to Cyberlabs

AI Holdings Limited (“Cyberlabs”), an AI company based in Brazil,24 through a

Membership Interest Purchase Agreement (the “MIPA”).25 Pinnacle received cash,

common shares of Cyberlabs, and a Secured Promissory Note (the “Cyberlabs

Note”).26 PSafe and PSafe Inc. guaranteed the Cyberlabs Note through a Guaranty

Agreement (the “PSafe Guaranty”).27

Cyberlabs made a partial payment towards the end of 2021, after which the

parties amended the Cyberlabs Note to adjust the amortization.28

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Bluebook (online)
Pinnacle IV, L.P. v. Cyberlabs AI Holdings Limited, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pinnacle-iv-lp-v-cyberlabs-ai-holdings-limited-delsuperct-2024.