Free State of Bavaria Represented by the Univ. of Wurzburg v. Ohio State Univ.

CourtOhio Court of Appeals
DecidedJune 30, 2026
Docket24AP-515
StatusPublished

This text of Free State of Bavaria Represented by the Univ. of Wurzburg v. Ohio State Univ. (Free State of Bavaria Represented by the Univ. of Wurzburg v. Ohio State Univ.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Free State of Bavaria Represented by the Univ. of Wurzburg v. Ohio State Univ., (Ohio Ct. App. 2026).

Opinion

[Cite as Free State of Bavaria Represented by the Univ. of Wurzburg v. Ohio State Univ., 2026-Ohio-2493.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

Free State of Bavaria, : Represented by the University of Würzburg, : No. 24AP-515 Plaintiff-Appellant, : (Ct. of Cl. No. 2022-00495JD)

v. : (REGULAR CALENDAR)

The Ohio State University, :

Defendant-Appellee. :

D E C I S I O N

Rendered on June 30, 2026

On brief: Hahn Loeser & Parks, LLP, Eric B. Levasseur; Chiesa, Shahinian & Giantomasi P.C., and Joseph V. Saphia, pro hac vice, for appellant. Argued: Joseph V. Saphia.

On brief: [Andy Wilson], Attorney General, Mathura J. Sridharan; Ice Miller, LLP, and Jenny Buchheit, pro hac vice, for appellee. Argued: Mathura J. Sridharan.

APPEAL from the Court of Claims of Ohio

LELAND, J.

{¶ 1} Plaintiff-appellant, The University of Würzburg (“UW”), appeals from a judgment of the Court of Claims of Ohio in favor of The Ohio State University (“OSU”). For the following reasons, we affirm. [Cite as Free State of Bavaria Represented by the Univ. of Wurzburg v. Ohio State Univ., 2026-Ohio-2493.]

I. FACTS AND PROCEDURAL HISTORY {¶ 2} UW and OSU were engaged in biomedical research with laboratory mice regarding spinal muscular atrophy (“SMA”), a debilitating disease that causes loss of motor function in children. Survival Motor Neuron (“SMN”) genes maintain motor neuron health, and mutations in the genes cause SMA. {¶ 3} Dr. Michael Sendtner and the UW team developed a mouse without full function of the SMN1 gene, known as the SMN1 Knockout Allele (“Knockout”) mouse. At about the same time, Dr. Arthur Burghes and the OSU team engineered a process to insert the SMN2 gene into a mouse. OSU reached out to collaborate with UW, and UW provided its mouse to OSU in 1997 to use in its research. An agreement regarding its use was not reduced to writing at that time. {¶ 4} In 1999, OSU synthesized the two mice and created the Severe SMA mouse that had full loss of the SMN1 gene but retained use of the new SMN2 gene and exhibited the same physical symptoms as a child with SMA. Drs. Burghes and Sendtner presented the mouse at a SMA conference in June 1999, and it became the first realistic animal model for SMA testing. The two scientists celebrated the success of this new research tool and co-authored two papers. The collaboration was dissolved in 2004 and the institutions pursued independent activity. {¶ 5} OSU continued its SMA genetic research and developed the SMNDelta 7 (“Delta 7”) mouse, which had a much longer life span and displayed a uniform course of the disease. The Delta 7 mouse became the gold standard research tool for SMA research and, in 2004, the SMA Foundation (“SMAF”) contacted OSU and negotiated a license for the Delta 7 mouse mice to facilitate broader dissemination in the research community. The SMAF also negotiated a license with UW for the use of the Knockout mouse. {¶ 6} On April 14, 2005, OSU entered into an agreement with the Jackson Laboratory (“JAX”), a central repository for scientific research animals, whereby JAX would assume distribution of the Delta 7 mouse. Pursuant to the agreement, non-profit and academic institutions are able to use the mice for research purposes without charge, but for-profit entities must seek a license from OSU. {¶ 7} A team from Nationwide Children’s Hospital (“NCH”) and OSU, including Dr. Burghes, used the Delta 7 mouse from JAX to create Zoglensma®, a gene therapy No. 24AP-515 3

treatment for SMA. NCH and OSU have been compensated for their involvement in the drug’s development. Neither Dr. Sendtner nor UW had any involvement in the research or development of Zoglensma®. {¶ 8} The OSU technology commercialization office (“TCO”) negotiates and manages agreements for the use of scientific material owned by OSU. In 2016, a company interested in the Delta 7 mouse requested the TCO clarify UW’s interest in the mouse. TCO staff discussed the development of the mouse with Dr. Burghes and realized that UW had an interest in the Delta 7 mouse. The TCO negotiated an Inter-Institutional Agreement (“IIA”) with UW in September 2017 to address unremitted fees and govern distribution of future license fees. The IIA had an effective date of April 14, 2005, and required OSU to pay UW a one-time fee of $25,000 to compensate UW for licensing agreements OSU entered into between 2005 and 2017. New commercial entities using the Delta 7 mouse would pay a licensing fee of $80,000 which would be split equally between UW and OSU after a JAX administrative fee was deducted. As of the date of oral argument in this case, UW had refused to accept payment from OSU pursuant to the IIA. {¶ 9} On June 22, 2022, UW filed a lawsuit against OSU for the unauthorized use of the Delta 7 mouse. UW alleged that OSU misrepresented its ownership interest in the mice to JAX and that OSU fraudulently misrepresented its position during the IIA negotiation resulting in the loss of compensation from licensing fees. The matter proceeded to a bench trial where the court found in favor of OSU on all counts. UW now brings the instant appeal. II. ASSIGNMENTS OF ERROR {¶ 10} UW assigns the following as trial court error:

[I.] The Court of Claims (“Trial Court”) erred when by entering judgment in favor of Defendant-Appellee The Ohio State University (“OSU”) and finding that OSU did not breach any fiduciary duty owed to Plaintiff-Appellant Free State of Bavaria, represented by the University of Wurzburg (“UW”).

[II.] The Trial Court erred by entering judgment in favor of OSU and failing to find that OSU committed fraud by concealing and misrepresenting material facts that it had a duty to disclose. No. 24AP-515 4

[III.] The Trial Court erred by entering judgment in favor of OSU and failing to find that OSU committed fraud by making false statements for which knowledge of falsity can be inferred.

[IV.] The Trial Court erred by entering judgment in favor of OSU and failing to find that OSU committed constructive fraud.

[V.] The Trial Court erred by entering judgment in favor of OSU and finding that UW’s damages claim was speculative.

[VI.] The Trial Court erred by denying UW’s motion to apply German law to pre-contractual disclosures.

III. STANDARD OF REVIEW {¶ 11} In a civil appeal from a bench trial, we apply a manifest weight standard to our review of the factual issues. Huntington Natl. Bank v. Miller, 2016-Ohio-5860, ¶ 13 (10th Dist.). Judgments supported by competent, credible evidence going to all the essential elements of the case will not be reversed as being against the manifest weight of the evidence. Skorvanek v. Ohio Dept. of Rehab. & Corr., 2018-Ohio-3870, ¶ 89 (10th Dist.). We presume the findings of the trial court are correct because the trial judge is best able to observe the witnesses and use those observations in weighing the credibility of the proffered testimony. Grove City v. Clark, 2002-Ohio-4549, ¶ 19 (10th Dist.). However, purely legal questions are subject to a de novo review. MacDonald v. Authentic Invests., L.L.C., 2016-Ohio-4640 (10th Dist.). IV. LEGAL ANALYSIS {¶ 12} UW argues as its first assignment of error that the trial court erred when it found in favor of OSU on UW’s claim for breach of fiduciary duty and determined that it did not have a fiduciary relationship with OSU. UW contends OSU breached a fiduciary duty by representing to JAX that it had the legal right to license the Delta 7 mouse SMA mice and concealing and misrepresenting material facts to entice UW to sign a backdated IIA. {¶ 13} A plaintiff bringing a claim for breach of fiduciary duty must prove “(1) the existence of a duty arising from a fiduciary relationship, (2) the defendant’s failure to observe the duty, and (3) an injury proximately resulting from the breach.” Santagate v. No. 24AP-515 5

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