Beanstalk Innovation, Inc. v. SRG Tech., LLC

338 F. Supp. 3d 691
CourtDistrict Court, S.D. Ohio
DecidedSeptember 18, 2018
DocketCase No. 1:17-cv-553
StatusPublished

This text of 338 F. Supp. 3d 691 (Beanstalk Innovation, Inc. v. SRG Tech., LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beanstalk Innovation, Inc. v. SRG Tech., LLC, 338 F. Supp. 3d 691 (S.D. Ohio 2018).

Opinion

Section 11 of the Reseller Agreement provides that oral modifications are prohibited:

This Agreement and any term or provision hereof may be changed, waived, discharged or terminated only in writing, signed by the Parties.

(Doc. 1-1 at ¶ 11).

Section 9 of the Settlement Agreement also prohibits oral modifications:

This Settlement Agreement may only be amended or modified with the prior consent of the Parties and in a writing executed by the Parties hereto.

(Doc. 1-2 at ¶ 9).

Florida courts enforce clauses, such as those in the Agreements, requiring any contract modifications be in writing.

[W]hen a contract plainly provides that any modification must be in writing, all claims - however labeled - founded upon an alleged oral modification should generally be disposed of as a matter of law. The parties have dealt with the issue through a provision designed - and intended - to protect them against the risk of being enmeshed in, and harassed by protracted litigation based upon alleged oral modifications and courts should in most cases do no more than enforce the contract as written.

*697Okeechobee Resorts, L.L.C. v. E Z Cash Pawn, Inc. , 145 So.3d 989, 993 (Fla. Dist. Ct. App. 2014) (granting summary judgment in breach of contract case and enforcing contract provision that required any modifications be in writing). Thus, under Florida law, the Court should generally disregard any alleged oral modification to the Agreements made between SRG and Beanstalk.

Nevertheless, Defendant notes that Florida law recognizes an exception to a "no oral modification" clause in which a "written contract or agreement may be altered or modified by an oral agreement if the latter has been accepted and acted upon by the parties in such manner as would work a fraud on either party to refuse to enforce it." Professional Insurance Corp. v. Cahill, 90 So.2d 916, 918 (Fla. 1956). In order to prove that an exception to the "no oral modification" provision applies, a party must show:

(a) that the parties agreed upon and accepted the oral modification (i.e., mutual assent); and (b) that both parties (or at least the party seeking to enforce the amendment) performed consistent with the terms of the alleged oral modification (not merely consistent with their obligations under the original contract); and (c) that due to [the party seeking enforcement of the oral modification's] performance under the contract as amended the [other party] received and accepted a benefit that it otherwise was not entitled to under the original contract (i.e., independent consideration).

Okeechobee , 145 So.3d 989, 995.

Here, even if the Court assumes that the parties orally modified the Agreements, Defendant cannot show the other two elements required to prove that an exception to the "no oral modification" clause applies. First, Defendant did not perform consistent with the alleged oral modification as SRG neither deposited $86,777 in trust nor did SRG make a payment to SRG pursuant to the alleged oral modification. Second, Plaintiff did not receive a benefit that it otherwise was unentitled to under the original contract as Beanstalk not only did not receive the full payment of $109,375 under the Agreements, it did not receive $86,777 it would have been owed under the alleged oral modification. Therefore, Defendant cannot show that show that an exception to the "no oral modification" clauses in the Agreements applies. Okeechobee , 145 So.3d 989, 995 ("Absent such a showing [that an exception applies], the parties will be held to the bargain as negotiated and memorialized in their written agreement.").

Finally, Defendant raises several affirmative defenses that it argues preclude entry of summary judgment, including estoppel, waiver, novation, and negligent misrepresentation. (Doc. 23 at 5-8). None of these affirmative defenses are successful.

Estoppel. Defendant argues that the defense of promissory estoppel precludes summary judgment for Plaintiff. Florida courts have found that promissory estoppel as an affirmative defense fails where a written contract includes a "no oral modification" clause because estoppel is "an equitable doctrine for the enforcement of agreements, not a device to nullify an expressly-agreed, written contractual term." Coral Reef Drive Land Dev., LLC v. Duke Realty Ltd. P'ship , 45 So.3d 897, 902 (Fla. Dist. Ct. App. 2010) (affirming summary judgment on basis that an alleged oral modification of a contract was unenforceable where contract included a "no modification" clause); see also Univ. of Miami v. Intuitive Surgical, Inc., 166 F. App'x 450, 454 (11th Cir. 2006) ("Promissory estoppel is not available as a remedy *698when parties have a written contract addressing the relevant issue").

Waiver . Defendant next contends that Plaintiff waived its right to the $109,375 payment under the Agreements. "Waiver is the voluntary and intentional relinquishment of a known right, or conduct which implies the voluntary and intentional relinquishment of a known right." Major League Baseball v. Morsani , 790 So.2d 1071, 1077 (Fla. 2001). Here, the Reseller Agreement plainly states that contract provisions can only be waived in writing. (Doc. 1-1 at ¶ 11). Defendant cites to no legal precedent to support its claim that Plaintiff's alleged oral waiver qualifies as an exception to the "no oral modification" rule. Therefore, Defendant's waiver defense fails.

Novation . Defendant argues that Plaintiff novated the Agreements through the alleged oral modification. Under Florida law, four elements are necessary to demonstrate a novation: (1) the existence of a previously valid contract; (2) the agreement to make a new contract; (3) the intent to extinguish the original contractual obligation; and (4) the validity of the new contract." Excess Risk Underwriters, Inc. v. Lafayette Life Ins. Co. , 328 F.Supp.2d 1319, 1331 (S.D. Fla. 2004). As the Court discussed supra , any alleged oral modification of the Agreements was invalid and unenforceable. Therefore, Defendant fails to prove the elements to demonstrate that Plaintiff novated the Agreements.

Negligent Misrepresentation. Finally, Defendant argues that the affirmative defense of negligent misrepresentation prevents an issuance of summary judgment in Plaintiff's favor.

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Related

University of Miami v. Intuitive Surgical, Inc.
166 F. App'x 450 (Eleventh Circuit, 2006)
Professional Insurance Corporation v. Cahill
90 So. 2d 916 (Supreme Court of Florida, 1956)
Major League Baseball v. Morsani
790 So. 2d 1071 (Supreme Court of Florida, 2001)
Keye v. Gautier
684 So. 2d 210 (District Court of Appeal of Florida, 1996)
Excess Risk Underwriters, Inc. v. Lafayette Life Insurance
328 F. Supp. 2d 1319 (S.D. Florida, 2004)
Coral Reef Drive Land Development, LLC v. Duke Realty Ltd. Partnership
45 So. 3d 897 (District Court of Appeal of Florida, 2010)
Okeechobee Resorts, L.L.C. v. E Z Cash Pawn, Inc.
145 So. 3d 989 (District Court of Appeal of Florida, 2014)
Jungbluth v. American Bank & Trust Co.
134 So. 612 (Supreme Court of Florida, 1931)
Hawaiian Airlines, Inc. v. AAR Aircraft Services, Inc.
167 F. Supp. 3d 1311 (S.D. Florida, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
338 F. Supp. 3d 691, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beanstalk-innovation-inc-v-srg-tech-llc-ohsd-2018.