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3rd Circuit Grants Summary Action in $9M Judgment Collection Case

The U.S. Court of Appeals for the Third Circuit issued a non-precedential opinion granting summary action in consolidated appeals involving Mark Stiffler's challenge to preliminary injunctive relief. Rivertown TCI, L.P. seeks to collect on a state court judgment exceeding $9 million.

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Seal of the Third Circuit Court of Appeals

Case Information

Case No.:
No. 25-1487

Key Takeaways

  • Third Circuit granted summary action in consolidated appeals involving $9 million judgment collection
  • Mark Stiffler unsuccessfully challenged preliminary injunctive relief granted to Rivertown TCI, L.P.
  • Court issued non-precedential opinion disposing of appeals without full briefing or oral argument

The U.S. Court of Appeals for the Third Circuit issued a non-precedential opinion on January 9, 2026, in the consolidated cases of *Rivertown TCI, L.P. v. Optymyze Pte Ltd.* and *Mark Stiffler*, disposing of the appeals through summary action without full briefing.

The consolidated cases, numbered 25-1487 and 25-2528, involved Mark Stiffler's appeals challenging the grant of preliminary injunctive relief to Rivertown TCI, L.P. The underlying dispute centers on Rivertown's efforts to collect on a state court judgment exceeding $9 million.

The appeals originated from the U.S. District Court for the Eastern District of Pennsylvania, where District Judge Nitza I. Quiñones Alejandro presided over the original proceedings under case number 2:24-cv-02576. The matter was submitted to the Third Circuit on December 11, 2025, based on the appellee's motion for summary action pursuant to Third Circuit Local Appellate Rule 27.4 and Internal Operating Procedure 10.6.

A three-judge panel consisting of Circuit Judges Krause, Matey, and Bove reviewed the case. The court's per curiam opinion noted that it was writing primarily for the parties, who were familiar with the procedural history and underlying facts, and therefore did not include extensive detail in the published opinion.

The case involves multiple parties, including Rivertown TCI, L.P. as the primary plaintiff seeking to enforce its judgment, and defendants Optymyze Pte Ltd., represented through its President and CEO Alexandru Sandu, and Mark Stiffler. Stiffler served as the appellant in both consolidated cases.

Summary action procedures allow appellate courts to dispose of cases without full briefing and oral argument when the legal issues are straightforward or when the appeal lacks merit. Under Third Circuit rules, such motions are typically granted when the court determines that full appellate review is unnecessary because the outcome is clear based on existing law and the record.

The court's jurisdiction to review the preliminary injunction stemmed from 28 U.S.C. § 1292(a)(1), which provides federal appellate courts with immediate jurisdiction over orders granting or denying preliminary injunctions. This statutory provision allows parties to appeal preliminary injunction rulings without waiting for final judgment in the underlying case.

The opinion references *Delaware Strong Families v. Attorney General of Delaware* as precedent for the court's authority to review preliminary injunction orders. This jurisdictional foundation is crucial in federal civil procedure, as it represents one of the limited exceptions to the general rule that appeals must wait until final judgment.

The underlying commercial dispute appears to involve significant financial stakes, given the reference to a state court judgment exceeding $9 million that Rivertown TCI seeks to collect. While the Third Circuit opinion does not detail the nature of the original dispute or the basis for the state court judgment, the substantial amount suggests a complex business relationship or transaction gone awry.

Preliminary injunctions require plaintiffs to demonstrate likelihood of success on the merits, irreparable harm, that the balance of hardships favors granting the injunction, and that the injunction serves the public interest. The district court's grant of preliminary injunctive relief in favor of Rivertown TCI suggests the trial court found these elements satisfied in the judgment collection context.

Stiffler's decision to appeal the preliminary injunction indicates disagreement with either the district court's legal analysis or its application of the preliminary injunction factors to the specific circumstances of this case. However, the Third Circuit's grant of summary action suggests the appeals lacked sufficient merit to warrant full appellate review.

The non-precedential nature of the opinion, as noted in the court's disclaimer, means the decision does not constitute binding precedent under Third Circuit Internal Operating Procedure 5.7. Such dispositions are common for routine matters that do not involve novel legal questions or significant jurisprudential development.

This case represents typical commercial litigation involving judgment enforcement, where creditors seek court assistance in collecting on existing judgments. The involvement of both domestic and international entities, including Singapore-based Optymyze Pte Ltd., suggests potential complications in asset recovery or jurisdiction that may have necessitated federal court intervention.

The swift resolution through summary action, less than a month after submission, indicates the Third Circuit found the legal issues sufficiently clear to warrant expedited disposition. This efficiency serves judicial economy by avoiding unnecessary expenditure of court resources on appeals unlikely to succeed.

For practitioners in commercial litigation and judgment collection matters, this case demonstrates the continued viability of preliminary injunctive relief as a tool for creditors seeking to preserve assets or prevent conduct that might frustrate judgment collection efforts. The decision also illustrates federal courts' willingness to use summary action procedures to efficiently dispose of appeals lacking substantial merit.

Topics

preliminary injunctionappealsjudgment enforcementcivil litigationappellate procedure

Original Source: courtlistener

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