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In ConocoPhillips Co. v. Hahn,1 the Supreme Court of Texas addressed whether a “fixed” nonparticipating royalty interest (“NPRI”) was later converted to a “floating” NPRI.2 The court weighed two possible means of this conversion: (i) a lease ratification; and (ii) a stipulation of interest. The Hahn court holds that a properly executed stipulation of interest can (and did) convert an NPRI from fixed to floating.
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