TrueCoin LLC v Techteryx, Ltd: Anti-Suit Injunction & Arbitration Agreement Dispute

In TrueCoin LLC v Techteryx, Ltd, the General Division of the High Court of Singapore granted an anti-suit injunction in favor of TrueCoin, restraining Techteryx from pursuing a court action in Hong Kong. The court found that Techteryx's claims were prima facie within the scope of arbitration agreements between the parties and that there were no strong reasons to deny the injunction. The case involved a breach of contract claim and a dispute over the validity and scope of arbitration agreements in the context of digital currency products and related services. The court's decision was delivered by Justice Andre Maniam on 29 November 2024.

1. Case Overview

1.1 Court

General Division of the High Court of the Republic of Singapore

1.2 Outcome

Anti-suit injunction granted restraining Techteryx from continuing to pursue the Hong Kong action against TrueCoin.

1.3 Case Type

Civil

1.4 Judgment Type

Grounds of Decision

1.5 Jurisdiction

Singapore

1.6 Description

Singapore court granted TrueCoin an anti-suit injunction, restraining Techteryx from pursuing a Hong Kong court action due to a breach of their arbitration agreement.

1.7 Decision Date

28 November 2024

2. Parties and Outcomes

Party Name	Role	Type	Outcome	Outcome Type	Counsels
Techteryx Ltd	Respondent	Corporation	Application dismissed	Lost	Foo Yiew Min of Tan Kok Quan Partnership Tnee Zixian Keith of Zheng Zixian Tyronne Toh Jia-En of Tan Kok Quan Partnership
TrueCoin LLC	Applicant	Corporation	Anti-suit injunction granted	Won	Lim Jingzhen Jerrick of WongPartnership LLP G Kiran of WongPartnership LLP Leo Zhen Wei Lionel of WongPartnership LLP Li Yiling Eden of WongPartnership LLP

3. Judges

Judge Name	Title	Delivered Judgment
Andre Maniam	Judge	Yes

4. Counsels

Counsel Name	Organization
Foo Yiew Min	Tan Kok Quan Partnership
Tnee Zixian Keith	Zheng Zixian
Tyronne Toh Jia-En	Tan Kok Quan Partnership
Lim Jingzhen Jerrick	WongPartnership LLP
G Kiran	WongPartnership LLP
Leo Zhen Wei Lionel	WongPartnership LLP
Li Yiling Eden	WongPartnership LLP

4. Facts

TrueCoin and Techteryx entered into a Strategic Alliance Agreement and a Master Services Agreement on 2 December 2020.
The SAA and MSA contained clauses providing for arbitration in Singapore under SIAC rules.
TrueCoin commenced two SIAC arbitrations against Techteryx on 17 November 2023, claiming payments under the SAA and MSA.
Techteryx commenced a Hong Kong action against TrueCoin on 24 November 2023, seeking to be relieved of its payment obligations under the SAA and MSA.
The Hong Kong action included claims against Legacy Trust, Crossbridge Capital Asia Pte Ltd, Aria Commodity Finance Fund, and Mr. Alex de Lorraine.
TrueCoin applied for an anti-suit injunction to restrain Techteryx from pursuing the Hong Kong action against it.

5. Formal Citations

TrueCoin LLC v Techteryx, Ltd, Originating Action No 364 of 2024, [2024] SGHC 296

6. Timeline

Date	Event
2020-12-02	TrueCoin and Techteryx entered into a Strategic Alliance Agreement and a Master Services Agreement.
2021-01-20	Closing of the transaction between TrueCoin and Techteryx took place.
2021-04-01	Techteryx and TrueCoin issued a joint written instruction to Legacy Trust Company Limited.
2023-11-17	TrueCoin commenced two SIAC arbitrations against Techteryx.
2023-11-24	Techteryx commenced the Hong Kong action.
2024-01-02	Techteryx amended the writ to add Crossbridge Capital Asia Pte Ltd and Aria Commodity Finance Fund as defendants.
2024-02-06	Techteryx amended the writ again to add TrueCoin and Mr. Alex de Lorraine as defendants.
2024-04-17	TrueCoin applied for an anti-suit injunction.
2024-08-14	Hearing proceeded on a “with notice” basis and the ASI was granted.
2024-11-29	Andre Maniam J issued the grounds of decision.

7. Legal Issues

Breach of Arbitration Agreement
- Outcome: The court held that Techteryx's claims against TrueCoin in the Hong Kong action were prima facie in breach of the arbitration agreements between them.
- Category: Substantive
- Sub-Issues:
  - Supersession of arbitration agreement by subsequent jurisdiction clause
  - Scope and ambit of arbitration agreement
- Related Cases:
  - [2019] 1 SLR 732
  - [2024] 2 SLR 279
  - [2024] SGCA 50
Anti-Suit Injunction
- Outcome: The court granted the anti-suit injunction, restraining Techteryx from continuing to pursue the Hong Kong action against TrueCoin.
- Category: Procedural
- Sub-Issues:
  - Grounds for granting an anti-suit injunction
  - Comity considerations in granting an anti-suit injunction
  - Forum fragmentation
- Related Cases:
  - [2018] SGHC 56
  - [2019] 1 SLR 732
  - [2023] 1 SLR 349

8. Remedies Sought

Anti-Suit Injunction
Termination or rescission of the SAA and the MSA
Damages

9. Cause of Actions

Breach of Contract
Misrepresentation

10. Practice Areas

Arbitration
Commercial Litigation
Injunctions

11. Industries

Finance
Technology

12. Cited Cases

Case Name	Court	Affirmed	Citation	Jurisdiction	Significance
Hilton International Manage (Maldives) Pvt Ltd v Sun Travels & Tours Pvt Ltd	High Court	Yes	[2018] SGHC 56	Singapore	Cited for the principle that the court may grant an anti-suit injunction to restrain foreign court proceedings.
COSCO Shipping Specialized Carriers Co, Ltd v PT OKI Pulp & Paper Mills and others and another matter	Court of Appeal	Yes	[2024] SGCA 50	Singapore	Cited for the principle that the court may grant an anti-suit injunction to restrain foreign court proceedings.
Sun Travels & Tours Pvt Ltd v Hilton International Manage (Maldives) Pvt Ltd	Court of Appeal	Yes	[2019] 1 SLR 732	Singapore	Cited for the general principles governing the grant of anti-suit injunctions, including breach of agreement as a basis for granting such injunctions.
Asiana Airlines, Inc v Gate Gourmet Korea Co, Ltd and others	High Court	Yes	[2024] 2 SLR 279	Singapore	Cited for the applicable standard of whether there is prima facie a breach of the arbitration agreement when considering the grant of an anti-suit injunction.
Hai Jiang 1401 Pte Ltd v Singapore Technologies Marine Ltd	High Court	Yes	[2020] 4 SLR 1014	Singapore	Cited for the principle that the prima facie standard is to be applied when considering an anti-suit injunction, similar to stay applications under s 6 of the International Arbitration Act 1994.
Tomolugen Holdings Ltd and another v Silica Investors Ltd and other appeals	High Court	Yes	[2016] 1 SLR 373	Singapore	Cited for the test applicable in stay applications under s 6 of the International Arbitration Act 1994.
Aggeliki Charis Compania Maritima S.A. v Pagnan S.p.A (The “Angelic Grace”)	English Court	Yes	[1995] 1 Lloyd’s Rep 87	England	Cited for the principle that it would be patronizing to defer an application for an injunction until something goes wrong in the foreign court.
Anupam Mittal v Westbridge Ventures II Investment Holdings	Court of Appeal	Yes	[2023] 1 SLR 349	Singapore	Cited as an authority against the argument that supervisory jurisdiction is subordinate to a foreign court’s primary jurisdiction.
Attorney-General v Au Wai Pang	High Court	Yes	[2015] 2 SLR 352	Singapore	Cited for the principle that it is not open to a court to decline to follow the decision of a superior appellate court on the basis that the appellate court decided per incuriam.
Westbridge Ventures II Investment Holdings v Anupam Mittal	High Court	Yes	[2021] SGHC 244	Singapore	Cited for the principle that on the question of construction of the arbitration agreement, the court proceeded on the basis that the approach was the same, whether under Singapore or Indian law.
Ollech David v Horizon Capital Fund	High Court	Yes	[2024] 1 SLR 287	Singapore	Cited for the principle that if a party wishes to contend that foreign law is relevant and different from local law, he needs to assert and prove what the content of that foreign law is.
EFT Holdings, Inc and another v Marinteknik Shipbuilders (S) Pte Ltd and another	High Court	Yes	[2014] 1 SLR 860	Singapore	Cited for the principle that if a party wishes to contend that foreign law is relevant and different from local law, he needs to assert and prove what the content of that foreign law is.
CSY v CSZ	Court of Appeal	Yes	[2022] 2 SLR 622	Singapore	Cited for the principle that the fact of a multiplicity of proceedings arising from related actions is not in itself a sufficient reason to refuse a discretionary stay of court proceedings in favour of arbitration.
Maybank Kim Eng Securities Pte Ltd v Lim Keng Yong and another	High Court	Yes	[2016] 3 SLR 431	Singapore	Cited for the principle that by putting in place different dispute resolution agreements, there would necessarily be a multiplicity of proceedings if claims were brought by the appellant against the appellant’s client and the appellant’s remisier in respect of the same loss.
Donohue v Armco Inc and others	House of Lords	Yes	[2002] 1 All ER 749	England	Cited for the principle that the English court may well decline to grant an injunction or a stay where the interests of parties other than the parties bound by the exclusive jurisdiction clause are involved or grounds of claim not the subject of the clause are part of the relevant dispute so that there is a risk of parallel proceedings and inconsistent decisions.
Chimbusco International Petroleum (Singapore) Pte Ltd v Fully Best Trading Ltd	Hong Kong Court of First Instance	Yes	[2016] 1 HKLRD 582	Hong Kong	Cited for the principle that Hong Kong has a duty to comply with its duties under art.II of the New York Convention: to recognise and enforce an arbitration agreement and to stay actions before the court in breach of a valid and subsisting arbitration agreement.
Rals International Pte Ltd v Cassa di Risparmio di Parma e Piacenza SpA	Court of Appeal	Yes	[2016] 5 SLR 455	Singapore	Cited for the principle that the presumption mentioned by Lord Hoffmann in Fiona Trust is not intended to apply irrespective of the context in which the underlying agreement was entered into or the plain wording of the agreement.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute Name	Jurisdiction
Supreme Court of Judicature Act 1969	Singapore
International Arbitration Act 1994	Singapore

15. Key Terms and Keywords

15.1 Key Terms

Anti-suit injunction
Arbitration agreement
Strategic Alliance Agreement
Master Services Agreement
Joint Written Instruction
SIAC arbitration
Hong Kong action
Prima facie breach
Forum fragmentation
Comity

15.2 Keywords

Anti-suit injunction
Arbitration
Singapore
Hong Kong
Contract
Breach
International Arbitration

17. Areas of Law

Area Name	Relevance Score
Anti-suit injunction	95
Restraint of foreign proceedings	95
Arbitration	90
Jurisdiction	60
Breach of Contract	50
Contractual terms	40
Misrepresentation	30
Commercial Disputes	30

16. Subjects

Arbitration
Injunctions
Contract Law
International Law