Unitednet v. Tata Communications America

112 F.4th 1259
CourtCourt of Appeals for the Tenth Circuit
DecidedAugust 19, 2024
Docket23-2057
StatusPublished
Cited by2 cases

This text of 112 F.4th 1259 (Unitednet v. Tata Communications America) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Unitednet v. Tata Communications America, 112 F.4th 1259 (10th Cir. 2024).

Opinion

Appellate Case: 23-2057 Document: 010111096500 Date Filed: 08/19/2024 Page: 1 FILED United States Court of Appeals PUBLISH Tenth Circuit

UNITED STATES COURT OF APPEALS August 19, 2024

Christopher M. Wolpert FOR THE TENTH CIRCUIT Clerk of Court _________________________________

UNITEDNET LTD.; LEVI RUSSELL,

Plaintiffs - Appellants,

v. No. 23-2057

TATA COMMUNICATIONS AMERICA, INC.; TATA COMMUNICATIONS INDIA; TATA SONS PRIVATE, LTD.; STEVEN LUCERO; LATINGROUP, LLC,

Defendants - Appellees. _________________________________

Appeal from the United States District Court for the District of New Mexico (D.C. No. 1:21-CV-01081-KWR-JFR) _________________________________

Scott Fuqua of Fuqua Law & Policy, P.C., Santa Fe, New Mexico, for Plaintiffs - Appellants.

Douglas D. Janicik (Karl Tilleman with him on the brief) of Dentons US LLP, Phoenix, Arizona, for Defendants - Appellees Steven Lucero and LatinGroup, LLC.

Philip D. Robben (Randall L. Morrison Jr. with him on the brief) of Kelley Drye & Warren LLP, New York, New York, for Defendants - Appellees Tata Communications India, Ltd. and Tata Sons Private, Ltd.

Katherine A. McNamara of Fraser Stryker PC LLO, Omaha, Nebraska, for Defendant - Appellee Tata Communications America, Inc. _________________________________

Before BACHARACH, McHUGH, and MORITZ, Circuit Judges. _________________________________ Appellate Case: 23-2057 Document: 010111096500 Date Filed: 08/19/2024 Page: 2

MORITZ, Circuit Judge. _________________________________

This case arises from a foreign business deal gone wrong. In 2016, Unitednet,

Ltd., a United Kingdom company, entered into an agreement to purchase a fiber-optic

telecommunications network owned by three foreign companies that are part of a

multinational conglomerate described in the complaint as the “Tata Communications

empire.” App. vol. 1, 3. But Steven Lucero, a New Mexico resident and key player in

the deal, allegedly conspired with three other Tata companies to sink the deal so that

he could purchase the network through his company based in New Mexico,

LatinGroup, LLC. After the deal fell apart, Unitednet and its director, United

Kingdom resident Levi Russell, filed this action in New Mexico federal district court.

They asserted tortious interference with a contract and related claims against Lucero,

LatinGroup, and the three Tata companies that allegedly participated in the

conspiracy. But the district court dismissed the case under the doctrine of forum non

conveniens, determining that the United Kingdom was a more appropriate forum for

the litigation. Because the district court did not abuse its discretion in concluding that

foreign law applies and that the private and public interests at stake favor dismissal

for forum non conveniens, we affirm.

Background

The facts of this case, as alleged in the complaint, describe a failed business

deal that began in 2013, when Tata Sons Private, Ltd., an Indian investment holding

2 Appellate Case: 23-2057 Document: 010111096500 Date Filed: 08/19/2024 Page: 3

company, decided to sell all noncore assets of the Tata empire to pay down its debt.1

One such asset was a fiber-optic telecommunications network that runs from the

United Kingdom to the Netherlands. Through family connections to the Tata empire,

Lucero learned of the sale and agreed to purchase the network “at a price well below

market value” via his company, LatinGroup. Id. at 4. In early 2014, LatinGroup

formally entered into a preliminary agreement to purchase the network from three

foreign Tata companies—Tata Communications (UK) Ltd., Tata Communications

(Netherlands) B.V., and Tata Communications (Bermuda) Ltd. (together, Tata

sellers).

During the ensuing negotiations, however, Lucero changed plans and decided

to purchase the network through a separate corporate entity. To that end, Lucero

formed Unitednet in the United Kingdom and had LatinGroup assign its purchase

rights to Unitednet. Lucero also made Russell, a United Kingdom resident,

Unitednet’s director and promised him an equity stake in the company as

compensation. Based on that promise, Russell spent the next several years working

on the deal.

But at some point, Lucero allegedly changed course yet again and decided to

sabotage the deal. Lucero realized that he would stand to gain if he could complete

1 In reviewing the district court’s forum non conveniens dismissal, we accept as true the well-pleaded allegations in the complaint unless they are contradicted by affidavits or other evidence. See DIRTT Env’t Sols., Inc. v. Falkbuilt Ltd., 65 F.4th 547, 550 (10th Cir.) (accepting factual allegations in complaint as true in reviewing forum non conveniens dismissal), cert. denied, 144 S. Ct. 197 (2023). 3 Appellate Case: 23-2057 Document: 010111096500 Date Filed: 08/19/2024 Page: 4

the purchase through LatinGroup, as originally planned, rather than through

Unitednet. In an effort to sink the deal, Lucero allegedly “played a dual game in

which he exerted near total control over the negotiations [between Unitednet and the

Tata sellers] for the purchase of the [network].” Id. at 5. Lucero purported to

represent Unitednet’s interests “while at the same time working behind the scenes”

with three other Tata companies—Tata Communications America, Inc., based in

Virginia; Tata Communications India, Inc., based in India; and Tata Sons Private, the

Indian investment holding company (together, Tata defendants)—to control the

position of the Tata sellers. Id. In so doing, Lucero allegedly conspired with the Tata

defendants to impose onerous terms on Unitednet, including a condition that

Unitednet obtain a letter from a bank or investor showing that it had secured nearly

$11 million in funding for the purchase.

In March 2016, after several years of negotiations, Unitednet and the Tata

sellers entered into a sale-and-purchase agreement. The agreement contains the

funding-letter requirement, which provides that Unitednet must produce the letter

showing the securance of nearly $11 million in financing “within 30 days of written

request by the Tata . . . [s]ellers.” Id. at 145. It also contains a forum-selection clause

stating that “[e]ach of the parties consents to the exclusive jurisdiction and venue of

the [c]ourts of England and Wales in any suit or proceeding arising out of or relating

to th[e a]greement or the transactions contemplated by th[e a]greement.” Id. at 165. It

additionally specifies that “[n]othing in th[e a]greement, express or implied, is

intended to confer upon any [p]erson other than United[n]et or the Tata . . . [s]ellers

4 Appellate Case: 23-2057 Document: 010111096500 Date Filed: 08/19/2024 Page: 5

(or their successors or permitted assigns)[] any rights or remedies under or by reason

of th[e a]greement.” Id. at 163–64.

In April 2016, the Tata sellers requested that Unitednet produce the funding

letter, but Unitednet failed to meet the 30-day deadline provided in the agreement.

Eventually, after over a year without receipt of the requisite funding letter, the Tata

sellers terminated the agreement.

Unitednet and Russell then filed this suit in the District of New Mexico against

Lucero, LatinGroup, and the Tata defendants (but not the Tata sellers). Plaintiffs

asserted claims against all defendants for tortious interference with contract, civil

conspiracy, and quantum meruit.

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112 F.4th 1259, Counsel Stack Legal Research, https://law.counselstack.com/opinion/unitednet-v-tata-communications-america-ca10-2024.