Gratuity Solutions, LLC v. Toast, Inc.

CourtDistrict Court, M.D. Florida
DecidedFebruary 28, 2025
Docket2:24-cv-00737
StatusUnknown

This text of Gratuity Solutions, LLC v. Toast, Inc. (Gratuity Solutions, LLC v. Toast, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gratuity Solutions, LLC v. Toast, Inc., (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION

GRATUITY SOLUTIONS, LLC, and GRATUITY, LLC,

Plaintiffs,

v. 2:24-cv-737-JLB-NPM

TOAST, INC.,

Defendant.

ORDER This misappropriation-of-trade-secrets action arises from business interactions between plaintiffs Gratuity Solutions, LLC and Gratuity, LLC (collectively “Gratuity”) on the one hand and defendant Toast, Inc., on the other. Gratuity, as implied by its name, offers a platform for gratuity distribution for the hospitality industry, while Toast sells restaurant-management products and services. In August 2016, Gratuity approached Toast to discuss the possibility of providing its platform to Toast’s point-of-sale customers. The parties entered a mutual non- disclosure agreement to foster open communication, such as the exchange of trade secrets and other confidential information.1 In late 2019, the parties entered into a

1 Gratuity alleges that upon signing the NDA, Toast obtained access to some of Gratuity’s “trade secrets and other confidential information including certain technical and/or financial information related to, for example, certain business plans and strategies; customer lists and preferences; development information and plans including feature sets and feature development, and release plans; applications and/or methodologies for integrating and implementing such second non-disclosure agreement after Gratuity contacted Toast about acquiring the Gratuity businesses. During these latter negotiations, Gratuity further disclosed trade

secrets and confidential information to Toast. In January 2020, Toast declined to move forward with the Gratuity acquisition, and subsequent efforts by Gratuity in September 2021 also failed.

On November 16, 2021, Toast announced its own gratuity management solution, “Toast Tips Manager,” which Gratuity believed had many specific features found in its developed products. So on September 19, 2022, Gratuity filed suit against Toast—in the district of Massachusetts—for patent infringement, along with

a claim for breach of contract as to both nondisclosure agreements. Gratuity Solutions, LLC and Gratuity, LLC v. Toast, Inc., No. 1:22-cv-11539-PBS (D. Mass. Sept. 19, 2022). The infringement action was stayed on April 24, 2024 (and remains

stayed), after the Patent Trial and Appeal Board granted Toast’s petition for inter partes review, which challenges the validity of a Gratuity patent. Shortly thereafter, Gratuity filed this action for trade secret misappropriation on August 14, 2024, alleging that Toast obtained trade secrets and other confidential

information about Gratuity’s “PayDayPortal” program through certain customer advisory board members associated with Toast and that Toast has, in turn, used the

features sets and future features; work flows including customer-specific flows, software routines and applications for obtaining and processing customer-specific information; system architectures and interfaces; and associated source code.” (Doc. 50, ¶ 18). information to develop its “Tips Manager” program. Gratuity asserts state and federal claims for misappropriation and claims for civil conspiracy and intentional

interference with contracts. (Doc. 50). Gratuity seeks injunctive relief, compensatory and punitive damages, and attorney’s fees and costs. Id. We are presented with three motions: (1) Toast’s opposed motion to dismiss

the second amended complaint or to transfer venue to the District of Massachusetts (Doc. 54); (2) Toast’s request for oral argument regarding the same (Doc. 55); and Toast’s motion to stay discovery pending resolution of its transfer-or-dismiss motion (Doc. 56). Against this backdrop, the court addresses Toast’s request to transfer

venue. Toast argues that this action should be transferred to the district of Massachusetts under the first-to-file rule. When a complaint involving overlapping

parties and issues has already been filed in another district court, the “first-to-file” rule creates “a strong presumption” that the second case should be heard by the court with the first-filed matter. Manuel v. Convergys Corp., 430 F.3d 1132, 1135 (11th Cir. 2005). “The primary purpose of the rule is to conserve judicial resources and

avoid conflicting rulings.” Allstate Ins. Co. v. Clohessy, 9 F. Supp. 2d 1314, 1316 (M.D. Fla. 1998) (citing Nw. Airlines, Inc. v. Am. Airlines, Inc., 989 F.2d 1002, 1006 (8th Cir. 1993)). In determining whether the first-to-file rule applies, courts consider “(1) the chronology of the two actions, (2) the similarity of the parties, and (3) the similarity

of the issues.” Marrero v. Laundress, LLC, No. 2:23-cv-00519-JLB-KCD, 2024 WL 478370, *2 (M.D. Fla. Jan. 26, 2024) (citation omitted). Where the rule applies, “the party objecting to jurisdiction in the first-filed forum carr[ies] the burden of proving

“compelling circumstances” to warrant an exception to the first-filed rule.” Women’s Choice Pharms., LLC v. Rook Pharms., Inc., No. 16-cv-62074, 2016 WL 6600438, *2 (S.D. Fla. Nov. 8, 2016) (quoting Manuel, 430 F.3d at 1135). Compelling circumstances include bad-faith negotiations, anticipatory litigation, and forum

shopping. See Belacon Pallet Servs., LLC v. Amerifreight, Inc., No. 15-cv-191, 2016 WL 8999936, *4 (N.D. Fla. Mar. 26, 2016). The first two elements of the rule—the chronology of the actions and the

similarity of the parties—are quickly dispensed with. The Massachusetts action was filed in September 2022, almost two years before this one. And the parties aren’t just similar; they are identical. Thus, the key issue is whether the two actions are sufficiently similar.

The first-to-file rule does not require that the complaints be “mirror-images” of each other; instead, “[w]hat is required is a similarity or an overlapping in subject matter.” Rudolph and Me, Inc. v. Ornament Cent., LLC, No. 8:11-cv-670-T-33EAJ,

2011 WL 3919711, *3 (M.D. Fla. Sept. 7, 2011) (citing Manuel, 430 4 F.3d at 1135); see also Strother v. Hylas Yachts, Inc., No. 12-80283-CV, 2012 WL 4531357, *2 (S.D. Fla. Oct. 1, 2012) (explaining that “[a]ll that need be present is that the two

actions involve closely related questions or common subject matter …. The cases need not be identical to be duplicative”) (citation omitted). Looking past the legal dressing, it is apparent from the complaints that there

is indeed similarity and overlap. See Peterson v. Aaron’s, No: 1:14-cv-1919-TWT, 2015 WL 224750, *3 (N.D. Ga. Jan. 15, 2015) (“[W]hether cases are similar is a question of substance rather than form … [a]s long as the underlying facts are the same … the fact that the two complaints allege violations of different … laws is not

enough to render them dissimilar for purposes of the first-to-file analysis.” (citation omitted)). At the heart of each case is Toast’s Tips Manager. While the Massachusetts action alleges patent infringement and this action alleges

misappropriation of trade secrets, at bottom, the issue to be resolved in each case is whether Toast unlawfully used Gratuity’s proprietary information or invention to develop its Tips Manager. (Mass. Comp. ¶ 80; Doc. 50 ¶ 29). Despite the overlap, Gratuity argues that its trade-secret claims are factually

distinct from its patent-infringement claims because Toast allegedly obtained Gratuity’s trade secrets about its PayDayPortal through members of Toast’s Customer Advisory Board. But the means by, or conduit through which, the

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