Steel River Systems, LLC v. Variant Alternative Income Fund

Summary

The court affirmed dismissal of Steel River’s UCC claim and denial of its preliminary-injunction motion. It held that Steel River did not plausibly allege that the contingent Additional Preferred Return, valued as of contracting, could reasonably be determined to produce an interest rate exceeding New York’s criminal-usury cap. Because the complaint failed to plausibly allege a usury violation, the requested restraints on collateral enforcement were unavailable.