The Delaware Court of Chancery in HUMC Holdco, et al. v. MPT of Hoboken TRS, LLC, et al., C.A. No. 2019-0972-KSJM, memo. op. (Del. Ch. July 2, 2020), concludes that the scope of a right of first refusal, unless expressly expanded, is limited to the subject matter of the agreement in which it is created.

Morris James discusses the decision in Chancery Interprets Right of First Refusal Provision in LLC Agreement.