Thursday, October 19, 2017

A US perspective on the risks of term sheets

https://www.sullcrom.com/siteFiles/Publications/Konevsky_JIBFL_June_2011.pdf


Preliminary outlines of a proposed transaction – 
whether styled as term sheets, letters of intent, memoranda of understanding or agreements in principle – allow the parties to sketch out the fundamental terms in a non-invasive document before expending substantial resources on negotiating definitive agreements, finalising due diligence, pursuing third-party approvals and other matters. These documents appear simple and as something that can be advanced without lawyers. The opportunities for later re-trades and selective lapses in memory on key points are reduced, at least in theory. Furthermore, an ‘agreed’ term sheet can facilitate discussions with the debt and equity financing providers, as well as allow preliminary discussions and filings with antitrust and other regulators. Lastly, it is often said that these documents can create deal momentum and foster a moral and psychological commitment on the part of the principals to do the deal or, at a minimum, work towards getting one done on the outlined terms. In many cases where such arrangements come up in complex corporate transactions, the parties are unlikely to think of themselves as legally obligated to do the deal unless, and until, they get to a signed definitive contract (and may view time and expenses spent in the process as a sunk cost of exploring strategic alternatives). 
Often the parties produce a hybrid preliminary document that presents a non-binding outline of the main transaction points with certain binding provisions (such as exclusivity/no-shop and confidentiality provisions, as well as termination, governing law, choice of forum, waiver of jury trial and other miscellaneous provisions). 
There are also downsides. While these types of documents may save time and expense in the long run, they have as much chance to absorb the deal team in long and protracted negotiations on the short-form terms. And time is the greatest enemy of every deal. Substantial expenses may already be run up. Management time and focus may already be diverted. Alternative strategic opportunities may be passed up, markets may move against the parties in the meantime and the world could change. In some cases, as one commentator noted, ‘[i]n a panic, with good intentions or out of sheer frustration, the parties reduce their total lack of understanding and lack of workable transactional framework’ into a preliminary agreement, with a hope of papering over differences, kicking the can and praying to make progress later. 
As a broader point, the parties may have only a general idea about what their status is and where they are heading, or divergent views and expectations that are not well articulated. In some cases, public disclosure obligations may be triggered. Then there are leaks, of course, coupled with desire on certain parties’ sides to tout the term sheet voluntarily to the world, or shop it to other bidders. An even greater risk, however, is that, if things go sour, a court concludes that the preliminary outline of terms is, in fact, something more than a free pass – either a fully binding agreement in and of itself, capable of being enforced with specific performance or awards of expectation damages, or an agreement to negotiate in good faith within the agreed parameters for some period of time. 
There is, of course, also a converse risk of a court failing to enforce what the parties may have thought was a binding agreement or certain of its portions that they assumed would bind – although this fear is usually secondary to being trapped in an unwanted marriage. 
The risk of being entrapped in a binding relationship may be particularly surprising in a cross-border context where the walking around assumption for most principals is that – unlike in certain European and other jurisdictions – US law immunizes transaction participants from precontractual liabilities and duties of good faith (including a duty to work in good faith to try to do a deal on the basis of an agreed term sheet). That is not the law, however. As the Delaware Court of Chancery in Global Asset Capital, LLC v Rubicon US REIT, Inc noted, ‘parties enter into [letters of intent] for a reason. They don’t enter into them because they are gossamer and can be disregarded whenever situations change. They enter into them because they create rights.’ So a term sheet can lead the parties down the path of pleasure or pain. And the latter alternative is not academic. Case reporters are full of litigation, which is not just limited to dealings among the unsophisticated and the under-advised. Disputes arise out of high-profile acquisitions, financings, commercial and licensing transactions and settlement negotiations. There is no one uniform rule that governs the enforceability of such documents. 
The question is largely a function of state common law and, consequently, differs from state to state; with respect to laws of a specific state, there are divergences of tone, approach and, sometimes, outcome between state courts and federal courts applying such state’s law, as well as evolving views that are sometimes difficult to spot and reconcile. 
And within a jurisdiction, the application of the law can be inconsistent and turn on nuanced facts that make advance planning difficult. Despite – or because of – evolving jurisprudence on the topic, Professor Farnsworth’s observation that ‘[i]t would be difficult to find a less predictable area of contract law’ has held up well these last couple of decades. Litigation over these matters is typically very fact-intensive and, therefore, potentially long, expensive and unpredictable. The lack of clarity complicates planning and compounds transaction costs. It can also introduce an element of strategic behaviour and moral hazard. If a party continues to like the deal, it can claim that the term sheet was binding and use it as potentially cheap insurance; if not, it can argue that it was never intended to bind. 
It is equally important not to overstate the issue. There are a number of tools available to informed and well-advised parties who decide to prepare a preliminary agreement for sound commercial or other reasons that are likely either to mitigate the potential for a dispute or, if one does come to pass, demonstrate to a court what the intentions of the parties were and how to enforce them. While it is tempting to say – and is true to some extent – that most litigation results from ambiguous drafting, that is not always the culprit. There are many term sheets that are labeled as ‘not binding’ (often in bold face with flashing lights) that end up being litigated. What is critical is to establish and coordinate – across all phases of the discussions and all deal workstreams – a consistent tone that represents the intent of the parties. 

HISTORICAL BACKGROUND 
In Venture Assoc Corp v Zenith Data Sys. Corp, Judge Posner has called this space ‘one of the most difficult areas of contract law’. The relationship between the parties before there is a signed definitive contract in place is nuanced and slippery and difficult to describe in practice and, consequently, as a matter of law. Historically, however, the question of precontractual liability under American common law (and its English roots) was generally binary. Preliminary manifestations of assent did not create binding obligations. Parties were free to negotiate at will, make offers and counteroffers and manoeuvre at will until such time as a legally cognisable contract crystallised. In this light, term sheets and other preliminary agreements can seem as neither fish nor fowl from that perspective – parties may not be in pure exploratory negotiation mode by the point they settle on a preliminary outline of a deal, but not committed to do the transaction either until more work takes place. Towards the end of the 20th century, however, courts began to shift away, albeit somewhat reluctantly, from this ‘all-or-nothing’ approach. There was a recognition that complex staggered guts of deal-making and negotiations, and the preliminary agreements that arise out of them, are something different, something that needs recognition. As one California court noted in Copeland v Baskin Robbins, ‘[c]ontracts today are not formed by discrete offers, counteroffers and acceptance. Instead they flow from a gradual flow of information between the parties followed by a series of compromises and tentative agreements on major points which are finally refined into contract terms’. The courts, even those that have noted the need for a more pragmatic assessment of the economic realities and role of preliminary agreements in transactional practice, have generally struggled with the task. As the US Court of Appeals for the Second Circuit put in Adjustrite Systems, Inc v GAB Business Services, Inc, the challenge lies in the twin concerns of, on the one hand, ‘trapping parties in surprise contractual obligations that they never intended’ and, on the other hand, enforcing certain preliminary agreements, ‘for it is the aim of contract law to gratify, not defeat, expectations’. 

IS THERE A BINDING CONTRACT TO DO THE UNDERLYING DEAL? 
However elusive the law may be, each case is generally rooted in the principle that the objective outward intent of the parties is the key factor. Those courts that will entertain the enforceability of a term sheet generally consider a wide array of factors to discern the intent of the parties with respect to the underlying transaction outlined in a term sheet (courts often have less difficulties with respect to specific provisions, such as the non-shop/exclusivity and confidentiality provisions, that are clearly designated as being binding). These factors differ from case to case and often turn on the specific facts. No consistent weighting is assigned to any one factor. Here are the issues that come up: 
´ Drafting helps, although there are no magic words and phrases that end the inquiry in all cases. Clear and unambiguous disclaimers (or affirmations) of binding effect will be very important and possibly dispositive, although they may not ultimately be controlling in all jurisdictions. Calling the document a ‘term sheet’, ‘agreement in principle’ or ‘letter of intent’ (rather than a ‘contract’) is unlikely to be dispositive in isolation, although cases differ. The degree of formality and use of contract terms and language is also of interest. 
´ A clear indication that the parties envisioned that a final definitive contract would be executed is accorded some weight as evidence of their intent not to be bound, although that is not conclusive. 
´ Inclusion of all essential terms of the transaction will not necessarily lead to a conclusion that the document is binding, absent other facts, and vice versa. Some courts will not enforce an agreement if it leaves essential terms open for future negotiations; other courts are willing to recognise that a term sheet need not have settled with utmost certainty all of the points and may supply the missing terms if the agreement is to be enforced. ´ Further corporate or regulatory approvals required in order to consummate the underlying transaction are relevant, although their presence may not automatically lead to the conclusion that the preliminary arrangements were not binding. 
´ The customs and practices of the specific parties and in their industries, as well as those applicable to the relevant types of deals. The courts often recognise that large complex deals cannot be done off the back of a napkin or even a ten-page term sheet, although they will not necessarily use that as a bar to enforcing the terms if the intent to be bound is otherwise determined. 
´ The sophistication of the parties. ´ What steps the parties took to perform the arrangements outlined in the preliminary agreement. Unilateral partial performance, in and of itself, is not sufficient to establish the binding nature of a preliminary agreement. ´ Contemporaneous conduct among the parties and members of the deal team. Gratuitous oral assurances (‘We have a deal!’), handshakes and/or hugs, joint publicity, co-ordination of business activities and the like may all be relevant, especially to a jury. 
´ Whether there are provisions that the parties intended to be legally binding that are clearly delineated from the nonbinding terms. ´ Whether the binding terms included a no-shop or an obligation to negotiate exclusively and/or in good faith and whether there are time limitations on those obligations (indicating that the parties intended to negotiate for some time more and part ways if there was no agreement). 
´ Some courts may also consider the impact of the statute of frauds, as well as review other traditional objections to contract formation and enforcement, such as lack of mutuality of obligations and consideration. 
Federal courts applying New York law have developed an influential framework for analysing the issue. The courts look at: (a) whether there was an express reservation of the right not to be bound; (b) whether there has been partial performance; (c) whether all of the terms of the agreement have been agreed upon; and (d) whether the agreement is usually the type that is committed to a more formal writing. Depending on where this exercise comes out, the parties could be found to have formed a fully binding contract (a so-called ‘Type I’ agreement) that is self-executing and enforceable. These courts noted that ‘there is a strong presumption against finding obligation in agreements which include open terms, call for future approvals and expressly anticipate future preparation and execution of contract documents’ (this presumption may be sufficient to lead to summary judgment for the defendant). 

IS THERE AN OBLIGATION TO WORK IN GOOD FAITH TOWARDS THE UNDERLYING DEAL? 
Finding a binding contract to do the underlying deal off the back of a term sheet is not an everyday occurrence. If there is not a binding contract, some more traditional courts will end the inquiry. Others may go on to try to give the preliminary document a more nuanced effect. Certain courts may infer or imply a duty to negotiate in good faith to reach the definitive contract. They can imply this duty on top of a generic exclusivity/no-shop provision or otherwise arrive at it on the basis of other weakly worded or ambiguous provisions, or imply it in face of total silence. 
Other courts will only enforce an explicit contractual undertaking to that effect, but decline to impose a duty to bargain in good faith in a term sheet that is otherwise silent. For example, using a modified version of the test described above developed by federal courts applying New York law, a court could find that the parties have agreed on some major terms and accepted a mutual commitment to negotiate together in good faith to reach final agreement based on the parameters laid out in the preliminary agreement (a so-called ‘Type II’ agreement). The test for the latter inquiry is slightly different – the courts would generally look at: (a) the language of the agreement; (b) the context of the negotiations; (c) the existence of open terms; (d) partial performance; and (e) the necessity of putting the agreement in final form. 
Other courts will not imply a good faith obligation in the absence of an otherwise binding contract. Where the preliminary agreement has expressly disclaimed such duties, courts have enforced it in certain cases and declined to imply a stand-alone duty of their own. The scope of good faith is largely a factual question. The courts will often look to the terms of the preliminary agreement to examine what the parties intended to be the parameters of their good faith obligations – the more specific the document is, the less room a party will have to introduce new demands. It is reasonably clear that the obligation permits some degree of commercial leeway – the obligation is less than Justice Cardozo’s ‘punctilio of an honor the most sensitive’ and does not require the parties playing their cards face up. But the question is typically one for the trier of facts. If the parties negotiate in good faith for a reasonable period of time and no agreement is reached, there should generally be no liability. 

REMEDIES 
If the term sheet is deemed to be a binding agreement with respect to the underlying transaction, then the losing party could be liable for full expectation or ‘benefit of the bargain’ damages. A court could also order specific performance of the contract. Suffice it to say that either of those outcomes would be severe (and rare). For breaches of an agreement (or duty) to negotiate in good faith towards a final contract in an otherwise non-binding document, recovery is typically limited to reliance damages such as out-of-pocket costs incurred in preparing to do the transaction. In such cases, the courts have cast doubt on the efficacy of ordering parties to negotiate in good faith.





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