ARKEMA INC. v. MAVIRO CATALYST INC.

CourtDistrict Court, E.D. Pennsylvania
DecidedMay 8, 2025
Docket2:24-cv-06130
StatusUnknown

This text of ARKEMA INC. v. MAVIRO CATALYST INC. (ARKEMA INC. v. MAVIRO CATALYST INC.) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ARKEMA INC. v. MAVIRO CATALYST INC., (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

ARKEMA INC., CIVIL ACTION Plaintiff,

v.

MAVIRO CATALYST, INC., NO. 24-6130 Defendant.

MEMORANDUM OPINION Plaintiff Arkema Inc. (“Arkema”) produces specialty materials, adhesives, and coatings that are “widely used in the manufacture of personal care and household products.” It operates a facility in Texas that “reacts propylene (hydrocarbon gas) with air to produce acrylic acid” to be used in those products. Defendant Maviro Catalyst, Inc. (“Maviro”), meanwhile, is an industrial services company that performs “catalyst changeout services” for “large tubular reactor[s]” operated by companies like Arkema.1 In 2017, Arkema and Maviro entered into an agreement— the “Master Plant Services Agreement” (the “MPSA”)—for work to be performed at Arkema’s Texas facility. Maviro alleges, however, that Arkema breached the MPSA and owes it “over three million additional dollars.” Arkema disagrees, arguing that it “has paid all amounts on approved and timely submitted change orders” made pursuant to the MPSA. In November 2024, Arkema filed the above-captioned action seeking a declaratory judgment “to have the parties’ obligations under [the] MPSA” clarified “to resolve the existing contract[ual] dispute.” But a month later, Maviro filed a competing breach of contract lawsuit against Arkema in the Southern District of Texas

1 In layman’s terms, Arkema analogizes the “catalyst changeout” process “to someone performing an oil change on [a] car.” based on that same dispute. Maviro now moves to dismiss the above-captioned action for lack of personal jurisdiction and improper venue pursuant to Federal Rules of Civil Procedure 12(b)(2) and (3) respectively.2 Alternatively, it moves to transfer the venue of this action to the Southern District of Texas

pursuant to 28 U.S.C. § 1404(a). For the reasons set forth below, Maviro’s Motions shall be denied. I. RULE 12 MOTIONS A. Timeliness At the outset, Arkema contends that Maviro’s Rule 12 Motions are untimely, and therefore, waived pursuant to Federal Rules of Civil Procedure 12(g)(2) and (h)(1)(A). Rule 12(g)(2) provides: “Except as provided in Rule 12(h)(2) or (3), a party that makes a motion under [Rule 12] must not make another motion under [Rule 12] raising a defense or objection that was available to the party but omitted from its earlier motion.” Rule 12(h)(1)(A) states: “A party waives any defense listed in Rule 12(b)(2)-(5) by omitting it from a motion in the circumstances described in Rule 12(g)(2).” To that end, Arkema submits that, by the Parties’ Stipulation and Order of this Court, Maviro had until January 9, 2025, to respond to its Original Complaint. But Maviro’s only

response to that Complaint was a Motion to Transfer Venue pursuant to 28 U.S.C. § 1404(a), which did not raise any Rule 12(b) defenses. Instead, Maviro first asserted those defenses in response to Arkema’s Amended Complaint, the filing of which, argues Arkema, does not “revive the right to present by motion defenses that were available but were not asserted in timely

2 In its brief, Maviro moves to dismiss the Amended Complaint for lack of personal jurisdiction pursuant to Rule 12(b)(1). That Rule, however, pertains to subject matter jurisdiction, see Fed. R. Civ. P. 12(b)(1), so the Court will construe Maviro’s Motion as one brought under Rule 12(b)(2), which concerns personal jurisdiction, see Fed. R. Civ. P. 12(b)(2). fashion prior to the amendment of the pleading.” Chan v. Cnty. of Lancaster, 2012 WL 4510776, at *13 (E.D. Pa. Sept. 28, 2012) (citing 5C Charles Alan Wright & Arthur R. Miller, Federal Practice & Procedure § 1388). That argument is unavailing, however, as the proposition in the case cited by Arkema is

inapposite. In Chan, the defendants sought to dismiss several disability discrimination claims alleged in the plaintiff’s Second Amended Complaint. Id. However, those claims were also pleaded in the Original and First Amended Complaint, and the defendants did not previously seek their dismissal in prior Rule 12 Motions. Id. Because the defendants challenged those claims only after plaintiff filed her Second Amended Complaint, they were found to have waived the ability to assert any defense to them under Rule 12(g). Id. But here, Maviro did not file a Rule 12 Motion in response to Arkema’s Original Complaint. Instead, it brought a Venue Transfer Motion pursuant to 28 U.S.C. § 1404(a). Therefore, Maviro did not waive its Rule 12(b)(2) and (b)(3) arguments, because, as the Chan Court noted, Rule 12(g) “generally precludes [defendants from] asserting available defenses in

successive motions brought pursuant to Rule 12.” Id. at *13 n.35 (emphases added). And regardless, “[a] court, in its discretion, may excuse the requirements of Rule 12(g).” Id. at *13 n.34 (citing Penn-Mont Benefit Services, Inc. v. Crosswhite, 2003 WL 203570 (E.D. Pa. Jan. 29, 2003)). Accordingly, Maviro’s Rule 12 Motions will be considered. B. Legal Standard Rule 12(b)(2) provides that a claim may be dismissed for “lack of personal jurisdiction.” Fed. R. Civ. P. 12(b)(2). “Once challenged, the plaintiff bears the burden of establishing personal jurisdiction,” which is a threshold matter that must be resolved before considering the merits of the pleadings. O’Connor v. Sandy Lane Hotel Co., 496 F.3d 312, 316 (3d Cir. 2007); see also Small v. Camden Cnty., 728 F.3d 265, 270 (3d Cir. 2013). A plaintiff is required to establish a prima facie case by demonstrating with “reasonable particularity sufficient contacts between the defendant and the forum state.” Provident Nat. Bank v. California Fed. Sav. & Loan Assoc., 819 F.2d 434, 437 (3d Cir. 1987). While this burden is not a heavy one, a plaintiff may not “rely on the bare pleadings alone” and must “respond with actual proofs, not mere allegations.” Time

Share Vacation Club v. Atlantic Resorts, Ltd., 735 F.2d 61, 66 n.9 (3d Cir. 1984). In so doing, a plaintiff is entitled to have all allegations taken as true and factual disputes resolved in their favor. Shuker v. Smith & Nephew, PLC, 885 F.3d 760, 780 (3d Cir. 2018). Allegations that “are no more than conclusions,” however, “are not entitled to the assumption of truth.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). Rule 12(b)(3) provides that a claim may be dismissed for improper venue. Fed. R. Civ. P. 12(b)(3).

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