NANOVENTIONS HOLDINGS, LLC v. STEVEN DANIELS A/K/A STEVEN DANIEL, A21A0167

Nanoventions Holdings, LLC sued former CFO Steven Daniels and multiple other individuals/entities for claims including conversion and unjust enrichment; several defendants were dismissed or defaulted during litigation.
The trial court granted summary judgment to Nanoventions on most claims against Daniels and entered a money judgment of $6,147,729.93 against him.
The court denied Nanoventions’ summary judgment motion on the conversion claim (Count 5) and did not rule on unjust enrichment (Count 7). Those claims therefore remained disputed.
The court entered default liability judgments against BIW (damages reserved) and against Hutchinson (later concluded Nanoventions could not collect from her).
The trial court issued a February 26, 2020 order styled as a “Final Order” purporting to resolve all claims, and Nanoventions appealed directly to the Court of Appeals.
The Court of Appeals concluded it lacked jurisdiction because material claims (conversion, unjust enrichment, and BIW damages) remained pending and the trial court had not entered a Rule 54(b) certification nor had Nanoventions followed interlocutory appeal procedures.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the February 26 order is a final, appealable judgment under OCGA § 5-6-34(a)(1)	The order states it is a full and final resolution of all claims; thus the appeal is proper.	Several claims and damages issues remained pending so the order is not final.	Not final; appeal dismissed for lack of jurisdiction.
Effect of denied summary judgment on conversion claim against Daniels	Judgment on other claims plus money judgment resolved the case; conversion claim does not bar finality.	Denial of summary judgment left genuine issues of material fact on conversion, so claim remains pending.	Conversion claim remained pending; order not final.
Whether default judgment against BIW (liability only) is final	Liability judgment suffices to conclude that defendant's rights were adjudicated.	Damages were expressly reserved, so the case remains open as to BIW.	Liability-only default is not final when damages are reserved.
Whether Rule 54(b) certification or interlocutory appeal procedures were required	Plaintiff relied on the trial court’s wording that the order was final.	Without an express Rule 54(b) directive or compliance with OCGA § 5-6-34(b) interlocutory procedures, appeal is premature.	Plaintiff needed Rule 54(b) certification or to pursue interlocutory review; failure to do so mandates dismissal.

Johnson v. Hosp. Corp. of America, 192 Ga. App. 628 (1989) (decision adjudicating fewer than all claims or parties is not final)
Standridge v. Spillers, 263 Ga. App. 401 (2003) (finality determined by substance, not nomenclature)
Rapid Taxi Co. v. Broughton, 244 Ga. App. 427 (2000) (judgment not final if it does not dispose of entire case)
Holloway v. McMichael, 151 Ga. App. 802 (1979) (case not final where issue of damages is reserved)
Pace Constr. Corp. v. Northpark Assocs., 215 Ga. App. 438 (1994) (failure to follow appellate procedures requires dismissal)