Strobl v. Croft, 1:24-cv-00140

Plaintiffs allege that defendants, including Kawamura (CEO of ROI), operated a fraudulent investment scheme via Rhino Onward International, LLC (ROI).
Kawamura purportedly failed to correct false statements in investment calls and permitted co-defendants to divert investor funds for personal and unrelated business use.
Plaintiffs claim that Kawamura’s conduct (and his alleged travel to Tennessee) connects him to the state for purposes of jurisdiction.
The Court previously denied Kawamura’s motion to dismiss for lack of personal jurisdiction, holding that jurisdiction was proper based on a conspiracy theory.
Kawamura moved to certify that decision for interlocutory appeal and to stay the case as to himself; plaintiffs opposed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether interlocutory appeal should be certified on conspiracy-based personal jurisdiction issue	The issue is not a pure legal question but a fact-intensive, case-specific inquiry; appeal is premature	Whether conspiracy-based jurisdiction over out-of-state defendants lacking minimum contacts is a controlling question warranting immediate appeal	Certification denied; issue is a mixed law/fact question not suited for interlocutory appeal
Whether an immediate appeal would materially advance litigation	Appeal would not save significant resources as discovery will proceed and Kawamura would be involved regardless	Immediate appeal would end claims against Kawamura and save time/expense	Certification denied; litigation would proceed similarly regardless of appeal

Chenault v. Walker, 36 S.W.3d 45 (Tenn. 2001) (discussing conspiracy theory of personal jurisdiction)
Eisen v. Carlisle & Jacquelin, 417 U.S. 156 (1974) (explaining policy against piecemeal appeals)
In re City of Memphis, 293 F.3d 345 (6th Cir. 2002) (standards and discretion for certifying interlocutory appeals)