LCM Litigation Fund Pty Ltd v Coope [2017] NSWCA 200

LCM Litigation Fund Pty Ltd v Coope [2017] NSWCA 200

Passive receipt of a funding application and the execution of a funding agreement did not constitute 'direct dealings' as required by the undertaking. The evidence did not establish that any relevant dealings with the client (Mr Farnsworth) were done by the respondent in his capacity as an officer of LCM, but rather as an officer of SCF. Accordingly, contempt was not made out.

Jurisdiction
Australia
Judgment Date
11 August 2017
Procedural Posture
Appeal / Final Judgment on Appeal
Outcome
Appeal dismissed
Legal Topics
['breach of Undertaking' 'construction of Employment Restraint' 'direct Dealings' 'solicitation of Clients' 'litigation Funding']

Case Brief

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Procedural Posture

Appeal / Final Judgment on Appeal

  1. 1 ["Whether the respondent had 'direct dealings' with a client of the appellant within the meaning of an undertaking to the court" "Whether passive receipt of a funding application or execution of a funding agreement constituted 'direct dealings'" 'Whether communications constituted breach of an undertaking restraining solicitation, canvassing, or approaching clients']

Ratio Decidendi

Passive receipt of a funding application and the execution of a funding agreement did not constitute 'direct dealings' as required by the undertaking. The evidence did not establish that any relevant dealings with the client (Mr Farnsworth) were done by the respondent in his capacity as an officer of LCM, but rather as an officer of SCF. Accordingly, contempt was not made out.

Court Disposition

Appeal dismissed

Orders

  • ['Appeal dismissed' "Appellant to pay the respondent's costs"]