VIJAY BASANI & Another v. CYGILANT, INC.

CourtMassachusetts Appeals Court
DecidedJune 4, 2024
Docket23-P-0743
StatusUnpublished

This text of VIJAY BASANI & Another v. CYGILANT, INC. (VIJAY BASANI & Another v. CYGILANT, INC.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
VIJAY BASANI & Another v. CYGILANT, INC., (Mass. Ct. App. 2024).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

23-P-743

VIJAY BASANI & another 1

vs.

CYGILANT, INC.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

This appeal stems from a dispute between the defendant

corporation, Cygilant, Inc. (Cygilant), and two minority

shareholders over the management and direction of the company

and Cygilant's efforts to raise outside capital. The plaintiff

minority shareholders, Vijay Basani and Jayapal Basani, as

trustee of the Reddy Family Living Trust, are the original

founders of Cygilant, which they started in 2003 to develop and

market cyber security software services. They brought this

action in July 2021 alleging that Cygilant had violated certain

contractual rights owed to them. Cygilant counterclaimed,

1 Jayapal Basani, as the trustee of the Reddy Family Living Trust. alleging that the Basanis had violated fiduciary duties owed to

the company. The Basanis filed a motion to dismiss Cygilant's

counterclaim with prejudice, pursuant to Mass. R. Civ. P.

12 (b) (6), 365 Mass. 754 (1974), on the ground that as minority

shareholders they owed no fiduciary duties to Cygilant. The

motion to dismiss was allowed by a judge of the Superior Court.

The judge also denied Cygilant's motion to amend its

counterclaim. 2 At the Basanis' request, their claims were

dismissed without prejudice so that the Basanis could pursue

those claims in a related action in Delaware. 3 A final judgment

of dismissal entered on April 11, 2023. Thereafter, Cygilant

filed a motion for reconsideration, which was denied on May 19,

2023.

2 The judge described Cygilant's motion to amend its counterclaim as "futile" because "the more detailed factual allegations in [the] proposed amended counterclaim [did] not plausibly suggest that the Basanis ever exercised any control over Cygilant's planned refinancing, without which the Basanis would not owe the company a fiduciary duty under Delaware law." Although the judge denied the motion to amend, he analyzed the allegations set forth in both the counterclaim and the proposed amended counterclaim in reaching his conclusion. We do the same. However, we do not consider "legal conclusions cast in the form of factual allegations." Leavitt v. Brockton Hosp., Inc., 454 Mass. 37, 39 n.6 (2009). Stripped of such conclusions, the amended counterclaim still relied on facts associated with the Basanis' exercise of their contractual rights. Accordingly, Cygilant's motion to amend was properly denied.

3 Accordingly, this appeal does not concern any issues with respect to the Basanis' claims.

2 Cygilant appeals, arguing that (1) the motion judge erred

in concluding that Cygilant did not plead facts showing that the

Basanis were controlling shareholders who owed the company

fiduciary duties and (2) to the extent Cygilant's counterclaim

should have been dismissed, the judgment of dismissal should

have been without prejudice. We affirm.

Background. In reviewing the judgment of dismissal, we

accept as true the well-pleaded facts as alleged by Cygilant in

support of its counterclaim and draw all reasonable inferences

in Cygilant's favor. See Shaw's Supermkts., Inc. v. Melendez,

488 Mass. 338, 339 (2021). The Basanis founded Cygilant in 2003

and managed its operations until 2019, at which time they agreed

to separate from the company as officers or directors but

remained shareholders, holding 28.14 percent of Cygilant's

series 1 preferred stock. To protect their interests as

minority shareholders, the Basanis received "enhanced controls

and protections" that were set forth in their stock purchase

agreement and various corporate documents. These protections

gave the Basanis the right to obtain information from the

company, approve debt financing, approve equity financing, and

avoid the dilution of their stock, among other things.

In 2020, Cygilant needed additional operating capital but

was unable to obtain traditional debt financing. Consequently,

Cygilant decided to try to obtain equity financing by offering

3 additional shares of the series 1 preferred stock and, as part

of that process, asked the Basanis to waive some of their

protections. In response, the Basanis demanded information from

Cygilant "under the guise of 'due diligence.'" Cygilant

provided some information, but the Basanis asserted that the

information provided was insufficient. Cygilant alleged that

the Basanis acted out of self-interest by not waiving their

contractual rights and by requiring Cygilant to produce

irrelevant information. Ultimately, the Basanis proposed that

Cygilant raise additional equity financing to buy them out.

Cygilant declined to do so 4 and, instead, obtained debt financing

at premium rates.

Discussion. We review de novo the allowance of a motion to

dismiss for failure to state a claim. See Shaw's Supermkts.,

Inc., 488 Mass. at 339. The parties agree that the primary

issue is whether Cygilant pleaded facts showing that the Basanis

were controlling shareholders who owed the company fiduciary

duties. The parties, and the judge, agreed that since Cygilant

is a Delaware corporation, this issue must be resolved under

Delaware law. Under Delaware law, a shareholder owes fiduciary

duties to the corporation and other shareholders "if [the

4 Cygilant alleged that "[t]he company needed any further investment for its operations and growth, not to line [the] Basanis' pockets."

4 shareholder] owns a majority interest in or exercises control

over the business affairs of the corporation" (quotation,

emphasis omitted). Kahn v. Lynch Communication Sys., Inc., 638

A.2d 1110, 1113 (Del. 1994). Thus, for a minority shareholder

to owe fiduciary duties, that minority shareholder must exercise

"actual control" (quotation omitted). Id. at 1114. A

shareholder who does not exercise actual control as a general

matter but who exercises actual control over a particular

transaction owes fiduciary duties for that particular

transaction. See, e.g., id. at 1114-1115. However, the

exercise of contractual rights, without more, does not amount to

the exercise of actual control. See In re KKR Fin. Holdings LLC

Shareholder Litigation, 101 A.3d 980, 992-994 (Del. Ch. 2014).

Cygilant's allegations show nothing more than the Basanis'

exercise of their contractual rights. As alleged, the Basanis

received certain contractual rights to protect their interests

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kahn v. Lynch Communication Systems, Inc.
638 A.2d 1110 (Supreme Court of Delaware, 1994)
In re KKR Financial Holdings LLC Shareholder Litigation
101 A.3d 980 (Court of Chancery of Delaware, 2014)
Leavitt v. Brockton Hospital, Inc.
907 N.E.2d 213 (Massachusetts Supreme Judicial Court, 2009)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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