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TrueCoin v Techteryx [2024] SGHC 296: Singapore High Court grants anti-suit injunction upholding SIAC arbitration agreement in cryptocurrency dispute; comity, forum fragmentation and non-party limits addressed

Published on: 21 January 2025

Published by a LexisNexis Arbitration expert
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TrueCoin LLC v Techteryx, Ltd [2024] SGHC 296 Background

The dispute concerned TrueCoin, a Delaware entity engaged in creating digital currency offerings such as stablecoins. Through two contracts governed by Delaware law, TrueCoin conferred on Techteryx, a BVI company, certain exclusive entitlements over its TrueUSD stablecoin (TUSD). Each contract stipulated SIAC rules with arbitration seated in Singapore. Later, the two parties jointly issued an instruction notice (the Notice) to an escrow agent to release and transfer the digital assets to Techteryx’s agent. The Notice was subject to Hong Kong law and named the Hong Kong courts as having non-exclusive jurisdiction. When Techteryx allegedly defaulted on payment commitments, TrueCoin commenced two SIAC arbitrations, which were subsequently consolidated. Techteryx, for its part, began proceedings in Hong Kong, initially against the escrow agent and two further parties under separate agreements linked to the TrueCoin transaction, and thereafter joined TrueCoin as a defendant for alleged breaches of the stablecoin agreements and for misrepresentation. Techteryx’s position was that the arbitration agreement had been displaced by the Hong Kong jurisdiction clause contained in the Notice and therefore governed their disputes in full...

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