Transdev North America, Inc. v. Recess Holdco LLC

CourtCourt of Chancery of Delaware
DecidedJuly 11, 2025
DocketC.A. No. 2023-1063-MTZ
StatusPublished

This text of Transdev North America, Inc. v. Recess Holdco LLC (Transdev North America, Inc. v. Recess Holdco LLC) 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
Transdev North America, Inc. v. Recess Holdco LLC, (Del. Ct. App. 2025).

Opinion

COURT OF CHANCERY OF THE STATE OF DELAWARE MORGAN T. ZURN LEONARD L. WILLIAMS JUSTICE CENTER VICE CHANCELLOR 500 N. KING STREET, SUITE 11400 WILMINGTON, DELAWARE 19801-3734

July 11, 2025 E. Chaney Hall, Esquire Raymond J. DiCamillo, Esquire Fox Rothschild LLP Richards, Layton & Finger, P.A. 1201 North Market Street, Suite 1200 920 North King Street Wilmington, DE 19801 Wilmington, DE 19801

RE: Transdev North America, Inc. v. Recess Holdco LLC, Civil Action No. 2023-1063-MTZ

Dear Counsel:

A transit services company purchased another transit service company’s

subsidiary. The purchase agreement subjected the seller to restrictive covenants,

fencing off part of the North American transportation services market for the buyer.

After the agreement closed, the buyer and seller submitted competing bids for

several transit services contracts, and the seller hired one of the buyer’s former

employees. The buyer sued the seller for breaching the restrictive covenants and the

implied covenant of good faith and fair dealing, and sought a declaratory judgment.

The seller moved to dismiss. This letter addresses the seller’s motion.

I. BACKGROUND

Plaintiff Transdev North America, Inc. (“Buyer”) provides contract-based

passenger transportation services to institutions seeking to outsource their Transdev N. Am., Inc. v. Recess Holdco LLC, C.A. No. 2023-1063-MTZ July 11, 2025 Page 2 of 29

transportation needs.1 Defendant Recess Holdco LLC (“Seller”) provides student

and non-student transportation services through its controlled affiliates.2

On October 25, 2022, Buyer and Seller entered a stock purchase agreement

(the “Agreement”) to facilitate Buyer’s acquisition of Seller’s subsidiary First

Transit Topco Inc. (“Target”), which provides “passenger motor carrier mobility

services, including fixed route bus services, paratransit, and shuttle bus services.”3

The acquisition closed on March 6, 2023 (the “Closing” or “Closing Date”).4 After

Closing, Seller continues to provide student and non-student transportation services

through controlled affiliates.5

The Agreement contains a nonsolicitation provision (the “Nonsolicit”)6 and a

noncompetition provision (the “Noncompete”).7 Both restrictive covenants apply

“[f]rom the Closing until the third (3rd) anniversary of the Closing.”8

1 Docket Item (“D.I.”) 28 ¶ 3 [hereinafter “Compl.”]. 2 See id. ¶¶ 7, 8, 10 n.12, 17, 18, 23–24. 3 Id. ¶¶ 8 n.1; Compl. Ex. 1 at 1 [hereinafter “Agr.”]. 4 Compl. ¶ 9; Agr. § 1.1. 5 See Compl. ¶¶ 10 n.12, 18, 23. 6 Agr. § 6.23(a)(i). 7 Id. § 6.23(a)(ii). 8 Id. § 6.23(a). Transdev N. Am., Inc. v. Recess Holdco LLC, C.A. No. 2023-1063-MTZ July 11, 2025 Page 3 of 29

The Nonsolicit provides that “Seller shall not, and shall cause the other members of

the Seller Group not to . . . directly or indirectly, solicit or hire . . . any employee of

the Company Group, in each case as of immediately prior to the Closing.”9 The

“Seller Group” means Seller and its affiliates.10 The “Company Group” means

Buyer and its affiliate entities.11 The Nonsolicit carves out two exceptions:

[T]he foregoing restriction shall not apply to (i) generalized searches by use of advertising or recruiting efforts (including the use of search firms) that are not specifically targeted at such employees and hiring any individual who responds to such search or (ii) soliciting or hiring any such employee of the Company Group or other employee of Purchaser and its Subsidiaries who is no longer employed by the Company Group or Purchaser or any of its Affiliates and has not been so employed for one hundred eighty (180) days[.]12

The Noncompete provides:

Seller shall not, and shall cause the other members of the Seller Group not to . . . engage, directly or indirectly . . . in a business or endeavor in the United States or Canada that is competitive with the business of the Company and its Subsidiaries, in each case as conducted immediately prior to the date hereof or the Closing, excluding the FS Business (“Competitive Business”) . . . .13 9 Id. § 6.23(a)(i). 10 Id. § 6.13(a). 11 Id. § 1.1. 12 Id. § 6.23(a)(i). 13 Id. § 6.23(a)(ii). The Noncompete specifies that it “shall not apply to (A) ownership of ten percent (10)% or less of the outstanding equity securities of any Person or (B) any person or business acquired by Seller or its Affiliates following the date hereof if, on the date of the entry of a definitive agreement with respect to such acquisition, less than thirty Transdev N. Am., Inc. v. Recess Holdco LLC, C.A. No. 2023-1063-MTZ July 11, 2025 Page 4 of 29

Thus, the Noncompete carves out “FS Business” from the Noncompete’s restriction

on Competitive Activity (the “FS Business Exception”). Put differently: the

Noncompete fences off part of the North American transportation market for Buyer,

but Seller can continue to perform FS Business even within that fenced-off space.

The Agreement defines “FS Business” as

the business of Seller, First Student Topco Inc. [(“Seller Sub 1”),14] and/or their respective controlled Affiliates and parent entities (which includes, for the avoidance of doubt, Total Transportation Corp., Pride Transportation Services, Inc., Bella Bus Corp., GVC II Inc., MJT Bus Company Inc. and Atlantic Garden Holdings, Corp. and each of their respective Subsidiaries) and their respective successors and assigns (other than the Company and its Subsidiaries) as of the date of this Agreement and/or the Closing Date.15

percent (30%) of the revenues of such Person or business for the twelve (12) months prior to the date of such entry are generated from a Competitive Business, but only, in the case of this clause (B), to the extent the Seller Group does not expand the revenues of such acquired Person or business beyond growth with existing customers or clients.” Id. 14 Seller Sub 1 is a subsidiary of Seller and a leading school bus operator. Compl. ¶¶ 7, 10 n.12. 15 Agr. § 1.1. “Affiliate” is defined to include entities that a company, “directly or indirectly through one or more intermediaries, controls, or is controlled by, or is under common control with.” Id. The Agreement defines “Subsidiary” as follows: “‘Subsidiary’ of any Person (such Person for purposes of this definition, the ‘Controlling Company’) means any other Person (i) of which a majority of the outstanding voting securities or other voting equity interests, or a majority of any other interests having the power to direct or cause the direction of the management and policies of such other Person, are owned, directly or indirectly, by the Controlling Company and/or (ii) with respect to which the Controlling Company or its Subsidiaries is a general partner or managing member.” Id. Transdev N. Am., Inc. v. Recess Holdco LLC, C.A. No. 2023-1063-MTZ July 11, 2025 Page 5 of 29

At issue are the activities of three entities not explicitly named in the FS

Business definition: (i) MPC Bus Corporation (“Seller Sub 2”), (ii) Autobus

Transco (1988) Inc. (“Seller Sub 3”), and (iii) Autobus Dufresne Inc. (“Seller Sub

4”).

Seller Sub 2 is a wholly owned subsidiary of Seller’s affiliate Total

Transportation Corp., which is listed in the FS Business definition.16

Seller Sub 3 is Seller’s indirect wholly owned subsidiary.17 Between the

Agreement’s signing and Closing, Seller Sub 3 acquired Seller Sub 4.18 Upon that

acquisition, Seller Sub 4 became Seller’s indirect wholly owned subsidiary.19 Seller

Sub 4 is “engaged in the business of providing both student and non-student transit

services in Montréal, QC, Canada.”20 As of Closing, Seller Sub 4 operated two non-

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Transdev North America, Inc. v. Recess Holdco LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/transdev-north-america-inc-v-recess-holdco-llc-delch-2025.