Foreign LLC Unqualified in California Can Enforce Judgment Here

A California Court of Appeal this past week determined that a foreign LLC which is not qualified to transact business in California can nonetheless enforce a judgment obtained in another state in California. Conseco Marketing, LLC v. IFA and Ins. Services, Inc., 2013 Cal. App. LEXIS 946 (Cal. App. 2d Dist. Nov. 22, 2013).  Under both California's current LLC Act and the new one effective in 2014, neither maintaining or defending a lawsuit nor collecting a debt is by itself sufficient to constitute transaction intrastate business in California.