Integrated Business Planning Associates v. Operational Results

CourtDistrict Court, D. Utah
DecidedJune 6, 2024
Docket2:22-cv-00733
StatusUnknown

This text of Integrated Business Planning Associates v. Operational Results (Integrated Business Planning Associates v. Operational Results) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Integrated Business Planning Associates v. Operational Results, (D. Utah 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

INTEGRATED BUSINESS PLANNING MEMORANDUM DECISION & ORDER ASSOCIATES, INC., an Illinois corporation, (AMENDED) GRANTING IN PART AND DENYING IN PART DEFENDANT’S Plaintiff, MOTION FOR PARTIAL SUMMARY JUDGMENT v. Case No. 2:22-cv-00733-JNP-CMR OPERATIONAL RESULTS, INC., a Delaware corporation, District Judge Jill N. Parrish

Defendant.

Through this action, Integrated Business Planning Associates, Inc. (“IBP2” or “Plaintiff”) asserts claims for breach of contract and under the Utah Sales Representative Commission Payment Act against Operation Results, Inc. (“ORI” or “Defendant”). Before the court is ORI’s Motion for Partial Summary Judgment, ECF No. 28 (“Mot.”). For the reasons set out below, ORI’s motion is GRANTED IN PART AND DENIED IN PART. FACTUAL BACKGROUND This action centers on the business relationship between IBP2 and ORI. IBP2 is a consulting firm that focuses on supply chain planning. ORI is a consulting and software-as-a- service company. The parties’ dealings go back to at least 2016, when IBP2 and ORI entered into their first mutual referral agreement, in which each agreed to pay referral fees for new customers and business referred by the other. ECF No. 28-3 (“2016 Agreement”). In 2018, the parties executed a new agreement, largely based on the 2016 Agreement, but with some modifications. ECF No 28-4 (“2018 Agreement”). The 2018 Agreement forms the basis for IBP2’s breach-of-contract claim against ORI. See ECF No. 1 (“Compl.”) ¶ 30. The 2018 Agreement creates an ostensibly perpetual entitlement to referral fee payments

held by a referring party according to an agreed-upon payment schedule. 2018 Agreement §§ 12, 15; id., Ex. A §§ 2, 4(a). The Agreement outlines particular terms and processes restricting the parties’ entitlement to referral fees under the Agreement. Namely, the contractual provisions identified in Exhibit A of the 2018 Agreement are applicable to referral fees as defined by section four of the Agreement. An entitlement to these referral fees is created where a referred party “enters into a contract with a New Sales Lead or otherwise provides products and/or services to a New Sales Lead[.]” Id. § 3. Such New Sales Leads, the Agreement states, are to be identified as a New Sales Lead and communicated by the referring party to the referred party “through electronic mail via a format mutually agreed to by the parties.” Id. § 2. Section two continues to read that “[e]ach party will

have fifteen days to accept or reject a New Sales Lead. If the Referred Party does not provide written acceptance (electronic mail is acceptable) of the New Sales Lead within fifteen days after submission, then the New Sales Lead shall be deemed rejected.” Id.1 In addition to being subject to being “deemed rejected” as New Sales Leads by the referred party, referrals of such New Sales Leads are also vulnerable to expiration and becom[ing] null and void without the requirement of written notice thereof, and no longer subject to the payment of any Referral Fee, in in the event that the New Sales Lead has not become a customer of the Referred Party (as evidenced by a signed

1 By implication, the court understands that rejection of such New Sales Leads unambiguously defeats any entitlement to referral fees under the 2018 Agreement. 2 purchase agreement) within one (1) year from the date of the written approval of the New Sales Lead. Referrals which have so expired shall no longer be subject to the opportunity for any Referral Fee.

Id. § 5. Thus, a referring party’s entitlement to Referral Fees under the 2018 Agreement is ostensibly subject to at least three agreed-upon terms or conditions: (1) Such Referral Fees must have been generated from New Sales Leads properly identified and communicated “via a format mutually agreed to by the parties,” id. § 2; (2) Such New Sales Leads must have been accepted or approved by the referred party within fifteen days of such identification and communication, id.; and (3) Contracts with such New Sales Leads (from which the Referral Fees would be paid under the Agreement) must be executed, meaning that the New Sales Leads become customers of the referred party, within one year from the date of the written approval of the New Sales Leads by the referred party. Id. §§ 3, 5. In its motion, ORI moves for partial summary judgment as to the application of the 2018 Agreement to seven customers referred to it by IBP2.2 On September 24-25, 2018, a representative from ORI sent IBP2 an email with a list of “companies we accept as New Sales Leads from IBP2,” including the seven customers. See ECF No. 28-5 at 3. Because the sales contracts with the first four of these customers were all signed more than one year after this purported acceptance email (which IBP2 argues did not satisfy the contract terms), ORI argues that the referrals expired. ORI also argues that the latter three customers are

2 For the purposes of this amended order, these customers will be referred to by a roman numeral corresponding to numbering in the sealed version of this order. See ECF No. 59 (filed under seal). 3 outside of the terms of the Agreement because they were already ORI customers at the execution of the 2018 Agreement. Although ORI previously paid IBP2 referral fees for the seven customers at issue here, it has since changed course, arguing that it was under no legal obligation to do so, and that the prior

payments were the result of a mistake regarding its contractual duties. See Mot. at 4. Thus, ORI now requests that this court interpret the terms of the 2018 Agreement to determine, as to those seven customers, ORI’s obligations. Although IBP2 points to the potential applicability of other agreements to these customers,3 the court, in this order, considers only the 2018 Agreement pursuant to ORI’s motion. ORI also seeks a determination of the applicability of the remedial provisions of the Utah Sales Representative Commission Payment Act, UTAH CODE ANN. § 33-44- 101 et seq. (“Act” or “Utah Act”). For the reasons laid out below, ORI’s motion is GRANTED IN PART AND DENIED IN PART. LEGAL STANDARD

Summary judgment is appropriate when “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). The movant bears the initial burden of demonstrating the absence of a genuine dispute of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986). “A fact is material only if it might affect the outcome of the suit under the governing law. And a dispute over a material fact is

3 These include the 2016 Agreement and an agreement entered into by the parties in 2019, the Software Services Agreement, ECF No. 35-5 (“2019 Agreement” or “2019 Pilot Agreement”), which, under IBP2’s interpretation, created an additional avenue for IBP2 to collect a referral fee from ORI. 4 genuine only if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Foster v. Mountain Coal Co., 830 F.3d 1178, 1186 (10th Cir. 2016). Once the movant has met this burden, the burden shifts to the nonmoving party to “set forth specific facts showing that there is a genuine issue for trial.” Anderson v. Liberty Lobby, Inc., 477

U.S. 242, 248 (1986) (citation omitted). When applying the summary judgment standard, the court must “view the evidence and make all reasonable inferences in the light most favorable to the nonmoving party.” N. Nat. Gas Co. v. Nash Oil & Gas, Inc., 526 F.3d 626, 629 (10th Cir. 2008).

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Integrated Business Planning Associates v. Operational Results, Counsel Stack Legal Research, https://law.counselstack.com/opinion/integrated-business-planning-associates-v-operational-results-utd-2024.