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Mark Billion is an insightful, focused and sophisticated litigator. I would definitely recommend him as an attorney.

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Mark not only has a brilliant legal mind, but he's an absolute pleasure to work with. He's thoughtful, creative, empathetic, and always provides timely responses. If you're looking for top-notch counsel, Mark has my full recommendation.

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Case Studies

November 30, 2024

Billion Law Remembers Walter K. Stapleton

A Brilliant Jurist Whose Presence Will Be Missed
October 8, 2024

Billion Law Breaks New Ground Post-Mallory

Middle District of Tennessee Clarifies Limits of the Mallory Decision
June 1, 2024

Billion Law Successfully Recovers Client Funds in Complex Multi-State Litigation

Navigating Legal and Strategic Challenges Across Multiple Jurisdictions to Secure Client’s Financial Recovery
September 1, 2023

Billion Law Secures Major Distribution for Client in In Re Kalos Bankruptcy Case

Effective Mediation Strategy Leads to One of the Largest Creditor Payouts in Complex Bankruptcy Matter

News & Updates

April 7, 2025

Billion Law Selected as Restructuring Counsel for Kina Lane Enterprises

March 21, 2025

Billion Law Files Chapter 7 Petition for Kiromic BioPharma, Inc.

March 13, 2025

Billion Law Tapped to Represent JAL Equity Corp. in the District of Delaware

January 3, 2025

Billion Law Tapped to Represent Ready Maker (Gibraltar) Limited in the Delaware Chancery Court

December 26, 2024

Billion Law Selected to Represent United Policyholders in the Delaware Supreme Court

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Get in Touch

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Billion Law Breaks New Ground Post-Mallory

Billion Law, representing Alliance Global Solutions, LLC, secured a favorable ruling in Dozier v. Alliance Global Solutions, LLC, 24-cv-348 (M.D. Tenn.), before the Middle District of Tennessee. The case involved the application of Mallory v. Norfolk Southern Railway Co. to Tennessee’s statute requiring out-of-state corporations to register with the Secretary of State.

The plaintiff argued that the Tennessee corporate registration statute conferred personal jurisdiction over the defendant under the Mallory decision. However, the Court declined to make an Erie guess regarding whether the Tennessee statute provided such jurisdiction. Instead, the Court ruled that personal jurisdiction could only be established if (i) the statute explicitly conferred jurisdiction or (ii) state courts had previously determined that the registration regime conferred Mallory jurisdiction. In its decision, the Court noted, "The absence of such decision is dispositive in and of itself."

Billion Law was assisted by Tennessee counsel from Riley & Jacobson, including Katharine Klein and James Bowen. This ruling provides clarity on the limitations of corporate registration statutes in Tennessee, particularly in the context of personal jurisdiction claims under Mallory. The decision marks an important interpretation of the jurisdictional reach of Tennessee's statutory framework for out-of-state corporations.