ITG Brands, LLC v. Reynolds American Inc.

CourtCourt of Chancery of Delaware
DecidedApril 1, 2024
Docket2017-0129-LWW
StatusPublished

This text of ITG Brands, LLC v. Reynolds American Inc. (ITG Brands, LLC v. Reynolds American Inc.) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ITG Brands, LLC v. Reynolds American Inc., (Del. Ct. App. 2024).

Opinion

COURT OF CHANCERY OF THE STATE OF DELAWARE LORI W. WILL LEONARD L. WILLIAMS JUSTICE CENTER VICE CHANCELLOR 500 N. KING STREET, SUITE 11400 WILMINGTON, DELAWARE 19801-3734 Date Submitted: February 5, 2024 Date Decided: April 1, 2024

Stephen C. Norman, Esquire Kurt M. Heyman, Esquire Matthew F. Davis, Esquire Aaron M. Nelson, Esquire Tyler J. Leavengood, Esquire Heyman Enerio Gattuso & Hirzel LLP Potter Anderson & Corroon LLP 300 Delaware Avenue, Suite 200 1313 North Market Street Wilmington, Delaware 19801 Wilmington, Delaware 19801

Gregory P. Williams, Esquire Rudolf Koch, Esquire Robert L. Burns, Esquire Matthew D. Perri, Esquire Edmond S. Kim, Esquire Richards, Layton & Finger, P.A. 920 North King Street Wilmington, Delaware 19801

RE: ITG Brands, LLC v. Reynolds American Inc., et al., C.A. No. 2017-0129-LWW

Dear Counsel:

This letter resolves Philip Morris USA Inc.’s motion to intervene. Philip

Morris seeks to assert an unjust enrichment claim against the parties. But

intervention could have been sought long ago and comes on the cusp of trial. The

motion is denied as untimely.

I. BACKGROUND

The background of this action is described in memorandum opinions by this

court dated September 30, 2022 (the “2022 Opinion”) and October 2, 2023 (“2023 C.A. No. 2017-0129-LWW April 1, 2024 Page 2 of 7

Opinion”).1 Capitalized terms used below have the same meanings given in the

2023 Opinion.

In the 2022 Opinion, I held that the Florida Judgment Liability was an

Assumed Liability that ITG was responsible for under the APA.2 In the 2023

Opinion, I held that Reynolds was entitled to indemnification for the Losses

associated with the Florida Judgment Liability based on ITG’s sales of Acquired

Brand cigarettes.3 The amount of Reynolds’ damages will be determined after trial

this July. The issues for trial include the potential application of a Profit

Adjustment allocation, which ITG avers may reduce the amount of indemnification

available to Reynolds.4

The Profit Adjustment relates to annual payments to Florida, based on the

volume of ITG’s sales of the Acquired Brands, in connection with a settlement

agreement among Florida, Reynolds, and Philip Morris. The Profit Adjustment

formula has been in place since the Florida Judgment in 1998, and a separate

agreement between the Settling Defendants dictates allocation of the Profit

1 ITG Brands, LLC v. Reynolds Am., Inc., 2022 WL 4678868 (Del. Ch. Sept. 30, 2022) (“2022 Op.”); ITG Brands, LLC v. Reynolds Am., Inc., 2023 WL 6383240 (Del. Ch. Oct. 2, 2023) (“2023 Op.”). 2 2022 Op. at *20. 3 2023 Op. at *23. 4 Id. C.A. No. 2017-0129-LWW April 1, 2024 Page 3 of 7

Adjustment among them.5 In general, the Profit Adjustment “applies if the Settling

Defendants’ aggregate net operating profits from domestic sales of cigarettes in the

current year exceed aggregate inflation-adjusted ‘base year’ profits from a 1997

base year.”6 It is intended to “ensure[] that if the Settling Defendants’ post-

settlement shipment volumes decrease but their profits increase, settlement

payments increase as well.”7

In Philip Morris’s view, assessment of the Profit Adjustment at trial

implicates its own interests. On October 31, 2023, Philip Morris moved to

intervene in this action so that it could advance an unjust enrichment claim against

ITG and Reynolds.8 It argues that since the “aggregate portion of the Profit

Adjustment payment allocated to Reynolds was reduced (because ITG did not join

the Florida Settlement), the portion allocated to Philip Morris was increased by the

exact same amount.”9

5 ITG Brands, LLC’s Combined Opening Br. in Supp. of Mot. for Summ. J. on Remedies and Answering Br. in Opp’n to Reynolds’ Mot. for Summ. J. (Dkt. 343) Ex. 5 at App. A; Id. Ex. 8. 6 2023 Op. at *3. 7 Id. 8 Id.; see Philip Morris USA, Inc.’s [Proposed] Compl. in Intervention (Dkt. 396). 9 Philip Morris USA, Inc.’s Mot. to Intervene (Dkt. 396) (“Mot.”) ¶ 13. C.A. No. 2017-0129-LWW April 1, 2024 Page 4 of 7

After Reynolds and ITG opposed the motion,10 Philip Morris filed a reply,11

and oral argument was held on February 5, 2024.12

II. ANALYSIS

Court of Chancery Rule 24 allows intervention by right or by permissive

intervention.13 Rule 24(a)(2) requires the court to permit intervention when the

movant “claims an interest relating to the property or transaction” at issue and “is

so situated that disposing of the action may as a practical matter impair or impede

the movant’s ability to protect its interest, unless existing parties adequately

represent that interest.”14 Rule 24(b)(1)(b) permits intervention as a matter of the

court’s discretion when the movant “has a claim or defense that shares with the

main action a common question of law or fact.”15 Philip Morris argues that either

provision provides a means for it to intervene.

10 Reynold’s Opp’n to Philip Morris USA Inc.’s Mot. to Intervene (Dkt. 401); ITG Brands, LLC’s Opp’n to Philip Morris USA Inc.’s Mot. to Intervene (Dkt. 403). 11 Dkt. 409. 12 Dkt. 410; see Tr. Of Oral Arg. on Philip Morris USA Inc.’s Mot. to Intervene (Dkt. 411) (“Hr’g Tr.”). 13 Ct. Ch. R. 24. 14 Ct. Ch. R. 24(a)(2). 15 Ct. Ch. R. 24(b)(1)(b). C.A. No. 2017-0129-LWW April 1, 2024 Page 5 of 7

Intervention of right and permissive intervention require a “timely

motion.”16 “Timeliness is a flexible concept, requiring consideration of all the

circumstances of a particular case.”17 A timeliness determination is fact specific

and discretionary.18 The court’s analysis is driven by two factors: “the

inexcusableness of the delay and the prejudice to existing parties.” 19 Neither

supports granting Philip Morris’s motion.

First, Philip Morris’s delay is inexcusable. “[C]ourts have generally been

reluctant to allow intervention when the applicant appears to have been aware of

the litigation but has delayed unduly in seeking to intervene.”20 Philip Morris

could have sought intervention long before now and offers no reason for its failure

to do so.21

16 Ct. Ch. R. 24(a), (b). 17 Dugan v. Dineen, 1990 WL 82719, at *5 (Del. Ch. June 12, 1990). 18 GMF ELCM Fund L.P. v. ELCM HCRE GP LLC, 2021 WL 4313430, at *10 (Del. Ch. Sept. 22, 2021) (quoting Great Am. Leasing Corp. v. Republic Bank, 2003 WL 22389464, at *1 (Del. Ch. Oct. 3, 2003)). 19 Id. 20 Great Am. Leasing, 2003 WL 22389464, at *1 (quoting 7C Charles Alan Wright, Arthur R. Miller & Mary Kay Kane, Federal Practice and Procedure § 1916 (2d ed. 1986)). 21 See In re Reinz Wisconsin Gasket, LLC, 2023 WL 4986411, at *4 (Del. Ch. Aug. 3, 2023) (denying intervention where the movant “was aware of its interest in [the] litigation and the steps needed to directly protect those interests” but offered “no justification for its delay”). C.A. No. 2017-0129-LWW April 1, 2024 Page 6 of 7

Philip Morris’s delay is measured in years. It entered its appearance in this

action in February 2017, in connection with the first motion hearing before

Chancellor Bouchard.22 The thrust of its present motion is that it has been wrongly

losing funds under the Profit Adjustment allocation since the Florida Judgment was

entered in 2018.23 Nothing prevented Philip Morris from arguing—in Florida or

Delaware—that ITG inequitably retained funds belonging to Philip Morris due to

the Profit Adjustment. At the most generous, Philip Morris could have intervened

after ITG was found liable to Reynolds in my 2022 Opinion.24 Yet Philip Morris

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Bluebook (online)
ITG Brands, LLC v. Reynolds American Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/itg-brands-llc-v-reynolds-american-inc-delch-2024.