PureShares, LLC v. Zimnisky

CourtDistrict Court, D. Delaware
DecidedFebruary 25, 2025
Docket1:23-cv-01178
StatusUnknown

This text of PureShares, LLC v. Zimnisky (PureShares, LLC v. Zimnisky) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PureShares, LLC v. Zimnisky, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

PURESHARES, LLC, d/b/a PUREFUNDS and ANDREW CHANIN, Plawntis, Civil Action No. 23-1178-RGA Vv. PAUL ZIMNISKY, Defendant.

MEMORANDUM OPINION Joseph J. Longobardi, II], LONGOBARDI & BOYLE LLC, Wilmington, DE; Thomas S. Harty, HARTY LAW GROUP, PLLC, Philadelphia, PA, Attorneys for Plaintiffs. Jared T. Green, R. Karl Hill, SEITZ, VAN OGTROP & GREEN, P.A., Wilmington, DE, Attorneys for Defendant.

February 2025

Before me is Defendant’s Motion to Dismiss. (D.I. 16). I have considered the parties’ briefing. (D.I. 17, 19, 20, 22, 24, 25). For the reasons set forth below, the motion is GRANTED. I. BACKGROUND Plaintiff PureShares, LLC, d/b/a PureFunds (hereinafter PureFunds), is a research and business management firm. (D.I. 1 at 2 §2).! PureFunds was formed by Plaintiff Andrew Chanin, Thomas Brown, Thomas Winston, Leigh Zimniksy, and Defendant Paul Zimnisky.? □□□□ at 24,8426). The five original members of PureFunds executed an operating agreement (Operating Agreement I) for the company in February 2011 which governed the company’s operations and the relationship of the five as owners of the company. (/d.). Each of the five original founders held equity in PureFunds in the form of membership units. (/d. at 1 41, 2 99 6, 14). Operating Agreement I required a member to have majority approval should the member seek to transfer or dispose of his or her units in PureFunds. (/d. at 10 4 36). Operating Agreement | also provided a mechanism for the members to purchase any shares that another member sought to sell. (/d. at 10 39). Specifically, Operating Agreement | required a member to provide notice to the others prior to selling membership units and to give the other members a right of first refusal to purchase the units. (/d. at 10 §] 39-40). On August 1, 2011, the members executed Amendment I to Operating Agreement I; the amendment removed Thomas Winston as Manager and Chief Operating Officer and terminated his interest in the 150,000 membership units he originally held. (id. at 9 § 30). Amendment I

' On page 8 of the Complaint, there is repeated paragraph numbering. I cite to the Complaint as (D.I. 1 at X § Y), where X is the page number and Y is the paragraph number. Paul and Leigh Zimnisky are siblings.

also served to memorialize Thomas Brown’s resignation as a Managing Member and the transfer of his 200,000 membership units to Thomas Brown Group, LLC, which was solely owned by Brown. (/d. at 9 931). Amendment I left Andrew Chanin and Paul Zimnisky as the Managers of PureFunds. (/d. at 10 1 38). Thomas Brown Group subsequently changed its name to Blockhouse. (/d. at 9 J 31). After Brown resigned as a Manager, Paul Zimnisky, Leigh Zimnisky, Andrew Chanin, and NYRV, LLC? entered into a new operating agreement (Operating Agreement II). (/d. at □ 32-33). Operating Agreement II imposed the same requirements and procedures for the sale of membership units as Operating Agreement I. (/d. at 9 35). Blockhouse was terminated as a member of PureFunds for cause. (/d. at 6 § 25). The Complaint alleges that Paul Zimnisky played a role in Blockhouse’s termination. (/d.). Zimnisky referred to Brown in written communications with Chanin and third parties as a “problem,” “mentally imbalanced,” and “impractical.” (/d. at 6 726). Zimnisky accused Brown and his father of blackmailing Zimnisky for additional membership units in PureFunds by threatening to go to PureFunds’ co-venture partner’ with various concerns. (Jd. at 7 27). Zimnisky also complained about Brown to a professional colleague. Ud. at 7 { 28). As PureFunds struggled financially, Paul and Leigh Zimnisky eventually left. Gd. at 3 6). In January 2014, Paul and Leigh Zimnisky decided to transfer their units to Chanin. (/d.). On January 24, 2014, Paul and Leigh Zimnisky provided notice of the transfer to the agreement’s signatories, Chanin and NYRV, LLC, in accordance with Operating Agreement II. (/d. at 11

3 The Complaint does not explain anything about NYRV, LLC. 4 The Complaint does not identify the “co-venture partner.”

46). In February 2014, Paul Zimnisky confirmed in a message to Chanin that the withdrawal was “binding.” (/d. at 13 ¥ 53). After Paul and Leigh Zimnisky left, Chanin assumed control of PureFunds as its sole Managing Member. (/d. at 11-13 48-50). PureFunds raised more than $1 billion in assets under Chanin’s management. (/d. at 13 (51). On August 8, 2015, Zimnisky wrote Chanin and claimed that he was still a member of PureFunds. (/d. at 13 752). Specifically, Zimnisky argued that the transfer of his units to Chanin was of no effect because Brown did not approve of the transfer and therefore refuted its legal validity. (/d.). On August 13, 2015, Chanin sent a letter to Paul Zimnisky demanding that Zimnisky cease and desist with his claims and that he and his sister confirm the prior transfer of their units to Chanin. Ud. at 4912). Zimnisky did not cease and desist; he wrote PureFunds’ accountant and demanded that he be re-listed as a member of the company. (/d. at 4 13). Chanin and PureFunds then filed suit in 2015 against Paul and Leigh Zimnisky in the District of Delaware, seeking a declaratory judgment confirming Chanin’s sole ownership of PureFunds. at 4 16; D.I. 14-13). The parties to the 2015 lawsuit subsequently settled. (D.I. 1 at 5 717). By signing the settlement agreement, Paul and Leigh Zimnisky reaffirmed the transfer of their ownership interests in PureFunds to Chanin and promised to execute and deliver an annexed Transfer and Assignment of Ownership Interest to Chanin. (D.I. 14-13 § 1(i)). Additionally, the settlement agreement committed Paul Zimnisky to appear at trial as requested to confirm certain representations made in the agreement. (/d. § 1(1i)(g)). By signing the agreement, Paul Zimnisky represented that: (a)Since January 24, 2014, all equitable and legal rights, [and] title to the Interests have been owned, held and exercised by Chanin;

(b)There were no encumbrances, liens, claims or rights on [Paul and Leigh Zimnisky’s] Interests in PureFunds asserted on or before the Transfer Date other than those that may have been set forth in the Operating Agreements; □ (c)On or before January 24, 2014, neither Tom Brown, nor TomBrown Group, LLC (collectively ““Brown’”), provided either [Paul or Leigh Zimnisky] with any written notice objecting to the transfer of the Interests to Chanin; (d)Since January 24, 2014, neither Brown, nor any successor thereto, has provided either [Paul or Leigh Zimnisky] with any written notice objecting to the transfer of the Interest[s] to Chanin; (e) Since January 24, 2014, [Paul and Leigh Zimnisky] have not advised Brown that the transfer to [Chanin] was invalid or violated any of the Operating Agreements previously executed by one or more of the Members; [and] (f) [Paul and Leigh Zimnisky] advised [Chanin and PureFunds] that Brown may claim that the transfer of the Interests to Chanin on January 24, 2014 was void, of no effect, or that one or more of them had a right to all or a portion thereof (the “Brown Claim”). (id. § 1(ii)). The Settlement Agreement also contained a non-disparagement clause requiring the parties “not to make statements, written or verbal, . . . that defame, disparage or in any way criticize the business reputation, practice or conduct of the other, their employees, directors and officers.” (/d. § 8). In March 2018, Blockhouse filed suit against Chanin and PureFunds in the Court of Chancery for the State of Delaware.’ (D.I. 1 at 5 § 20; D.I. 17-1 at 13 of 146). Paul Zimnisky was called to testify in a deposition. (D.I. 1 at 5 20). The Complaint alleges that during his testimony, Zimnisky once again claimed an ownership interest in the units that he had transferred to Chanin. (/d.). When Blockhouse’s counsel asked Zimnisky about the outcome of his prior

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PureShares, LLC v. Zimnisky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pureshares-llc-v-zimnisky-ded-2025.