Forian Holdings LLC v. Symphony Health Solutions Corp.
CourtCourt of Chancery of Delaware
Date FiledJune 17, 2026
Docket2026-0686-LWW
StatusPublished
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Full Opinion
COURT OF CHANCERY
OF THE
STATE OF DELAWARE
LORI W. WILL LEONARD L. WILLIAMS JUSTICE CENTER
VICE CHANCELLOR 500 N. KING STREET, SUITE 11400
WILMINGTON, DELAWARE 19801-3734
June 17, 2026
Michael A. Barlow, Esquire Blake Rohrbacher, Esquire
Shannon M. Doughty, Esquire Kevin M. Gallagher, Esquire
Quinn Emanuel Urquhart Andrew L. Milam, Esquire
& Sullivan, LLP Saralynn G. Davis, Esquire
500 Delaware Avenue, Suite 1400 Richards, Layton & Finger, P.A.
Wilmington, Delaware 19801 920 North King Street
Wilmington, Delaware 19801
RE: Forian Holdings LLC, et al. v. Symphony Health Solutions Corp., et
al., C.A. No. 2026-0686-LWW
Dear Counsel:
I write regarding your submissions on the appropriate amount of a bond in
accordance with my June 2, 2026 bench ruling and subsequent Status Quo Order.1
The Status Quo Order preserves the status quo by requiring the defendants to
maintain the historical supply of commercial data to Forian Holdings LLC pending
a preliminary injunction hearing.
1
See Joint Letter Regarding Bond Amount (Dkt. 27) (“Letter”) 1; Status Quo Order
(Dkt. 16).
C.A. No. 2026-0686-LWW
June 17, 2026
Page 2 of 3
The defendants request a bond of $10 million.2 This figure is based on
estimates of downstream customer attrition that might occur if certain data suppliers
object to providing further data to Symphony Health Solutions Corp. The plaintiffs,
for their part, submit that a bond of no more than $437,000 is appropriate.3 This
figure corresponds to two months of fees owed to the defendants under the operative
contracts and aligns with the parties’ bargained-for limitation of liability in Section
9.4 of the Master Services Agreement.4
“Because actual damages are uncertain, and because a wrongfully enjoined
party has no recourse other than the security, the court should ‘err on the high side’
in setting the bond.”5 If the bond is too high, the plaintiffs will ultimately recover
the excess. But if the bond is too low and the Status Quo Order is later deemed
improvidently issued, the defendants may suffer losses.6
2
See Letter at 8.
3
See id. at 4.
4
See id. at 4-5.
5
Guzzetta v. Serv. Corp. of Westover Hills, 7 A.3d 467, 470 (Del. 2010).
6
See Leon v. Orlando, 2024 WL 2862452, at *2 (Del. Ch. June 5, 2024); see also Steward
Health Care Sys. LLC v. Tenet Bus. Servs. Corp., 2022 WL 3025587, at *6 (Del. Ch.
Aug. 1, 2022).
C.A. No. 2026-0686-LWW
June 17, 2026
Page 3 of 3
That said, a bond cannot be predicated on speculative harm.7 At the June 2
hearing, I directed the defendants to provide evidence, such as upstream penalty
provisions or actual costs, to justify their $10 million calculation. The defendants
have failed to do so, relying instead on hypotheticals about how third-party suppliers
might react and the ensuing downstream consequences.
The $437,000 figure advanced by the plaintiffs, by contrast, appropriately
provides security in accordance with the economic realities of the parties’
commercial relationship.8 It relies on metrics contemplated by the operative
agreements rather than estimates of potential, indirect harm. The plaintiffs must post
a bond in this amount within three business days of this letter. If necessary, I will
take up whether a larger bond is warranted at the preliminary injunction hearing.
IT IS SO ORDERED.
Sincerely yours,
Lori W. Will
Lori W. Will
Vice Chancellor
7
See Comcast Cable Commc’ns Mgmt., LLC v. CX 360, Inc., 2025 WL 79953, at *2 (Del.
Ch. Jan. 13, 2025).
8
See Status Quo Order, Health Intel. Co. v. Komodo Health, Inc., C.A. No. 2024-0702-
LWW (Del. Ch. Aug. 5, 2024).