Eve Sales Corp. v. Marie Sharp's, USA, LLC

CourtDistrict Court, S.D. New York
DecidedFebruary 24, 2025
Docket1:24-cv-02757
StatusUnknown

This text of Eve Sales Corp. v. Marie Sharp's, USA, LLC (Eve Sales Corp. v. Marie Sharp's, USA, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eve Sales Corp. v. Marie Sharp's, USA, LLC, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK EVE SALES CORP. and MARIE SHARP'S. FINE FOODS, LTD., Plaintiffs, 24-cv-2757 (PKC) -against- OPINION AND ORDER MARIE SHARP’S, USA, LLC, Defendant. nnn nnn nnn nnn nnn nen

CASTEL, U.S.D.J., Marie Sharp, who is not a party to this action, was inducted into the Hot Sauce Hall of Fame in Brooklyn, New York in 2016. The company she founded, plaintiff Marie Sharp’s Fine Foods, Ltd. (“MSFF’’), is headquartered in Belize and sells branded sauces, jams and jellies. At some point, defendant Marie Sharp’s USA, LLC (‘MSUSA”), headquartered in North Carolina, began distributing MSFF products in the United States. Plaintiff Eve Sales Corp. (“ESC”) is a New York-based purchaser of MSFF-branded products. This action and a companion action pending in the United States District Court for the Middle District of North Carolina arise out of the breakdown in MSUSA’s relationships with MSFF and ESC. The parties were unable to resolve their differences outside of court. Ultimately, MSUSA asked MSFF if it would agree to waive service of process in the action that MSUSA threatened to bring against MSFF and ESC. Instead of responding to the waiver request, MSFF and ESC initiated this action against MSUSA by filing a complaint seeking exclusively declaratory relief.

About two months later, MSUSA filed its own complaint against MSFF and ESC in the Middle District of North Carolina, asserting claims for breach of contract, tortious interference, and fraudulent and/or negligent misrepresentation arising out of principally the same underlying events that form the basis for this action. MSFF and ESC have twice amended their complaint in this action. The operative pleading, the Second Amended Complaint (“SAC”) (ECF 24), was filed after the institution of the action in the Middle District of North Carolina and has added a breach of contract claim to the initial complaint’s declaratory judgment claims. MSUSA now moves to dismiss the SAC or, in the alternative, to transfer this action to the Middle District of North Carolina pursuant to 28 U.S.C. § 1404(a). For reasons that will be explained, including the conclusion that this action was initiated as an improper anticipatory declaratory judgment action as defined by the Second Circuit, MSUSA’s motion to transfer will be granted. BACKGROUND The claims in the SAC center on two agreements for the distribution and sale of products manufactured by MSFF. (ECF 24 1, 13.) On October 26, 2017, MSUSA, then known as Thoughtleader.com, LLC, and ESC, a food products distributor, entered into an agreement (the “2017 Agreement”) whereby ESC agreed to purchase MSFF products “only” from MSUSA and MSUSA authorized ESC to sell those products to certain clients and markets. (Id. ff 6, 12; ECF 24-1 §§ 1-2.) MSUSA and MSFF also entered into an agreement dated April 1, 2022 (the “2022 Agreement”) in which MSFF agreed to supply its products to MSUSA “for the purpose of sales, marketing, promotion and distribution” within the United States. (ECF 24- 2 at 2.) The 2022 Agreement appointed MSUSA as the “official USA Representative.” (Id.) MSFF, ESC, and MSUSA are headquartered in Belize, New York, and North Carolina, respectively. (ECF 24 4 4-6.) -2-

MSUSA’s relationship with ESC eventually broke down. Plaintiffs assert that in 2018, ESC discovered that MSUSA’s President had made misrepresentations to it regarding MSUSA’s rights to distribute and control the pricing of MSFF products. (Id. §§ 14, 37-38.) ESC “gmmediately contacted” MSUSA’s President to “express its dismay as to his misrepresentations.” (Id. 39.) ESC also allegedly terminated the 2017 Agreement at this time. (Id.) Nonetheless, by late 2018 or early 2019, MSUSA and ESC had agreed to pursue a new joint proposal for them to work with MSFF in the United States. (Id. § 41.) MSFF and ESC claim that all parties agreed to the joint proposal. (Id. J 45.) But MSUSA’s relationship with ESC reached another breaking point. ESC and MSFF repeatedly took issue with the manner in which MSUSA was conducting its business. (See, e.g., id. 47, 49.) In or about April 2023, ESC notified MSUSA that it was no longer willing to work with it. (id. § 67.) After ceasing to do business with MSUSA, ESC began purchasing MSFF products directly from MSFF. (Id.) On March 6, 2024, MSUSA sent MSFF a letter stating that it considered the direct sales between MSFF and ESC to be in violation of its 2022 Agreement with MSFF and its 2017 Agreement with ESC. (ECF 21-1 at 6.) It was MSUSA’s view that the 2022 Agreement granted it the exclusive right to distribute MSFF products in the U.S. (Id.) Noting that MSUSA’s “damages due to this violation . . . are quite substantial and continue to accrue,” the letter “urge[d] MSFF to cease all direct sales to US customers.” (Id. at 6-7.) In response, on March 15, MSFF provided MSUSA with written notice of no-cause termination of the 2022 Agreement. (ECF 24 § 69; ECF 26-3 at 1.) The effective date of the 2022 Agreement’s termination was June 13. (ECF 24 ¥ 79; ECF 26-3 at 1.) MSFF also provided MSUSA with a new, non-exclusive distribution agreement for its consideration. (ECF 24 § 69.)

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Following MSFF’s notice of termination, MSUSA sought to secure full exclusivity from MSFF, and began to threaten litigation. In a March 21 email to MSFF’s counsel, MSUSA’s counsel asserted that MSFF had breached the 2022 Agreement and tortiously interfered with MSUSA’s separate agreement with ESC. (ECF 26-13 at 4-5.) MSUSA’s counsel stated that “[his] client would prefer to avoid litigation,” but “‘[i]f MSFF is not amenable to negotiation of an acceptable and exclusive agreement and an immediate cessation of direct sales, MSUSA will be forced to pursue remedies at law.” (Id. at 5) MSUSA then turned its focus to ESC. On April 2, MSUSA’s counsel sent a cease and desist letter to ESC. (ECF 26-9 at 1.) The letter stated that ESC’s direct purchases from MSFF were in breach of the 2017 Agreement’s exclusivity requirement and that ESC had also tortiously interfered with MSUSA’s separate agreement with MSFF. (Id.) The letter continued, “Your breach and tortious interference have caused substantial financial damage to MSUSA.” (Id.) It then requested that ESC “immediately cease and desist from any and all direct purchases from MSFF.” (id.) Still without a response from MSFF regarding its exclusivity demand, MSUSA’s counsel sent another email to MSFF’s counsel on April 4. (ECF 26-10 at 1.) He informed MSFF’s counsel, “My client has asked me to move forward with preparation for litigation.” (Id.) He also asked, “Will you waive service on behalf of your client?” (Id.) Later that day, MSFF’s counsel emailed MSUSA’s counsel to address the latter’s March 21 email. (ECF 26-13 at 2-4.) While MSFF disagreed that the 2022 Agreement made MSUSA the exclusive distributor of its products in the U.S., it nonetheless offered to designate MSUSA as its exclusive distributor to Walmart. (Id. at 3.) MSUSA would otherwise remain a non-exclusive distributor pursuant to the new distribution agreement that MSFF had previously shared with MSUSA. (Id.)

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MSUSA rejected MSFF’s offer the next day. (Id. at 1.) Replying to MSFF’s counsel, MSUSA’s counsel reiterated that MSFF had breached the 2022 Agreement and tortiously interfered with MSUSA’s contractual relationship with ESC. (Id. at 2.) He stated that MSFF’s termination of the 2022 Agreement “doesn’t resolve the breach or tortious interference” and “only solidified and magnified the damages.” (Id.) He added that the company “remains willing to discuss an exclusive distribution agreement.” (Id.) MSUSA did not receive a response from MSFF to its April 5 email. On April 9, MSUSA’s counsel again raised the question of waiver of service with MSFF’s counsel.

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Eve Sales Corp. v. Marie Sharp's, USA, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eve-sales-corp-v-marie-sharps-usa-llc-nysd-2025.