The Third Circuit Court of Appeals recently cited Professor S.I. Strong’s article, Congress and Commercial Trusts: Dealing With Diversity Jurisdiction Post-Americold, 69 Florida Law Review 1021 (2017), in its decision in GBForefront, L.P. v. Forefront Management Group, LLP, 888 F.3d 29 (3rd Circ. 2018). The case (and Professor Strong’s article) considered the distinction between business trusts and traditional trusts and how that distinction affects diversity jurisdiction in the wake of the U.S. Supreme Court decision in Americold Realty Trust. v. ConAgra Foods, Inc., 136 S. Ct. 1012 (2016).