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Thompson v. Anchor Capital GP

2026-07-01

Authorities cited

Opinion

majority opinion

FILED IN

BUSINESS COURT OF TEXAS

BEVERLY CRUMLEY, CLERK

ENTERED

7/1/2026

2026 Tex. Bus. 41

The Business Court of Texas,

1st Division

JEAN CHRISTINE THOMPSON §

and THOMPSON PETROLEUM §

CORPORATION, Plaintiffs § Cause No. 25-BC01B-0038

§

v. §

§

ANCHOR CAPITAL GP LLC and

MICHAEL MANN, Defendants

═══════════════════════════════════════

NUNC PRO TUNC

MEMORANDUM OPINION AND ORDER ON

DEFENDANTS’ MOTION FOR PARTIAL SUMMARY JUDGMENT

═══════════════════════════════════════

[¶ 1] This case is about whether defendants breached various duties

owed to plaintiffs under a promissory note (Note),1 security agreement, and

employment agreement. Before the court is Defendants’ Motion for Partial

1

The promissory note was later amended and reinstated following an additional loan. However, both the original and amended notes were cumulatively entered for the same general purpose. So, references to the Note included within this opinion encompass both notes.

Summary Judgment. The court considered the parties’ pleadings,

submissions and oral arguments.

[¶ 2] The pivotal issue is whether the Note is a “security” under the

Texas Securities Act (TSA). After applying the Supreme Court’s test in Reves

v. Ernst & Young, 494 U.S. 56, 63-64 (1990), the court concludes that the

Note is not a TSA security. Accordingly, the court grants defendants’ motion.

[¶ 3] The parties are familiar with the facts the court discussed in its

May 4, 2026, Memorandum Opinion and Order on Plaintiffs’ Motion for

Summary Judgment. So, the court focuses on only those facts relevant to this

opinion.

I. BACKGROUND

A. Factual Background2

1. The Parties

[¶ 4] Jean Thompson is an owner and President of Thompson

Petroleum Corporation (TPC).3

2

These facts came from evidence contained in the Appendix to Plaintiffs’ Traditional Motion for Partial Summary Judgment (Motion Appx.), which is included in the same document file as Plaintiffs’ Motion, unless otherwise stated.

3

Motion Appx. at 544.

MEMORANDUM OPINION AND ORDER, Page 2

[¶ 5] TPC is a family business that manages the Thompson family’s

assets and employs the J. Cleo Thompson Family Office’s personnel. 4

[¶ 6] Michael Mann is the founder and CEO of defendant Anchor

Capital GP LLC, a private equity investment brokerage comprised of Anchor

and various subsidiaries.5

2. Thompson and Mann form a business relationship.

[¶ 7] Thompson and Mann met in 2022, after which Mann began

offering her investment advice on alternative investments. 6 Using Christy

2017, a holding company for the Thompson family’s investments, Thompson

began investing millions into Anchor-managed funds.7

[¶ 8] In September 2024, Mann asked Thompson to loan Anchor

money so he could buy out one of Anchor’s partners. 8 She agreed contingent

upon Mann providing a personal financial statement and loan guarantee. 9

Mann signed a Secured Promissory Note, Security Agreement, and Mann’s

Personal Guaranty to memorialize this agreement.10

4

Motion Appx. at 544.

5

Motion Appx. at 545.

6

Motion Appx. at 545.

7

Motion Appx. at 545.

8

Motion Appx. at 67.

9

Motion Appx. at 546.

10

Motion Appx. at 69–89.

MEMORANDUM OPINION AND ORDER, Page 3

[¶ 9] The parties amended this agreement three months later after

Mann requested additional funds to buy out another Anchor partner.11

[¶ 10] On May 5, 2025, Thompson exercised her rights to inspect the

Collateral to verify that her loans to Anchor were adequately protected.12 To

that end, she asked Anchor for access to its “books and records.” 13

[¶ 11] Throughout that month, the parties communicated about the

books and records request.14 But by early June, Thompson claimed that

Anchor failed to produce the requested information.15 Approximately two

weeks later, her outside counsel sent a letter requesting additional documents

and answers to specific questions.16

[¶ 12] Mann sent multiple replies but refused to provide an audited

personal financial statement that Thompson requested. 17 So, in late June,

Thompson’s counsel sent another letter about these issues. 18 When Mann

11

Motion Appx. at 547.

12

Motion Appx. at 378–79.

13

Motion Appx. at 79.

14

See Motion Appx. at 381–86.

15

Motion Appx. at 62–63.

16

Motion Appx. at 395.

17

See Motion Appx. at 398, 400–01.

18

Motion Appx. at 404–05.

MEMORANDUM OPINION AND ORDER, Page 4

didn’t respond, counsel sent another letter a week later, detailing the precise

list of necessary, outstanding documents. 19 Counsel sent two more letters.20

[¶ 13] Plaintiffs claim that defendants have not cured any outstanding

deficiencies highlighted in their last letter, which they say are an Event of

Default under both the Note and Security Agreement.21 So, on July 22nd,

Thompson sent Anchor a default notice and accelerated the loan.22

B. Procedural Background

[¶ 14] Plaintiffs sued the next month, 23 and Defendants answered24.

Plaintiffs later filed their First Amended Petition. 25 Defendants then filed this

motion,26 which plaintiffs opposed.27

19

Motion Appx. at 411–20.

20

Motion Appx. at 421–49

21

Motion Appx. at 554–55.

22

Motion Appx. at 450–52.

23

See generally Plaintiffs’ Original Petition (POP).

24

See generally Defendants’ Original Answer, Affirmative and Other Defenses, and Request for Attorneys’ Fees (Orig. Answer). Defendants later filed counterclaims but none are at issue for purposes of this motion. See generally Defendants’ First Counterclaims Against Plaintiffs.

25

See generally First Amended Petition (FAP).

26

See generally Defendants’ Motion for Partial Summary Judgment (MPSJ).

27

See generally Plaintiffs’ Response to MPSJ (MPSJ Response).

MEMORANDUM OPINION AND ORDER, Page 5

II. APPLICABLE LAW

A. Summary Judgment Standards

[¶ 15] At any time, a party may move with or without supporting

evidence for a summary judgment as to all or any part of any causes of action

asserted against it. TEX. R. CIV. P. 166a(b). The motion must state its specific

grounds. Id. at 166a(c).

[¶ 16] Thereafter, the court shall render judgment if the pleadings,

summary judgment filings, and properly filed evidence show that, except as to

the amount of damages, there is no genuine issue as to any material fact and

the movant is entitled to judgment as a matter of law on the issues stated in

the motion or in an answer or any other response. Id.; JLB Builders, L.L.C. v.

Hernandez, 622 S.W.3d 860, 864 (Tex. 2021).

[¶ 17] A court can grant a movant’s traditional summary judgment only

if the movant’s evidence as a matter of law either proves all elements of its

defense or disproves at least one element of the nonmovant’s claim. See e.g.,

Park Place Hosp. v. Estate of Milo, 909 S.W.2d 508, 511 (Tex. 1995) (causation

disproved as a matter of law).

[¶ 18] So a summary judgment motion

MEMORANDUM OPINION AND ORDER, Page 6

…is essentially a motion for a pretrial directed verdict. * * * Once

such a motion is filed, the burden shifts to the nonmoving party

to present evidence raising an issue of material fact as to the

elements specified in the motion. * * * [Courts] review the

evidence presented by the motion and response in the light most

favorable to the party against whom the summary judgment was

rendered, crediting evidence favorable to that party if reasonable

jurors could, and disregarding contrary evidence unless

reasonable jurors could not. * * *

Mack Trucks, Inc. v. Tamez, 206 S.W.3d 572, 581-82 (Tex. 2006) (citations

omitted).

[¶ 19] A genuine fact issue exists if more than a scintilla of evidence

supports the alleged fact. See Amazon.com Servs. LLC v. Grant, No. 05-23-01306, 2024 WL 5053063, at *2 (Tex. App.—5th Dist. Dec. 10, 2024, no

pet.). Evidence is more than a scintilla when it “rises to a level that would

enable reasonable and fair-minded people to differ in their conclusions.” King

Ranch v. Chapman, 118 S.W.3d 742, 751 (Tex. 2003) (quoting Merrell Dow

Pharms., Inc. v. Havner, 953 S.W.3d 706, 711 (Tex. 1997)). However, less

than a scintilla exists when the evidence is “so weak as to do no more than

create a mere surmise or suspicion” of a fact. Id. (quoting Kindred v.

Con/Chem, Inc., 650 S.W.2d 61, 63 (Tex. 1983)).

[¶ 20] When a contract’s terms are unambiguous and the material facts

are undisputed, compliance with those terms is a question of law. Hrdy v.

MEMORANDUM OPINION AND ORDER, Page 7

Second St. Props., 649 S.W.3d 522, 554 (Tex. App.—1st Dist. 2022, pet.

denied).

[¶ 21] Accordingly, to decide this motion, the court must apply

contractual construction principles to the Note and Security Agreement,

Guaranty, Employment Agreement, the parties’ submissions, and the

summary judgment evidence.

B. Contract Construction

[¶ 22] A court’s primary objective when construing contracts “is to

ascertain and give effect to the parties’ intent as expressed in the instrument.”

U.S. Polyco, Inc. v. Tex. Cent. Bus. Lines Corp., 681 S.W.3d 383, 387 (Tex.

2023) (quoting URI, Inc. v. Kleberg Cnty., 543 S.W.3d 755, 763 (Tex. 2018)).

[¶ 23] Usually, courts deem the contract alone to express the parties’

intent because it is objective, not subjective, intent that controls. Id.

[¶ 24] With unambiguous contracts, courts “can determine the parties’

rights and obligations under the agreement as a matter of law.” Inwood Nat’l

Bank v. Fagin, No. 24-0055, 2025 WL 349890, at *4 (Tex. 2025) (per curiam)

(quoting ACS Invs., Inc. v. McLaughlin, 943 S.W.2d 426, 430 (Tex. 1997)).

MEMORANDUM OPINION AND ORDER, Page 8

C. Statutory Construction

[¶ 25] A court’s primary purpose in statutory construction is to

implement the Legislature’s intent by giving effect to every word, clause, and

sentence. Sunstate Equip. Co. v. Hegar, 601 S.W.3d 685, 689-90 (Tex. 2020)

(citation omitted). Indeed, statutory text is the “first and foremost” indication

of legislative intent. Greater Hous. P’ship v. Paxton, 468 S.W.3d 51, 58 (Tex.

2015). Thus, courts apply the words’ common, ordinary meaning unless

(i) the text supplies a different meaning or (ii) the common meaning produces

absurd results. Fort Worth Transp. Auth. v. Rodriguez, 547 S.W.3d 830, 838

(Tex. 2018).

[¶ 26] Further, courts derive statutory meaning from the entire statute.

TEX. GOV’T CODE § 311.021(2); Janvey v. Gold Channel, Inc., 487 S.W.3d 560,

572 (Tex. 2016). So, courts “presume the Legislature chose statutory

language deliberately and purposefully,” Crosstex Energy Servs. L.P., v. Pro

Plus, Inc., 439 S.W.3d 384, 390 (Tex. 2014), and that it likewise excluded

language deliberately and purposefully, Cameron v. Terrell & Garrett, Inc.,

618 S.W.2d 535, 540 (Tex. 1981).

MEMORANDUM OPINION AND ORDER, Page 9

III. ANALYSIS

A. Introduction

[¶ 27] Defendants sought the following summary judgment rulings:

(i) Thompson’s Texas Securities Act claim (Count 3) fails because the Note is

not a security, and (ii) Thompson’s Breach of Guaranty claim (Count 2) fails

because the Guaranty did not require Mann to audit his personal financial

statement.28

[¶ 28] Plaintiffs responded that the court should deny the motion

because (i) the Note is presumed a security, and defendants failed to rebut that

presumption; and (ii) fact issues preclude summary judgment on a guaranty

claim.29

[¶ 29] In a separate, June 18, 2026, order the court concluded that the

Guaranty did not require Mann to provide an audited personal financial

statement.30 Thus, the only remaining issue is whether the Note is a security.

28

See generally MPSJ.

29

See generally MPSJ Response.

30

See generally June 18, 2026, Order on Defendants’ Motion for Reconsideration.

MEMORANDUM OPINION AND ORDER, Page 10

B. Securities Act Claim

1. Introduction

[¶ 30] The TSA 31 creates civil liability for a person who offers or sells a

security by means of an untrue statement of material fact or by means of a

material misleading, omission of fact. TEX. GOV’T CODE § 4008.052(a).

[¶ 31] The TSA broadly defines “securities.” See TEX. GOV’T CODE

§ 4001.068(a).

[¶ 32] Determining whether documents are TSA securities is a matter

of law. Grotjohn Precise Connexiones Intern., S.A. v. JEM Fin., Inc., 12 S.W.3d

859, 868 (Tex. App.—6th Dist. 2000, no pet.). Because the TSA closely

mirrors the Federal Securities Act of 1933, Texas courts look to federal

decisions to aid Texas’s interpretation of the TSA. See Searsy v. Com. Trading

Corp., 560 S.W.2d 637, 639 (Tex. 1977).

2. Parties’ Arguments

[¶ 33] Defendants argue that the Note is merely a “commercial loan

transaction” as opposed to a “security” and thus falls outside the TSA’s

31

The Texas Securities Act was recodified in 2022 under Texas Government Code §§ 4000.001 et seq. However, the recodification merely restates former Texas Civil Statutes article 581, so all cases analyzing the prior statute still hold full force and effect.

MEMORANDUM OPINION AND ORDER, Page 11

purview. 32 Plaintiffs respond that the Note is presumed a security under the

Supreme Court’s adopted “family resemblance” test.33 Defendants’ reply

asserts that the “commercial versus investment” test is the proper test, but

applying the “family resemblance” test produces the same result34

[¶ 34] Accordingly, the court must determine the proper test before

addressing the issue’s merits.

3. Securities Tests

[¶ 35] Since the Securities Act of 1933’s passage, courts have devised

multiple approaches to determine whether promissory notes are “securities.”

Reves, 494 U.S. at 63-64. Specifically, Reves discussed three such approaches

various federal circuits had adopted: (i) the “investment versus commercial”

test, (ii) the “family resemblance” test, and (iii) the Court’s Howey test.

a. “Investment versus Commercial” Test

[¶ 36] Under the “investment versus commercial approach” courts

distinguish, upon the totality of the circumstances, notes issued in investment

contexts (securities) versus notes issued in commercial or consumer contexts

32

MPSJ at 6–7.

33

MPSJ Response at 17–18.

34

Reply in Support of Defendants’ Traditional Motion for Partial Summary Judgment (MPSJ Reply) at 4–6.

MEMORANDUM OPINION AND ORDER, Page 12

(non-securities). Id. This test focuses on the degree to which the plaintiff

depends on the expertise and efforts of others rather than the instruments’

nature. See Futura Development Corp. v. Centex Corp., 761 F.2d 33, 40-41 (1st

Cir. 1985) (adopts investment/commercial test because it focuses on

disclosures and that securities laws were designed to offer protections through

disclosures).

b. “Family Resemblance” Test

[¶ 37] The “family resemblance test” presumes that any note with a

term of more than nine months is a security. Reves, 494 U.S. at 63 (citing

Exchange Nat. Bank of Chi. v. Touche Ross & Co., 544 F.2d 1126, 1137 (2nd

Cir. 1976)). However, that test judicially excepts certain notes that are

obviously not securities, such as (i) notes delivered in consumer financing,

(ii) notes secured by home mortgages, (iii) short-term notes secured by liens

on a small business or some of its assets, (iv) notes evidencing a “character”

loan to bank customers, and (v) notes formalizing open-account debts incurred

in the ordinary course of business. Exchange Nat. Bank, 544 F.2d at 1138.

[¶ 38] Further, that test allows parties to rebut the presumption if they

can show the note either (i) “bears a strong family resemblance” to an item on

MEMORANDUM OPINION AND ORDER, Page 13

the list of exceptions or (ii) convinces the court to add a new instrument to the

list. Reves, 494 U.S. at 64.

c. Howey Test

[¶ 39] The United States Supreme Court developed the Howey Test to

determine if an instrument was an “investment contract,” but some courts

later expanded its application to determine whether an instrument is a “note.”

Id. Under this test, a note is effectively presumed to not be a security unless it

evidences “(1) an investment, (2) in a common enterprise, (3) with a

reasonable expectation of profits, (4) to be derived from the entrepreneurial or

managerial efforts of others.” Id.

d. Adopted Test

[¶ 40] After analyzing all three tests, and noting that the “family

resemblance” and “investment versus commercial” tests formulate the same

general approach, the Reves Court rejected the Howey test and adopted the

“family resemblance” test. Id. at 64-65.

[¶ 41] Texas courts followed and also adopted the “family

resemblance” test as the controlling test on this issue.35 Campbell v. C.D.

Reves and its progeny are narrowly tailored to determining whether notes are securities. 35

The court’s analysis is thus limited to this issue and does not express any views on cases

MEMORANDUM OPINION AND ORDER, Page 14

Payne & Geldermann Sec., Inc., 894 S.W.2d 411, 418 (Tex. App.—7th Dist.

1995, writ denied); Grotjohn, 12 S.W.3d at 868.

[¶ 42] Accordingly, this court applies the “family resemblance” test.

4. “Family Resemblance” Test

a. Applicable Law

[¶ 43] To prevail under the “family resemblance” test, the movant

must rebut the note’s presumed security status by showing the note (i) is an

enumerated judicial exception or (ii) bears a strong family resemblance to one

of the exceptions. Reves, 494 U.S. at 64.

[¶ 44] Courts apply four factors when analyzing whether the note bears

a family resemblance to one of the enumerated exceptions. First, courts

consider the parties’ motivations for entering into the transaction. Id. at 66.

Evidence that the note is for an investment purpose as opposed to a

commercial or consumer purpose suggests that the note is a security. Id.

Second, courts examine the “plan of distribution” to determine whether it is

applying or analyzing tests on instruments aside from notes. See e.g., SEC v. Barton, 135 F.4th 206, 215-17 (5th Cir. 2025) (applying Howey test after concluding loan agreements were investment contracts); Life Partners, Inc. v. Arnold, 464 S.W.3d 660, 684 (Tex. 2015) (applying Howey test after determining life settlement agreements are investment contracts); Christie v. Hahn, No. 05-20-01045-CV, 2022 WL 3572690, at *4 (Tex. App.— 5th Dist. Aug. 19, 2022, no pet.) (mem. op.) (declining to apply Reves after concluding note was an investment contract).

MEMORANDUM OPINION AND ORDER, Page 15

an instrument where there is common trading for speculation or investment.

Id. Third, courts look to the investing public’s reasonable expectations. Id.

Finally, courts examine whether there are risk-reducing measures in place

thereby mitigating the need for statutory protections. Id. at 67.

b. “Short-Term” Note Analysis

[¶ 45] Preliminarily, defendants assert that the Note is “a short-term

note secured by a lien on a small business or some of its assets” thereby

avoiding the need to analyze the “family resemblance” test’s factors.36

Because the parties agree that the Note is secured by Anchor’s assets as

Collateral, the only relevant question is whether the Note is “short-term.”37

[¶ 46] Neither the TSA nor its federal analogues expressly define the

phrase “short-term” regarding securities or other instruments. However, the

statutes suggest that short-term notes are nine months or less. See TEX. GOV’T

CODE § 4005.055(1)(B) (exempting commercial paper with repayment

obligation of less than nine months); 15 U.S.C. § 78c(a)(10) (“[t]he term

ʻsecurity’…shall not include currency of any note…which has a maturity at

36

MPSJ at 7.

37

See MPSJ at 6; MPSJ Response ¶4.

MEMORANDUM OPINION AND ORDER, Page 16

the time of issuance not exceeding nine months[.]”). This approach tracks the

common industry short-term paper definition.38

[¶ 47] Here, the Note has a four-year maturity. 39 So, it is not a “shortterm” note nor excepted from the “family resemblance” test. Accordingly, the

court applies the “family resemblance” test.

c. Reves Factors Analysis

[¶ 48] Because Plaintiffs’ response conceded that the “plan of

distribution” factor (Factor 2) supports Defendants, 40 the court need consider

factors pertaining to only (i) the parties’ motives (Factor 1), (ii) the investing

public’s reasonable expectations (Factor 3), and (iii) the presence of riskreducing measures (Factor 4).

1) Party Motives

[¶ 49] The first factor considers both parties’ purpose for entering into

the Note transaction. Grotjohn, 12 S.W.3d at 868. If the note’s purpose is to

raise money for the business enterprise’s use and the lender seeks to profit off

the note, it is likely a security. Id. However, if the note’s purpose is to

38

See James Chen, Short-Term Paper, https://www.investopedia.com/terms/s/shortterm-note.asp# (last visited June 24, 2026).

39

Appendix to MPSJ (MPSJ App.) at 38-39.

40

MPSJ Response at 20.

MEMORANDUM OPINION AND ORDER, Page 17

generally advance some commercial or consumer purpose, the note is likely

not a security. Id.

[¶ 50] Here, Thompson is entitled to accruing interest on the Note,

which the Reves court held is included in the definition of “profit.” Reves, 494

U.S. at 68 n.4. But Thompson admitted that she agreed to the Note at a belowmarket rate and under a borrower-friendly payment schedule.41

[¶ 51] Thus, while she is entitled to interest, that the Note was

favorable to the borrower as to both payment terms and interest rate suggests

profit was not her primary motive. Cf. Grotjohn, 12 S.W.3d at 869 (favorable

interest rate indicated profit was lender’s primary motivation); SEC v.

Thompson, 732 F.3d 1151, 1162-63 (10th Cir. 2013) (attractive interest rate

suggests profit was primary motive). These facts slightly suggests the Note is

not a TSA security.

[¶ 52] However, Mann admits that he used the Note to raise capital to

avoid diluting Anchor’s existing equity investor. 42 More specifically, Mann

said that the Note’s funds were used to help grow the business by paying

41

Appendix to Plaintiffs’ Motion for Summary Judgment (MSJ App.) at 546. 42

Appendix to MPSJ Response (MPSJ Response App.) at 61-63.

MEMORANDUM OPINION AND ORDER, Page 18

salaries and other standard business expenses.43 Together, these facts suggest

the Note is a security. See Aubrey v. Barlin, 159 F.Supp.3d 752, 755 (W.D.

Tex. 2016) (notes likely security because funds used for general business

purposes).

[¶ 53] Thus, the borrower’s and seller’s motives are mixed. But

because Mann’s motives are clearly for investment purposes, this factor favors

the Note being a security. See Pollack v. Laidlaw Holdings, Inc., 27 F.3d 808,

812-13 (2d Cir. 1994) (buyer’s clearer motives suggest note is a security).

2) Investing Public’s Reasonable Expectations

[¶ 54] The third factor considers how the investing public would

reasonably view a note. Reves, 494 U.S at 58-59. Courts analyzing this factor

consider the (i) note’s express language, (ii) notes’ advertisement, and

(iii) parties’ sophistication. See Kirschner v. JP Morgan Chase Bank, N.A., 79

F.4th 290, 308 (2d. Cir. 2023). Here, these considerations suggests that the

Note is not a security.

[¶ 55] For starters, the Note is entitled a “Secured Promissory Note,”

which without more does not give rise to public expectations that the Note is

43

MPSJ Response App. at 63.

MEMORANDUM OPINION AND ORDER, Page 19

a security.44 Cf. Grotjohn, 12 S.W.3d at 669-70 (convertible debenture altered

investing public’s expectations surrounding instrument). There are also no

references to “investors” or “investments” in the Note to suggest that the

Note is a security. See Kirschner, 79 F.4th at 308 (isolated references to

“investors” insufficient to create reasonable expectation instruments were

securities). Instead, the instruments at issue frequently refer to the funds

associated with the Note as a loan.45

[¶ 56] Second, there is no evidence suggesting that the Note was ever

advertised as an investment. When a note is advertised as an investment, “in

the absence of contrary indications it is reasonable for prospective purchasers

to take the offeror at its word.” Stoiber v. S.E.C., 161 F.3d 745, 751 (D.C. Cir.

1998) (quoting Reves, 494 U.S. at 69) (internal citations omitted).

Conversely, when express disclaimers are made indicating the note is not an

investment, the investing public can reasonably conclude that the note is not

a security. Id. Because there is no evidence suggesting the Note was ever

44

See MPSJ App. at 38.

45

See MPSJ App. at 17–22, 29–30, 38–39. Additionally, the Note includes an ambiguous disclaimer (in bold at the top of the instrument) stating that “this note has not been registered under [any securities laws] and may not be sold without registration.”

MEMORANDUM OPINION AND ORDER, Page 20

advertised as an investment, the investing public lacks a reasonable basis to

conclude the Note is a security.

[¶ 57] Finally, there is no dispute whether these are sophisticated

businesspersons as they are actively involved in handling finances and

represented by sophisticated counsel. So, the court can reasonably conclude

the parties had a solid understanding that the Note was a loan and not a

business enterprise investment. See Banco Espanol de Credito v. Sec. Pac. Nat.

Bank., 973 F.2d 51, 55 (2d Cir. 1995) (parties’ sophistication ensured ample

notice given to instruments’ purpose).

[¶ 58] Based on the forgoing, the investing public would not reasonably

view the Note as an investment. Accordingly, this factor weighs against the

Note being a security.

3) Risk-Reducing Measures

[¶ 59] The final factor considers whether there are schemes in place

that reduce the instrument’s risk and thereby moot the need for securities

protections. Reves, 494 U.S. at 67.

MEMORANDUM OPINION AND ORDER, Page 21

[¶ 60] Here, the Note is both collateralized and personally guaranteed

by Mann. 46 Further, the Note contains extensive representations, warranties,

and covenants which provide additional protections. 47 And the agreements

gave Thompson rights to inspect the collateral and require Mann to provide

her with financial information in a form and substance reasonably acceptable

to her.48

[¶ 61] Having multiple risk-reducing measures in place strongly

suggests the Note is not a TSA security. Accordingly, this factor also weighs

against the Note being a security.

4) Conclusion

[¶ 62] Based on the above Reves analysis, the court concludes as a

matter of law that the Note is not a security While the first factor leans toward

the Note being a security, the other three factors support that the instrument

in question is not a security.

46

MPSJ App. at 17, 29.

47

See MPSJ App. at 8–9.

48

MPSJ App. at 31–32.

MEMORANDUM OPINION AND ORDER, Page 22

IV. CONCLUSION

[¶ 63] Consistent with this opinion and its prior June 18 order,

Defendants’ Traditional Motion for Partial Summary Judgment is GRANTED.

So ORDERED.

BILL WHITEHILL

Judge of the Texas Business Court,

First Division

SIGNED: July 1, 2026

MEMORANDUM OPINION AND ORDER, Page 23

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Case Contacts

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