LDL Capital, LLC v. Blume
9:23-cv-80942
S.D. Fla.Aug 23, 2024Background
- Plaintiffs invested in Jaguar Cryptocurrency, LLC, a Bitcoin mining company managed by Defendant Corbin Blume, based in Florida.
- Blume offered in writing to repurchase Plaintiffs' membership interests at a 1.4x return on invested capital; Plaintiffs accepted by signing settlement agreements.
- Blume repeatedly reaffirmed the buyback obligations but failed to tender payment, resulting in Plaintiffs' breach of contract suit.
- Plaintiffs unsuccessfully attempted personal service on Blume 18 times, eventually resorting to substituted service via Florida’s long-arm statute and the Secretary of State.
- Default was entered against Blume after he failed to respond or appear, and Plaintiffs moved for default final judgment.
- Plaintiffs sought damages totaling $1,302,000 plus prejudgment and post-judgment interest, attorney’s fees, and costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject-matter jurisdiction (diversity) | Complete diversity, amount in controversy exceeds $75,000. | No response | Jurisdiction satisfied. |
| Personal jurisdiction via long-arm/statute | Blume did business in FL, evaded service; substituted service proper. | No response | FL long-arm satisfied, service sufficient, due process met. |
| Existence/breach of unilateral contract | Offer accepted per written agreements; Blume failed to pay contractual sums. | No response | Contract exists, was breached; Plaintiffs entitled to damages. |
| Necessity of hearing on damages | Damages calculable from record; hearing unnecessary. | No response | Damages, interest justified — no need for hearing. |
Key Cases Cited
- Mitchell v. Brown & Williamson Tobacco Corp., 294 F.3d 1309 (11th Cir. 2002) (standards for entry of default judgment)
- Tyco Fire & Sec., LLC v. Alcocer, 218 F. App’x 860 (11th Cir. 2007) (default judgment sufficiency standard)
- Venetian Salami Co. v. Parthenais, 554 So. 2d 499 (Fla. 1989) (two-step test for personal jurisdiction under FL’s long-arm statute)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (minimum contacts and due process for personal jurisdiction)
- Friedman v. N.Y. Life Ins. Co., 985 So. 2d 56 (Fla. 4th DCA 2008) (elements of breach of contract under Florida law)
- Kolodziej v. Mason, 774 F.3d 736 (11th Cir. 2014) (definition and requirements of unilateral contract under FL law)