In Re ColossusBets Limited v. the State of Texas

ACCEPTED
15-25-00150-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
10/16/2025 3:18 PM
No. 15-25-00150-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
15th COURT OF APPEALS
15th Court of Appeals of Texas AUSTIN, TEXAS
__________________________________________________________________
10/16/2025 3:18:32 PM
CHRISTOPHER A. PRINE
Clerk
In Re ColossusBets Limited,
Relator.

REPLY IN SUPPORT OF
RELATOR’S PETITION FOR WRIT OF MANDAMUS
__________________________________________________________________
Original Proceeding from
Cause No. 25-BC03A-0007
Business Court of Texas
Third Division
Austin, Texas

PILLSBURY WINTHROP SHAW PITTMAN LLP

Derrick Carson (Texas Bar No. 24001847)
Charles Conrad (Texas Bar No. 24040721)
Jonathan Sink (Texas Bar No. 24099968)
Lindsey Mitchell (Texas Bar No. 24138645)
PILLSBURY WINTHROP SHAW PITTMAN LLP
609 Main Street, Suite 2000
Houston, Texas 77002
(713) 276-7600 (Telephone)
(713) 276-7673 (Facsimile)
Derrick.Carson@pillsburylaw.com
Charles.Conrad@pillsburylaw.com
Jonathan.Sink@pillsburylaw.com
Lindsey.Mitchell@pillsburylaw.com

Counsel for Relator ColossusBets Limited

ORAL ARGUMENT REQUESTED
TABLE OF CONTENTS

Page

INTRODUCTION .....................................................................................................1

ARGUMENT .............................................................................................................2

I. Reed’s Improper Request for Appellate Reconsideration of the
First Jurisdictional Decision Should Be Summarily Rejected. ..................2

II. Reed’s Avoidance of the Statutes and Rules Cited by Relator in
Favor of Looking to Case Law Concerning Entirely Different,
Jurisdictional Statutes Only Reinforces Relator’s Point. ...........................4

III. Mandamus is a Meaningful and Proper Remedy. ....................................11

PRAYER ..................................................................................................................13

CERTIFICATE OF SERVICE ................................................................................15

CERTIFICATE OF COMPLIANCE .......................................................................15

ii
INDEX OF AUTHORITIES

Page(s)

Cases

In re AutoZoners, LLC,
694 S.W.3d 219 (Tex. 2024) ..............................................................................11

County of Cameron v. Brown,
80 S.W.3d 549 (Tex. 2002)................................................................................... 7

Ditech Servicing, LLC v. Perez,
669 S.W.3d 188 (Tex. 2023) ................................................................................ 8

In re ETC Field Services, LLC,
707 S.W.3d 924 (Tex. App.—15th Dist. 2025)............................................12, 13

In re GlobalSanteFe Corp.,
275 S.W.3d 477 (Tex. 2008) ..............................................................................12

Isbell v. Kenyon-Warner Dredging Co.,
261 S.W. 762 (Tex. 1924)..................................................................................... 7

In re McAllen Medical Center, Inc.,
275 S.W.3d 458 (Tex. 2008) ........................................................................11, 12

Meekey v. Rick's Cabaret Intern., Inc.,
171 S.W.3d 394 (Tex. App.—Houston [14th Dist.] 2005, pet. denied)............... 8

Olds v. Olds,
No. 25CV000166-740, 2025 NCBC Order 57, 2025 NCBC LEXIS 102
(Aug. 13, 2025) .............................................................................................10, 11

In re Prudential Ins. Co. of Am.,
148 S.W.3d 124 (Tex. 2004) ..............................................................................12

Rusk State Hosp. v. Black,
392 S.W.3d 88 (Tex. 2012)................................................................................... 7

Tex. Ass’n of Bus. v. Tex. Air Control Bd.,
852 S.W.2d 440 (Tex. 1993) ................................................................................ 7

iii
Tex. Dep’t of Parks & Wildlife v. Miranda,
133 S.W.3d 217 (Tex. 2004) ............................................................................6, 7

Statutes and Codes

Texas Government Code
Section 25.006(d) .................................................................................................. 5
Section 25.0041(a) ..........................................................................................5, 10
Section 25A.006(d) .........................................................................................5, 10
Section 25A.0041(a) ............................................................................................. 5
Section 25A.0041(a)(3) ........................................................................................ 5

Tort Claims Act, 28 U.S.C. §§ 2671–2680........................................................4, 6, 7

Rules and Regulations

Texas Rules of Appellate Procedure
Rule 25.1(c)........................................................................................................... 3
Rule 25.1(d)(2)...................................................................................................... 3
Rule 26.1 ............................................................................................................... 3
Rule 28.3(c)........................................................................................................... 3
Rule 52.1 ............................................................................................................... 3
Rule 52.3(d)(3)...................................................................................................... 3
Rule 52.3(f) ........................................................................................................... 3
Rule 52.4(d) .......................................................................................................... 3

Texas Rules of Civil Procedure
Rule 355 ................................................................................................................ 8
Rule 355(f)(1) ................................................................................................. 6, 10

iv
INTRODUCTION

Real Party in Interest, Plaintiff Jerry B. Reed, submitted a Response to

Relator’s Petition for Writ of Mandamus that rings hollow. Not only does Reed fail

to adequately engage the applicable statute and procedural rules, which undisputedly

are supreme in evaluating how the Business Court’s jurisdiction works, but Reed

also attempts to seek appellate review of the Business Court’s original decision to

exercise jurisdiction. At no time, however, did Reed seek reconsideration of the

original jurisdictional decision or file his own mandamus petition. Rather, and only

now in fear of the merits of Relator’s one-way jurisdiction argument, does Reed seek

untimely and procedurally improper reconsideration of a months-old trial court

decision, all in the context of Relator’s Petition, not Reed’s own petition. Such an

attempt should be summarily rejected for this reason alone. Regardless, the merits

of the Business Court’s first decision are plainly shown in that court’s thorough

opinion on the matter.

As for the merits here,1 Reed barely grapples with the text and structure of the

applicable jurisdictional statute and rules. Instead, he calls upon generic case law

interpreting other statutes and provisions with entirely different language and

purpose. Accordingly, Reed’s arguments serve only to reinforce Relator’s position

1
To avoid doubt, Relator reiterates that this proceeding is subject to Relator’s Special Appearance and it in no way
waives, through its Petition or this reply, its challenge to personal jurisdiction. See Pet. at 16.
that Chapter 25A’s text and structure establish a one-way door to the Business Court

that should be determined “promptly” and “finally” at the time of removal.

ARGUMENT

I. Reed’s Improper Request for Appellate Reconsideration of the First
Jurisdictional Decision Should Be Summarily Rejected.

In his Response, Reed tries to insert an additional “issue presented”: “Did the

Business Court possess subject-matter jurisdiction over this case at any point?”

Resp. at 1. In this, Reed refers to the Business Court’s First Decision2 regarding

jurisdiction and proceeds to spend more than seven pages criticizing it. See Resp. at

9–17.

A response to a Petition for Writ of Mandamus, however, is not the proper

vehicle to seek appellate review of an entirely separate, unchallenged order. If Reed

wanted to raise that order/issue, he should have done so promptly after the Business

Court’s original decision to exercise jurisdiction. But he didn’t. He never moved for

reconsideration. He never petitioned for permissive appeal. He never filed his own

mandamus petition. And he never noticed the matter for traditional interlocutory

appeal. Instead, he amended his petition—twice—and then filed a new Motion to

Remand, 3 specifically relying on the changes in his new pleading. See MR 293

2
“First Decision” is a reference to the Business Court’s June 18, 2025, order and opinion denying Reed’s Motion to
Remand.
3
Although Reed titled the motion a “Renewed” motion, it was in reality an independent and “new” motion based on
a different pleading. Indeed, this situation itself serves as “Exhibit A” for how the one-way jurisdiction approach will
practically protect parties from pleading gamesmanship.

2
(expressly “disclaim[ing] any allegation, legal theory, or request for relief that

requires th[e] [Business] Court to interpret or enforce the governance, internal

affairs, or governing documents of any Defendant entity.”).

As set forth in the Texas Rules of Appellate Procedure, “[a] party who seeks

to alter the trial court’s judgment or other appealable order must file a notice of

appeal” that identifies “the date of the judgment or order appealed from.” TEX. R.

APP. P. 25.1(c), (d)(2). Moreover, the party must do so “within 30 days after the

judgment is signed,” TEX. R. APP. P. 26.1, or within 15 days if it is a petition for

permissive appeal, TEX. R. APP. P. 28.3(c). If a party instead seeks mandamus relief,

it must do so “by filing a petition with the clerk of the appropriate appellate court”

and be captioned in the name of the petitioner, who is the “relator.” T EX. R. APP. P.

52.1. In such a petition, the relator must identify the “action” from which relief is

sought and the “Issues Presented.” TEX. R. APP. P. 52.3(d)(3), (f).

Most critically, the Rules of Appellate Procedure specifically limit the content

of any response to a mandamus petition as follows: “the argument must be confined

to the issues or points presented in the petition.” TEX. R. APP. P. 52.4(d) (emphasis

added).

Reed ignored all these rules and procedures. His attempt to now seek review

of the First Decision violates multiple layers of procedure and should outright be

rejected. To the extent the Court may still be interested in reviewing the Business

3
Court’s First Decision, Relator points the Court to the well-reasoned opinion of

Judge Andrews, which more than adequately addresses the matters raised by Reed

in this part of his argument.

II. Reed’s Avoidance of the Statutes and Rules Cited by Relator in Favor of
Looking to Case Law Concerning Entirely Different, Jurisdictional
Statutes Only Reinforces Relator’s Point.

Reed’s arguments with respect to the text and structure of Chapter 25A are

lacking. They are conclusory in that they fail to meet the various textual supports for

the meaning argued by Relator, and they entirely fail to address the implementing

rules promulgated by the Supreme Court of Texas that lend further support to the

meaning of Chapter 25A. Reed instead relies on a handful of cases that interpret and

apply jurisdictional statutes in the Tort Claims Act concerning sovereign immunity,

or other statutes that have nothing to do with or to say about how jurisdiction works

in the Business Court.

A few times in his Response, Reed suggests that Relator’s interpretation

“finds no support” in the text of Chapter 25A without explaining why. For example,

Reed baldly asserts that “[n]othing in Chapter 25A suggests the Legislature intended

to create [one-way jurisdiction],” but then fails to engage the multiple sources of

text, structure, and rules identified by Relator that show this is precisely what the

Legislature intended. Resp. at 27.

4
For example, Reed does not even once cite, much less analyze, § 25A.0041(a),

which contains an express instruction by the Texas Legislature that rules and

procedures be established “for the prompt, efficient, and final determination of

business court jurisdiction on the filing of an action in the business court.” Pet. at

24. There is simply no other reasonable reading of the word “final” other than the

Legislature intended the jurisdictional determination to be made once and for all by

the trial court. And that statute directly identifies the timing of when this “final”

determination should be made—“on the filing of an action,”—which necessarily

refers to either the case’s initial filing or its removal. Reed offers no alternative

meaning to § 25.0041(a) and how it impacts the reading of § 25.006(d).

Reed’s omission speaks volumes. Although Reed acknowledges the phrase

“shall remand the case” in § 25A.006(d), he does not address it in context the way

the Texas Supreme Court authorities require. See Pet. at 23–24 (collecting cases

instructing courts to interpret statutes “in context,” meaning “the surrounding words

and structure” and the “framework” of the statute within its chapter). Instead, Reed

plucks out and isolates the phrase “shall remand the case,” then simply asserts that

this phrase means “the Legislature expected the court to remand whenever it lacks

jurisdiction, not just at removal.” Resp. at 28.

Reed also fails to address § 25A.0041(a)(3), which contains another

instruction from the Texas Legislature that the rules and procedures take into

5
consideration the “limited potential” for movement of an action between the district

court and the Business Court. Pet. at 24.

Most striking, perhaps, is Reed’s failure to engage with Rule 355(f)(1) of the

Texas Rules of Civil Procedure. It expressly states, in specific words chosen by the

rule-making authority (which has the same force as a legislative statute), that the

Business Court must remand only if it determines “that removal was improper.” Pet.

at 25–26. Reed has no response to this.

Instead of addressing these plain evidences of meaning, Reed simply repeats

his conclusion over and over4 as if repetition were argument. See, e.g., Resp. at 19

(Business Court jurisdiction “depends on the continued presence of qualifying

allegations in the live pleadings.”); id. (“Texas law is clear….”). But merely

declaring a position to be “clear” does not make it so.

The only authorities Reed cites to support his position that jurisdiction should

be continually revisited are various cases that interpret entirely different

jurisdictional statutes in wholly different contexts. For example, Tex. Dep’t of Parks

& Wildlife v. Miranda addressed whether sovereign immunity could be waived

under the recreational use statute for purposes of allowing jurisdiction over claims

against a state sovereign under the Tort Claims Act. 133 S.W.3d 217 (Tex. 2004).

4
E.g., Resp. at 17 (“Texas law is clear that subject-matter jurisdiction is determined from the live pleadings.”); 18
(“Nothing in the statute freezes jurisdiction at the moment of removal….”).

6
The Tort Claims Act provides a mechanism for the state to file a plea to the

jurisdiction where there is insufficient evidence of waiver of immunity (i.e., gross

negligence). Id. at 224–25. Such a plea necessarily comes after discovery and other

advancements in a case, along with changes to the pleadings based on those

developments, and thus warrants revisiting jurisdiction specifically in accordance

with that statutory mechanism. See id. at 221–22. Miranda’s discussion of these

principles and issues has no application to the specific jurisdictional scheme in

Chapter 25A.

The same is true of Rusk State Hosp. v. Black, 392 S.W.3d 88 (Tex. 2012)

(another case involving sovereign immunity and the Tort Claims Act), County of

Cameron v. Brown, 80 S.W.3d 549 (Tex. 2002) (same), and Tex. Ass’n of Bus. v.

Tex. Air Control Bd., 852 S.W.2d 440 (Tex. 1993) (considering whether party had

constitutional standing given separation of powers doctrine).5 Indeed, the analysis

in these cases addressing the importance of live pleadings relates to ensuring the

plaintiffs had a chance to plead appropriately such that their claims could be heard

at all on the merits (rather than dismissed with prejudice). Those are different issues

and concerns than determining which of multiple courts can hear a case given a

specific statutory scheme.

5
Another of Reed’s cases, Isbell v. Kenyon-Warner Dredging Co., 261 S.W. 762 (Tex. 1924), actually supports
Relator here because the holding was that the County Court retained jurisdiction even though later developments and
amendments increased the damages beyond the jurisdictional limit. Reed appears to have just quoted certain language
from the case out of context rather than notice its relevance to the outcome.

7
Whatever jurisdictional rules Reed might glean from these cases, those rules

have nothing to say about the meaning of Chapter 25A. Indeed, the fact that Chapter

25A and Rule 355 specifically contain the language they do, and not the language of

those other statutory schemes, only lends further weight to Relator’s position.

Accordingly, it is not Relator who has made the Business Court “unique

among Texas Courts,” Resp. at 27, it is the Texas Legislature who has done so via

the specific words it selected. While Texas’s district courts are courts of general

jurisdiction, deriving their powers and jurisdiction from the Texas Constitution and

common law, the Business Court, in contrast, is a “creature of the legislature.” See

generally Meekey v. Rick’s Cabaret Int’l, Inc., 171 S.W.3d 394, 397 (Tex. App.—

Houston [14th Dist.] 2005, pet. denied) (drawing distinction between constitutional

county courts and county courts at law). Like administrative agencies and other

“creature[s] of the legislature,” the Business Court can exercise only “those powers

conferred by statute.” Id.; e.g., Ditech Servicing, LLC v. Perez, 669 S.W.3d 188,

190–91 (Tex. 2023) (Texas Supreme Court demonstrating analysis of the relevant

statute is supreme in deciding jurisdiction). Accordingly, whether and when the

Business Court has the power to remand a case “depends on statutory interpretation,”

not general principles of Constitutional court jurisdiction. Meekey, 171 S.W.3d at

398; see also Resp. at 29–30 (Reed agreeing that “enactments of the Legislature” are

controlling). All this to say, whether the Business Court is “unique” or not, its

8
jurisdiction is governed by the Texas Legislature’s chosen language, not by

generalized sentiments about jurisdiction or quotes from cases applying entirely

different jurisdictional statutory frameworks.

Moving beyond the statutory language, Reed misunderstands Relator’s

arguments about “policy concerns.” See Resp. at 26. As detailed in the Petition,

Relator raised concerns that if the Business Court’s jurisdiction can constantly be

revisited after every amended petition, then parties can game the system to escape

the Business Court whenever they deem it to be an unfavorable forum. Pet. at 33–

34. This creates obvious problems. No doubt, such concerns “cannot override” the

law regarding jurisdiction. See Resp. at 26. And they don’t here. Rather, such

concerns serve only to reinforce the law. As articulated above, the text and structure

of Chapter 25A, as well as the implementing procedural rules, all reflect an intent

and meaning that establishes a one-way jurisdictional door.

And so, it is actually Reed who asks this Court to ignore the text and structure

in favor of “policy concerns” when he decries “[i]f allowed to stand, the Business

Court’s [First Decision] would enable defendants to bootstrap entire cases into the

Business Court.” Resp. at 15. To be sure, gamesmanship can cut either way

depending on the outcome of how Chapter 25A is interpreted here. If Reed’s view

prevails, plaintiffs could artfully plead their way into a remand after being

disappointed with a proper removal. Or, if Relator’s view is adopted, certain

9
defendants might find a way to technically remove a case when it meets the statutory

requirements even if a plaintiff would have preferred not to be in Business Court.

No rule is perfect. These policy concerns, however, do not control. Instead, the

statute does. And the statutory scheme expressly says that the Business Court’s

jurisdiction should be determined in a “prompt” and “final” review “on the filing [or

removal] of an action in business court.” TEX. GOV’T CODE § 25.0041(a). The

Business Court “shall remand,” § 25A.006(d), only if it determines “that removal is

improper.” TEX. R. CIV. P. 355(f)(1) (emphasis added).

With respect to the comparison to the North Carolina Business Court, Relator

offered that comparison merely to demonstrate that a one-way door to jurisdiction is

not anathema to a business court model or structure. While North Carolina

establishes its Business Court as an administrative division that hears “designated”

cases, functionally, it operates the same way as Texas’s Business Court. Both courts

are “creatures of statute” that hear only certain types of cases (containing very

similar lists of subject matters) while leaving the general remainder of cases to be

heard in Constitutional superior or district courts. Also, both schemes provide a

specific judge to preside over the entire action who is required to issue written

opinions. Accordingly, the practical concerns articulated in Olds as to why a

revolving door approach to jurisdiction is problematic (i.e., permits

“gamesmanship” that “divests the Court of its authority”) are no less persuasive in

10
Texas, especially given that (again), such concerns reinforce the intention and

meaning of Chapter 25A. Olds v. Olds, No. 25CV000166-740, 2025 NCBC Order

57, 2025 NCBC LEXIS 102, ¶12 (Aug. 13, 2025).

III. Mandamus is a Meaningful and Proper Remedy.

Regarding the propriety of mandamus relief, Reed does not dispute that if the

Business Court’s decision was incorrect on the law (i.e., jurisdiction/remand), it

constitutes an abuse of discretion. Reed instead puts all his eggs in the “adequate

remedy” basket. See In re AutoZoners, LLC, 694 S.W.3d 219, 223 (Tex. 2024)

(“Mandamus relief is available if the relator establishes a clear abuse of discretion

for which there is no adequate appellate remedy.”). But here, Reed is plainly wrong,

as has already been articulated by the Texas Supreme Court.

“The most frequent use we have made of mandamus relief involves cases in

which the very act of proceeding to trial—regardless of the outcome—would defeat

the substantive right involved.” In re McAllen Medical Center, Inc., 275 S.W.3d 458,

465 (Tex. 2008). As such, traditional appeal is not an adequate remedy “when it will

mean … forcing parties to trial in a case they agreed to arbitrate; forcing parties to

trial on an issue they agreed to submit to appraisers; forcing parties to a jury trial

when they agreed to a bench trial; [or] forcing parties to trial in a forum other than

the one they contractually selected….” Id. No different from all these scenarios is

the situation here—forcing a party to trial in a court other than the one to which it is

11
statutorily entitled. Indeed, this Court has already indicated that “[r]emoval of

qualifying cases to the business court is a statutory right that must be respected….”

ETC Field Services, LLC, 707 S.W.3d 924, 928 (Tex. App.—15th Dist. 2025). And

this “procedural right” is necessarily “impaired” or lost if a party is forced to proceed

in district court. See In re GlobalSanteFe Corp., 275 S.W.3d 477, 483 (Tex. 2008)

(articulating factors involved in balancing test).

In addition, and directly contrary to Reed’s argument, see Resp. at 33

(suggesting “expense and inconvenience” do not matter), courts should consider

whether mandamus relief will “spare private parties and the public the time and

money utterly wasted enduring eventual reversal of improperly conducted

proceedings.” In re Prudential Ins. Co. of Am., 148 S.W.3d 124, 136 (Tex. 2004).

Relevant here, “if the first trial is conducted in the wrong time, place, or manner,”

then a case has to be tried “twice.” McAllen Medical Cntr., 275 S.W.3d at 466.

“[I]nsisting on a wasted trial simply so that it can be reversed and tried all over again

creates the appearance not that the courts are doing justice, but that they don’t know

what they are doing.” Id. As such, “[p]rudent mandamus relief” is not only

appropriate, but “also preferable to legislative enlargement of interlocutory appeals.”

Prudential, 148 S.W.3d at 137.

Moreover, and yet again contrary to Reed’s argument, see Resp. at 34, this

Court has specifically stated that “[m]andamus review of significant rulings in

12
exceptional cases would allow this Court ‘to give needed and helpful direction to the

law that would otherwise prove elusive.”’ ETC Field Services, 707 S.W.3d at 929.

The nature and importance of the jurisdictional question presented here only further

amplifies the necessity of mandamus review.

PRAYER

For these reasons, and those articulated in its Petition, Relator ColossusBets

Limited prays this Court grant a writ of mandamus and direct Respondent to (1)

vacate its August 25, 2025, order remanding the Lawsuit to the District Court, (2)

reinstate its administrative and scheduling orders, and (3) exercise jurisdiction over,

and proceed with, the Lawsuit in the Texas Business Court.

Relator also requests any further relief to which it may be justly entitled.

13
Dated: October 16, 2025

Respectfully submitted,

PILLSBURY WINTHROP SHAW PITTMAN LLP

/S/ Derrick Carson
Derrick Carson (Texas Bar No. 24001847)
(Lead Counsel)
Charles Conrad (Texas Bar No. 24040721)
Jonathan Sink (Texas Bar No. 24099968)
Lindsey Mitchell (Texas Bar No. 24138645)
PILLSBURY WINTHROP SHAW PITTMAN LLP
609 Main Street, Suite 2000
Houston, Texas 77002
(713) 276-7600 (Telephone)
(713) 276-7673 (Facsimile)
Derrick.Carson@pillsburylaw.com
Charles.Conrad@pillsburylaw.com
Jonathan.Sink@pillsburylaw.com
Lindsey.Mitchell@pillsburylaw.com

Counsel for Relator ColossusBets Limited

14
CERTIFICATE OF SERVICE

I certify that on October 16, 2025, a true and correct copy of the foregoing

document was served via electronic transmission on counsel of record.

/s/ Derrick Carson
Derrick Carson

CERTIFICATE OF COMPLIANCE

This brief complies with the length limitations of TEX. R. APP. P. 9.4(i)(2)(C)

because this brief consists of 3,129 words, excluding the parts of the brief exempted

by TEX. R. APP. P. 9.4(i)(1).

/s/ Derrick Carson
Derrick Carson

15
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andrea.caswell@pillsburylaw.com
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