Electro-Mechanical Recertifiers, L.L.C. v. Samsung E&C America, Inc.

CourtDistrict Court, M.D. Louisiana
DecidedJuly 1, 2025
Docket3:24-cv-00652
StatusUnknown

This text of Electro-Mechanical Recertifiers, L.L.C. v. Samsung E&C America, Inc. (Electro-Mechanical Recertifiers, L.L.C. v. Samsung E&C America, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Electro-Mechanical Recertifiers, L.L.C. v. Samsung E&C America, Inc., (M.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

ELECTRO-MECHANICAL RECERTIFIERS, L.L.C. CIVIL ACTION VERSUS 24-652-SDD-EWD SAMSUNG E&C AMERICA, INC.

RULING This matter is before the Court on the Motion to Dismiss, or alternatively to Transfer Venue,1 filed by Defendant Samsung E&C America, Inc. (“SECAI”). Plaintiff Electro- Mechanical Recertifiers, L.L.C. (“EMR”) opposes the Motion.2 SECAI filed a Reply,3 and EMR filed a Surreply.4 For the reasons that follow, the Motion will be granted in part and denied in part. I. BACKGROUND This case arises from a contractual relationship between EMR and SECAI. At the relevant time, SECAI was the general contractor on a construction project located in Taylor, Texas (the “Project”).5 In January of 2024, some of SECAI’s electrical gear at the Project was damaged by rainwater.6 SECAI sought the services of EMR to assess the damaged gear and prepare a plan and proposal for cleaning and restoration.7

1 Rec. Doc. 9. 2 Rec. Doc. 17. 3 Rec. Doc. 18. 4 Rec. Doc. 21. 5 Rec. Doc. 1, ¶ 4. 6 Id. at ¶ 5. 7 Id. at ¶ 6. On February 5, 2024, SECAI and EMR entered into a Technical Emergency Response Agreement (the “TERA”). The opening paragraph of the TERA reads, in part, as follows: EMR agrees to perform technical emergency consulting and technical restoration services for property and equipment damage restoration, repair, replacement and recertification services as more specifically set forth in Work Order(s) (the “Work”) for Client [SECAI]…8

EMR alleges that it agreed to perform “consulting services, including an assessment of the impacted Gear and the preparation of a plan and proposal for cleaning and restoration of the Gear (“Consulting Work”),” in exchange for payment on a time and expense basis not to exceed $24,800.9 EMR performed the Consulting Work and invoiced SECAI $24,108.52.10 Shortly after the completion of the Consulting Work, EMR alleges it “entered into a contractual agreement or modification” with SECAI whereby EMR would clean and restore the damaged electrical gear (the “Restoration Work”) in exchange for a projected total cost of $4,300,000.11 EMR alleges it performed the Restoration Work “diligently” from February 23, 2024, until March 8, 2024, when “SECAI represented that a stop work order was forthcoming in light of weather and flooding.”12 On March 11, 2024,13 SECAI sent EMR a letter (the “March 11 Letter”) stating that “SECAI will not be requiring any services of EMR for the [Project] including those related to the deep cleaning of electrical gear.”14

8 Rec. Doc. 9-4, p. 1. 9 Rec. Doc. 1, ¶¶ 6–7. 10 Id. at ¶ 8. 11 Id. at ¶ 9. 12 Id. at ¶ 10. 13 According to EMR, the letter was incorrectly dated March 7, 2024. See Rec. Doc. 17, p. 5. 14 Rec. Doc. 1, ¶ 12. EMR alleges the March 11 letter did not contain any reference to weather as the reason for the order to discontinue work. Id. at ¶ 13. The March 11 Letter further provided that SECAI “has not and will not authorize or otherwise approve EMR to render any services . . . other than the consulting services rendered from Feb 7-11, 2024.”15 EMR demobilized from the Project following receipt of the March 11 Letter.16

EMR alleges that it completed approximately 38.3% of the Restoration Work prior to the March 11 Letter.17 EMR asserts that it is entitled to payment in proportion to the amount of work it completed.18 EMR also alleges: During the time that EMR was on the Project site and continuing thereafter in the Baton Rouge, La. area, Plaintiff’s computers and cell phones were hacked and electronically stored information, private satellite video communications, and other communications personal and proprietary to EMR and its employees, was accessed, intercepted, disclosed, copied and damaged without permission, consent or authorization.19

EMR states that, “[u]pon information and belief,” SECAI committed these actions intentionally.20 Based on the foregoing facts, EMR’s Complaint enumerates the following seven claims: • Count I: Breach of Contract (Non-Payment on Work Performed);21 • Count II: Breach of Contract (Wrongful Termination);22

15 Id. at ¶ 13. 16 Id. at ¶ 14. 17 Id. at ¶ 16. 18 Id. EMR alleges that the only payments SECAI has made for the Consulting and Restoration Work are $765,924.95 paid on May 38, 2024, and $516,743.38 paid on June 26, 2024. Id. at ¶ 19. 19 Id. at ¶ 21. 20 Id. 21 Id. at ¶¶ 23–25. 22 Id. at ¶¶ 26–30. • Count III: Quantum Meruit;23 • Count IV: Misappropriation of Trade Secrets (Texas Law);24 • Count V: Louisiana Uniform Trade Secrets Act;25

• Count VI: Louisiana Unfair Trade Practices Act;26 • Count VII: Civil Action Under the Computer Fraud and Abuse Act, Stored Communications Act, and Wire and Electronic Communications Interception and Interception of Oral Communications Law.27 SECAI moves to dismiss for lack of personal jurisdiction, failure to state a claim, and improper venue, or alternatively to transfer venue.28 II. LAW AND ANALYSIS A. Motion to Dismiss for Improper Venue, or to Transfer Venue 1. Rule 12(b)(3)

SECAI moves to dismiss for improper venue pursuant to Federal Rule of Civil Procedure (“Rule”) 12(b)(3). In considering a Rule 12(b)(3) motion, the court is not limited to considering the facts pleaded in the complaint.29 Further, a plaintiff “need only make a prima facie case to establish venue if the court does not hold an evidentiary hearing.”30 The court “must accept as true all allegations in the complaint and resolve all conflicts in favor of plaintiff.”31

23 Id. at ¶¶ 31–33. 24 Id. at ¶¶ 34–38. 25 Id. at ¶¶ 39–43. 26 Id. at ¶¶ 44–50. 27 Id. at ¶¶ 51–54. 28 Rec. Doc. 9. 29 Ambraco, Inc. v. Bossclip B.V., 570 F.3d 233, 238 (5th Cir. 2009). 30 Martin v. Impact Health, No. CV 23-2497, 2023 WL 7498175, at *3 (E.D. La. Nov. 13, 2023) (citing Johnston v. Multidata Sys. Int'l Corp., 523 F.3d 602, 609 (5th Cir. 2008)). 31 Sinners and Saints, L.L.C. v. Noire Blanc Films, L.L.C., 937 F. Supp. 2d 835, 845 (E.D. La. 2013) (quoting Braspetro Oil Servs. Co. v. Modec (USA), Inc., 240 Fed. App'x 612, 615 (5th Cir. 2007)). Parties may limit future litigation to a particular venue through the use of a forum selection clause. The TERA contains a forum selection clause which reads as follows: Disputes. All disputes shall be resolved in a court of competent jurisdiction in East Baton Rouge Parish, Baton Rouge, Louisiana.32

Forum selection clauses “are prima facie valid and should be enforced unless enforcement is shown by the resisting party to be ‘unreasonable’ under the circumstances.”33 This may be done through demonstration that the clause “results from fraud or overreaching, that it violates a strong public policy, or that enforcement of the clause deprives the plaintiff of his day in court.”34 “The party resisting enforcement on these grounds bears a ‘heavy burden of proof.’”35 SECAI does not argue the forum selection clause is unenforceable. Rather, SECAI acknowledges the forum selection clause but argues it does not apply to this dispute.36 Specifically, SECAI asserts that the TERA – the contract containing the forum selection clause – only applies to Consulting Work. Because EMR’s lawsuit seeks payment for the Restoration Work rather than the Consulting Work, SECAI concludes the forum selection clause does not apply.37 In opposition, EMR argues the TERA encompasses the Restoration Work.38 In support of its position that the TERA covers the Restoration Work, EMR emphasizes the following language of the TERA: “EMR agrees to perform technical

32 Rec. Doc. 9-4, p. 2. 33 M/S Bremen v. Zapata Off-Shore Co., 407 U.S. 1, 10 (1972) (citation omitted).

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Electro-Mechanical Recertifiers, L.L.C. v. Samsung E&C America, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/electro-mechanical-recertifiers-llc-v-samsung-ec-america-inc-lamd-2025.