The Third Circuit dove into the law of escheat and Delaware’s Unclaimed Property Law. Siemens filed suit after Delaware attempted to take unclaimed property that Siemens possessed but did not own or have contact with the property’s owner. Siemens sought a preliminary injunction in addition to declarations that the State’s actions violated Siemens’s procedural due process rights and that federal common law preempted the Unclaimed Property Law. The District Court denied the motion to enjoin the audit and dismissed all but one count in the complaint. In large part, the matter revolved around a group of cases now called the “Texas trilogy” that govern the escheat of non-tangible property where multiple states may have a legitimate claim to the property. Initially, the Texas trilogy requires courts to determine the precise debtor-creditor relationship as defined by the law that creates the property. Given Delaware’s outsized role in American corporate law, the state has taken advantage of the Texas trilogy framework. The Third Circuit vacated the District Court’s order that dismissed Siemens’s preemption claim and denied Siemens’s motion for a preliminary injunction.