Issue No. 13 — November 2, 2026

Cornice Ventures v. Silberstein (Thrasio) — investors' fraud claims against a founder held time-barred (Del. Oct. 5, 2026, No. 29, 2026)

Two investment entities, Cornice Ventures I and II, bought about $15 million of Thrasio Holdings' Series C-2 and C-3 preferred stock in early 2021. In August 2024 they sued co-founder and former chief executive Joshua Silberstein for fraud, negligent misrepresentation, and unjust enrichment, first in New Jersey and then, in April 2025, in the Delaware Superior Court, which dismissed the claims as untimely under the three-year statute, 10 Del. C. § 8106. The Supreme Court affirmed. Justice Traynor reasoned that any tolling ended once the plaintiffs were on inquiry notice, and that the threshold was crossed in April 2021, if not sooner, when the company breached its contractual obligation to deliver audited financial statements within 120 days after fiscal year-end. The courts did not decide whether the alleged fraud occurred.

United States v. Güven (Kalder) — founder sentenced to 25 months after a seed-round fraud plea (S.D.N.Y. Oct. 30, 2026, No. 25-cr-592)

Gökçe Güven, founder and former chief executive of Kalder Inc., a New York loyalty-program start-up, was sentenced by Judge Lewis A. Kaplan to 25 months in prison, with forfeiture and restitution of $6,717,997 each, after pleading guilty in May to securities fraud. According to the U.S. Attorney's Office, Kalder's April 2024 seed round raised about $7 million from more than a dozen investors through misrepresentations that included false pitch-deck claims about brand customers and recurring revenue, inflated books supplied to investors, and a forged partner contract.

Kulak v. On (Movado PT Technologies) — final judgment authorized on an investor's fraudulent-inducement claim; fees shifted (Del. Ch. Oct. 16, 2026, C.A. No. 2023-0011-KSJM)

Kevin Kulak lent $250,000 in 2020 to Movado PT Technologies, a rehabilitation-app start-up. On April 24, Chancellor McCormick granted him summary judgment on fraudulent inducement, finding that the founders' June 2020 investor presentation described computer-vision capabilities the company did not have. On October 16, the court denied the self-represented founders' subsequent motions, permitted dismissal without prejudice of his derivative claim, and authorized entry of final judgment on the fraud claim under Rule 54(b), with interest. Applying the bad-faith exception, it allowed Kulak's fees and expenses for responding to the recusal, supplemental-declaration, and Rule 60 motions, denied his two sanctions motions, and requested a proposed final order.

Meta Platforms — stockholder class complaint filed Oct. 27 (Del. Ch., C.A. No. 2026-1413) alleging fiduciary breaches in the Class C recapitalization and seeking to enjoin it before its Jan. 19, 2027 effective date; allegations only • Robertson v. Cerebral — Magistrate's final report Oct. 29 (Del. Ch.) allowing the former chief executive advancement for the Cerebral-related portions of his defense of the government's civil action, not for claims based solely on his later ventures; subject to exceptions.