Under the link below, the Pepper Hamilton law firm discusses a very recent decision of the Delaware Court of Chancery addressing the potential fiduciary liability of persons who are not parties to an LLC operating agreement (in this case, it was an investor) to the parties to the agreement.  Here’s the link:

https://www.pepperlaw.com/publications/delaware-chancery-court-sustains-breach-of-fiduciary-duty-claims-against-nonparty-to-llc-agreement-2020-05-26/