Stone, R. v. Lystn, LLC.

CourtSuperior Court of Pennsylvania
DecidedJuly 1, 2025
Docket115 MDA 2023
StatusUnpublished

This text of Stone, R. v. Lystn, LLC. (Stone, R. v. Lystn, LLC.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stone, R. v. Lystn, LLC., (Pa. Ct. App. 2025).

Opinion

J-A27004-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

ROXANNE STONE, INDIVIDUALLY : IN THE SUPERIOR COURT OF AND AS EXECUTRIX OF THE ESTATE : PENNSYLVANIA OF JACQUELINE HILL, DECEASED : : Appellants : : : v. : : No. 115 MDA 2023 : LYSTN, LLC, FOOD FOR LIFE : TRUCKING AND LOGISTICS : COMPANY, INTEGRATIVE GREEN : SOLUTIONS, INCORPORATED, AND : BIODYNAMIC FARMS, LLC :

Appeal from the Order Entered December 12, 2022 In the Court of Common Pleas of Berks County Civil Division at No(s): 21-11790

ROXANNE STONE, INDIVIDUALLY : IN THE SUPERIOR COURT OF AND AS EXECUTRIX OF THE ESTATE : PENNSYLVANIA OF JACQUELINE HILL, DECEASED : : : v. : : : LYSTN, LLC, FOOD FOR LIFE : No. 428 MDA 2023 TRUCKING AND LOGISTICS : COMPANY, INTEGRATIVE GREEN : SOLUTIONS, INCORPORATED, AND : BIODYNAMIC FARMS, LLC : : Appellants :

Appeal from the Order Entered December 12, 2022 In the Court of Common Pleas of Berks County Civil Division at No(s): 21-11790

BEFORE: LAZARUS, P.J., KUNSELMAN, J., and McLAUGHLIN, J.

MEMORANDUM BY LAZARUS, P.J.: FILED: JULY 1, 2025 J-A27004-24

Roxanne Stone, individually and as executrix of the will of Jacqueline

Hill, deceased (collectively, Appellants), appeals from the order, entered in

the Court of Common Pleas of Berks County, granting a preliminary injunction

in favor of Appellees Lystn, LLC (Lystn), Food for Life Trucking and Logistics

Company (F4L), Integrative Green Solutions, Inc., and Biodynamic Farms, LLC

(Biodynamic), (collectively, Appellees), and granting, in part, and denying, in

part, the parties’ competing post-verdict motions.1 After careful review, we

affirm in part, reverse in part, and remand with instructions.

In 2009, the now-deceased Jacqueline Hill2 co-founded Lystn, LLC

(Lystn), a Delaware company that develops, formulates, manufactures, sells,

and distributes fermented raw pet food—in particular, its proprietary pet food,

ANSWERS™. Stone and Hill developed unique processes for inoculation and

natural preservation of Lystn’s raw pet food products. As the trial court noted,

“Stone [and] Hill—both founding members, shareholders, executives, and/or

employees of the Lystn Companies—developed processes for the natural

preservation of the Lystn Companies’ raw pet food products using whey

fermentation as a means of competitive inhibition.” Trial Court Opinion,

____________________________________________

1 Although Appellees filed a notice of appeal purporting to cross-appeal from

the order disposing of post-verdict motions, they have failed to file a Pa.R.A.P. 1925(b) statement of errors complained of on appeal or a cross-appellate brief with this Court. Thus, we will confine our issues to those properly raised and preserved by Appellants.

2 Hill passed away in September 2022. We refer to Stone and Hill by name prior to Hill’s death and as Appellants after Hill’s death.

-2- J-A27004-24

10/12/23, at 3.3 F4L, IGSI, and Biodynamic (collectively, Lystn-affiliated

companies), are all controlled by Lystn or under common control by Lystn. In

August 2009, Stone was hired as an independent consultant for Lystn, and

then, later, became a Lystn employee.

In April 2010, Stone and Hill executed an LLC Operating Agreement

(Agreement) for Lystn that designated “Class I Members” and “Class II

Members.” See Complaint (21-11790), 7/21/21, at ¶¶ 11-12. Class I

members were permitted to make capital contributions “both in cash and in

the form of an assignment of intellectual property, business and industry

contacts, and goodwill,” actively participate in the operation of the company’s

business, and receive compensation and benefits. Id. at ¶ 12. Class II

members, on the other hand, were not entitled to make capital contributions

other than in cash or participate actively in the operation of the company’s

business or receive compensation or benefits. Id. Under the Agreement, “all

Members may, notwithstanding this [A]greement, engage in whatever

activities they choose, provided the same are not competitive with [Lystn].”

Id. at ¶ 13. Finally, under the Agreement, members were permitted to serve

3 In particular, the “whey-fermentation process” included the introduction of

a specific type of “good” bacteria that competed to proliferate and, ultimately, outpace “bad” pathogenic bacteria (i.e., salmonella and E. coli) commonly found in raw pet food. Although fermentation had been in use for centuries as a means to preserve foods, the whey fermentation process was unique to the pet food industry at the time it was devised by Stone and Hill.

-3- J-A27004-24

a “transfer notice” if they wished to resign and transfer their membership

interest to another member. Id. at ¶ 72.

In February 2021, Stone and Hill gave a transfer notice to four other

Lystn members and to Lystn’s corporate counsel. Id. at ¶ 16. In the notice,

Stone and Hill stated that they wanted to transfer their member interests in

Lystn and resign as a managing member and employee, respectively. Id. at

¶ 17. Under the Agreement, once a transfer notice has been received, Lystn

and the transfer-member “shall negotiate in good faith to determine the

purchase price for the [transfer-member’s] membership interest.”

Agreement, 4/12/10, at ¶ 7.7.1.4 On March 1, 2021, Stone and Hill requested

copies of the Lystn-affiliated companies’ articles of incorporation, bylaws,

operating agreements, shareholders’ agreements, employment agreements,

and documents reflecting the companies’ capitalizations and ownership.

On March 5, 2021, invoking the “Buyout Provision” under the

Agreement, the Lystn members voted for Lystn to exercise a purchase option

for Hill’s and Stone’s membership interests. On April 26, 2021, Stone and Hill

resigned from Lystn and all of its affiliated companies, while explicitly retaining

their respective ownership interests in the companies. Stone and Hill publicly

announced their resignation from Lystn on May 4, 2021.

4 In the Agreement, Stone and Hill were classified as Class I members with

22% and 12% ownership interest in Lystn, respectively. See Limited Liability Company Agreement, 4/12/10, at ¶ 3.2.

-4- J-A27004-24

In May 2021, Stone and Hill were members of Appellant Initial, LLC

(Initial), a direct competitor of Lystn, which operates under the name “Kure

Pet Food” (Kure).”5 Initial is a collective of five Amish farmers—Steven Fisher,

Jess Ervin King, David Esh, John King, and Samual Stoltzfus (collectively,

Amish Farmers)— who each operate through their own companies, Ultra

Design (Fisher), Rocky Ridge Goat Dairy (Jesse Ervin King), and Lykens Valley

Creamery (Esh/John King/Stoltzfus). The Amish Farmers were all former,

long-time suppliers of the Lystn companies. The Lystn companies alleged that

Initial manufactured Kure’s products using the same formulas and processes—

involving proprietary and confidential business information—developed by

Stone and Hill while they were working for Lystn.

In July 2021, Stone and Hill sued Appellees alleging, among other

things, that Appellees breached their shareholder agreement by failing to

purchase their respective membership interests under the Agreement’s

relevant buyout provisions and also seeking declaratory and injunctive relief

based on their argument that any non-compete clause in the parties’

employment agreement was not enforceable as a matter of law as applied to

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