Case Explained: KNOCKOUT HOLDINGS, LLC, f/k/a Octo Platform Equity Holdings, LLC Plaintiff – v. ARVINDER KAKAR Defendant –

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-29 The Fourth Circuit affirmed the district court’s summary judgment in favor of defendant Arvinder Kakar on plaintiff Knockout Holdings’ defamation and declaratory judgment claims. The court first addressed a jurisdictional issue raised during oral argument, remanding the case to determine if complete diversity of citizenship existed under 28 U.S.C. § 1332 at the time the complaint was filed. Upon receiving the district court’s ruling that diversity existed because Kakar and a former member were Maryland citizens while no Knockout members were, the appellate court reviewed this finding for clear error and legal conclusion de novo, ultimately agreeing that complete diversity was present and affirming the jurisdictional ruling. Regarding the merits, the court applied a de novo standard of review to the summary judgment award, evaluating whether there was a genuine dispute of material fact and if the moving party was entitled to judgment as a matter of law. The court rejected Knockout’s argument that Kakar’s statements to an IBM employee were defamatory, holding that the statements were protected opinions under the First Amendment because they expressed Kakar’s subjective views regarding ongoing state litigation and his business relationship with Knockout, rather than asserting verifiable facts. Additionally, the court reviewed the district court’s refusal to grant declaratory relief for abuse of discretion, concluding that no reversible error occurred because the underlying defamation claims were not actionable, thereby eliminating the controversy of sufficient immediacy required under the Declaratory Judgment Act. As a practical consequence, the judgment in favor of Kakar stands, Knockout Holdings’ appeal is dismissed, and the case is closed with no further proceedings in federal court. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.