South Dakota Code § 47-14A-73

Qualifications of plaintiff in derivative action
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In a derivative action, the plaintiff must be a beneficial owner at the time of bringing the action and:
(1) At the time of the transaction of which the plaintiff complains; or
(2) Plaintiff's status as a beneficial owner had devolved upon plaintiff by operation of law or pursuant to the terms of the governing instrument of the business trust from a person who was a beneficial owner at the time of the transaction.

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