Sanjiv Mehra v. Jonathan Teller

CourtCourt of Chancery of Delaware
DecidedSeptember 20, 2024
DocketC.A. No. 2019-0812-KSJM
StatusPublished

This text of Sanjiv Mehra v. Jonathan Teller (Sanjiv Mehra v. Jonathan Teller) 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
Sanjiv Mehra v. Jonathan Teller, (Del. Ct. App. 2024).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

SANJIV MEHRA, individually, and ) SAMRITA MEHRA, as trustee of the ) SANJIV MEHRA 2014 IRREVOCABLE ) TRUST, ) ) Plaintiffs, ) ) v. ) C.A. No. 2019-0812-KSJM ) JONATHAN TELLER, EOS INVESTOR ) HOLDING COMPANY, LLC, ANGRY ) ELEPHANT CAPITAL, LLC, ANDREW ) SALTOUN, as successor trustee of the ) Teller Children’s 2015 Trust, and ) SARAH SLOVER, ) ) Defendants. )

POST-TRIAL MEMORANDUM OPINION

Date Submitted: June 11, 2024 Date Decided: September 20, 2024

John L. Reed, Peter H. Kyle, Kelly L. Freund, Daniel P. Klusman, DLA PIPER LLP (US), Wilmington, Delaware; Patrick J. Smith, Brian T. Burns, Michael K. Sala, CLARK SMITH VILLAZOR LLP, New York, New York; Counsel for Plaintiffs Sanjiv Mehra and Samrita Mehra as Trustee of the Sanjiv Mehra 2014 Irrevocable Trust.

Jon E. Abramczyk, D. McKinley Measley, Elizabeth A. Mullin Stoffer, Kirk C. Andersen, MORRIS, NICHOLS, ARSHT & TUNNELL LLP, Wilmington, Delaware; Counsel for Defendants Jonathan Teller, EOS Investor Holding Company, LLC, Angry Elephant Capital, LLC, and Andrew Saltoun as Successor Trustee of the Teller Children’s 2015 Trust, and Sarah Slover.

McCORMICK, C. This is the second post-trial decision resolving disputes arising from the

dissolution of EOS Investing Holding Company (“Holdco” or the “Company”). Before

the dissolution, Jonathan Teller and Sanjiv Mehra controlled the Company’s

membership interests. Teller controlled about 85%, and Mehra controlled the

remainder. They had a falling out, and Teller dissolved the Company due to deadlock

pursuant to a provision in the governing LLC Agreement (the “2016 LLC

Agreement”). Mehra filed this lawsuit challenging the dissolution and asserting

claims for breach of fiduciary duty against Teller. The court bifurcated the case to

first address Mehra’s challenges to the dissolution. In January 2021, the court issued

the first post-trial decision, finding that Teller had validly dissolved Holdco but

breached the LLC Agreement by failing to replicate Mehra’s economic rights at the

subsidiary level post-dissolution. Round two of the litigation ensued.

In the second trial, the plaintiffs proved that they are entitled under the 2016

LLC Agreement to have their economic rights replicated at the subsidiary level,

which means that they are entitled to share equally in distributions, and that Teller

breached this provision in bad faith. Bringing round two to a close, this decision

orders specific performance of the economic-rights provision and damages in the

amount of distributions that the plaintiffs would have received had that provision

been timely honored. It is not a total victory for the plaintiffs, however, because this

decision also finds that the plaintiffs have not proven entitlement to declaratory relief

or attorneys’ fees. I. FACTUAL BACKGROUND

The second trial in this action took place over two days. The record comprises

609 trial exhibits, live testimony from two fact witnesses, deposition testimony from

two fact witnesses and two expert witnesses, and 31 stipulations of fact.1 The court

also draws from the factual findings of the prior post-trial decision,2 which are the

law of the case.3 For the most part, this decision does not repeat those findings, but

focuses on the additional facts relevant to the remaining claims.

A. The Company And The Governing Agreements

Before its dissolution, Holdco was part of a collection of entities that operated

as “EOS”: Holdco, a Delaware LLC; The Kind Group, LLC (“Kind,” or the “Kind

Group”), a New York LLC; and EOS Products, LLC (“Products”), a New York LLC.4

Teller, Mehra, and their affiliated entities owned all of the equity of Holdco.

Holdco owned 66.3% of Kind. The remaining 33.7% of Kind’s membership interest

was owned by Teller, Mehra, an investment vehicle owned by Teller and his mother

1 This decision cites to: C.A. No. 2019-0812-KSJM docket entries by docket (“Dkt.”)

number; the 2024 trial exhibits (Dkt. 348) (cited by “JX” number); the trial transcript by page and line numbers (Dkts. 346–47) (cited as “Trial Tr.”); the transcripts of the depositions of Sanjiv Mehra, Bryan Moser, William Santora, Sarah Slover, and Jonathan Teller (Dkt. 339) (by the deponent’s last name and “Dep. Tr.”); and the Parties’ Joint Pre-Trial Order (Dkt. 329) (“PTO”). 2 Mehra v. Teller, 2021 WL 300352, at *2–15 (Del. Ch. Jan. 29, 2021) [Mehra I].

3 See Carlyle Inv. Mgmt. L.C.C. v. Moonmouth Co. S.A., 2015 WL 5278913, at *7 (Del.

Ch. Sept. 10, 2015) (holding that the law of the case doctrine “applies to decisions rendered by a court that arise again later in the same court, in the same proceeding— i.e., a ruling at the summary judgment stage that also applies at the post-trial stage”). 4 Mehra I, at *2.

2 called Angry Elephant Capital, LLC (“Angry Elephant”), and various other EOS

employees. Kind wholly owned Products, the operating entity.5

Teller and Mehra executed Holdco’s initial LLC Agreement in 2011 (the “2011

LLC Agreement”).6 The parties amended the LLC Agreement twice, first in 2014 (the

“2014 LLC Agreement”), and then again in 2016 through the 2016 LLC Agreement.

Article VII of the 2011 LLC Agreement governed “Distributions, Allocations of

Income and Loss,” and Section 7.01(a) governed distributions aside from those made

to cover tax losses.7 The 2011 LLC Agreement included language providing that

distributions would be made “pro rata in accordance with [Members’] respective

Membership Interests” in Kind—approximately 85% to Teller and 15% to Mehra (the

“85/15 Split”).8 The 85/15 Split only applied at the Holdco level; Mehra and Teller

shared the proceeds from Products equally.9

Prior to executing the 2011 LLC Agreement, Mehra and Teller had a

“handshake agreement” that they were “equal partners” and that, if Holdco was sold,

the parties would share those proceeds 50/50 after the first $100 million.10 They did

not memorialize the handshake agreement in the 2011 LLC Agreement.11 From 2011

5 Mehra I, at *2.

6 PTO ¶ 50.

7 JX-9 at 13–16.

8 Id. at 13, 29.

9 Trial Tr. at 30:10–31:11 (Mehra).

10 Id. at 22:17–23:20 (Mehra).

11 Id. at 27:6–21 (Mehra).

3 to 2014, however, EOS was successful under Mehra’s leadership.12 To incentivize

Mehra to stay with EOS,13 Teller agreed to improve Mehra’s economic rights by

amending the 2011 LLC Agreement.14

Through the 2014 LLC Agreement, the parties amended Section 7.01(a) to

require that distributions of proceeds be made based on “Revised Sharing

Percentages,” a defined term that entitled Teller and Mehra each to roughly half of

the distributions (with 1% to Angry Elephant).15

The 2014 LLC Agreement included an exception to the equal-sharing scheme.

The exception distinguished between “Extraordinary Proceeds” (proceeds from a sale

or significant recapitalization) and “Operating Proceeds” (all other proceeds,

including profits).16 The parties agreed that distributions of Extraordinary Proceeds

would be made pro rata until the “aggregate [d]istributions of Extraordinary Proceeds

to the Members equal $250,000,000.”17 After the first $250 million, Mehra and Teller

would share Extraordinary Proceeds equally (reserving 1% for Angry Elephant).18

Operating Proceeds were not subject to a similar provision and were shared equally

between Mehra and Teller (again, with 1% for Angry Elephant).19

12 Id. at 21:4–13 (Mehra); id. at 272:10–19 (Teller).

13 Id.

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