JoySuds, LLC v. N.V. Labs, Inc.

CourtDistrict Court, S.D. New York
DecidedSeptember 13, 2024
Docket1:22-cv-03781
StatusUnknown

This text of JoySuds, LLC v. N.V. Labs, Inc. (JoySuds, LLC v. N.V. Labs, Inc.) 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
JoySuds, LLC v. N.V. Labs, Inc., (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JOYSUDS, LLC, Plaintiff, 22 Civ. 3781 (DEH) v. OPINION N.V. LABS, INC. d/b/a REFORMA GROUP, AND ORDER Defendant.

DALE E. HO, United States District Judge: This case, familiarity with which is presumed, involves claims for breach of a supply agreement and for negligence, gross negligence, and negligent misrepresentation. See Second Am. Compl. (“SAC”), ECF No. 113. Defendant N.V. Labs, Inc. d/b/a Reforma Group (“Reforma” or “Defendant”) moves for judgment on the pleadings, arguing that JoySuds LLC (“JoySuds” or “Plaintiff”) has failed to state a claim for negligence, gross negligence, or negligent misrepresentation. See Mot. for J. on the Pleadings (“Def.’s Motion”), ECF No. 168. For the following reasons, Reforma’s motion is DENIED. BACKGROUND

JoySuds acquired the branding rights to “Joy” dish detergent products in 2019. SAC ¶ 18. Reforma “holds itself out as an experienced and professional contract manufacturer.” Id. ¶ 1. On April 6, 2021, JoySuds and Reforma entered into the Supply Agreement, under which Reforma would manufacture certain Joy products and sell them to JoySuds. Id. ¶¶ 1, 21, 23. The Supply Agreement is sixteen pages long, including signature pages and exhibits, and contains many provisions not immediately relevant to Reforma’s motion. See generally Supply Agreement, ECF No. 40-2. On April 4, 2022, Reforma sent a “Notice of Termination” of the Supply Agreement to JoySuds. See ECF No. 168. JoySuds initiated this action in the Supreme Court of the State of New York, New York County, on April 7, 2022. ECF No. 1. Reforma removed the litigation to federal court in this District on May 10, 2022. Id. On March 31, 2023, the Court entered an Order declining to dismiss JoySuds’ breach of contract claim, but granting Reforma’s motion to dismiss the claims for tortious interference and “Negligence/Gross Negligence” as duplicative of the breach of contract claim. See Order, ECF No. 92.1 The Order also granted JoySuds leave to amend its

pleading. Id. at 32. On May 2, 2023, JoySuds filed the Second Amended Complaint (the “SAC”). The SAC reasserts claims for negligence, gross negligence, and negligent misrepresentation claims.2 Plaintiff argues Reforma had negligently mislabeled the products in question, which “resulted in JoySuds scrambling to determine how many cases of Products were affected, retrieving those Products from retailers, re-labeling the Products, and otherwise handling damage control.” Order ¶ 90. This mislabeling meant that “inventory had to be recalled from distributors[’] and a wholesalers[’] shelves” and “consumer complaints had to be responded to.” Id. ¶ 91. The SAC includes fourteen paragraphs detailing losses resulting from the lack of capacity on Reforma’s part. See id. ¶¶ 102-115.

On October 19, 2023, this case was reassigned to the undersigned. See ECF No. 157. On December 1, 2023, Reforma filed another motion for a judgment on the pleadings. See Def.’s Motion, ECF No. 167.

1 JoySuds, LLC v. N.V. Labs, Inc., No. 22 Civ. 3781 (JPC), 2023 WL 2746772, at *1 (S.D.N.Y. Mar. 31, 2023). 2 Although the SAC is not as clear as it could be in alleging a negligent misrepresentation claim, the Order on the first motion to dismiss construed the First Amended Complaint as alleging a negligent misrepresentation claim. Order 27, ECF No. 92. Given the minimal alterations between the First Amended Complaint (“FAC”) and the SAC, the Court construes Plaintiff as again bringing a negligent misrepresentation claim. LEGAL STANDARDS “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Sacerdote v. N.Y. Univ., 9 F.4th 95, 106 (2d Cir. 2021) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)).3 In assessing the complaint, “[a court] must construe it liberally, accepting all factual allegations therein as true and drawing all reasonable inferences in the plaintiffs’ favor.” Id. at 106-07. The

court must, however, disregard any “conclusory allegations, such as formulaic recitations of the elements of a cause of action.” Id. at 107 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). “The standard for granting a Rule 12(c) motion for judgment on the pleadings is identical to that for granting a Rule 12(b)(6) motion for failure to state a claim.” Lively v. WAFRA Inv. Advisory Grp., Inc., 6 F.4th 293, 301 (2d Cir. 2021). DISCUSSION The Court previously dismissed JoySuds’ negligence claims as duplicative of its contract

claims, because JoySuds had not “adequately alleged its negligence claims stem from any duty independent of the contract or give rise to special damages.” Order at 29 (emphasis added). On this motion, Reforma argues JoySuds’ negligence claims remain duplicative of its breach of contract claim, because the SAC fails to properly allege a duty of care that is independent of the contract between the parties. See generally Motion, ECF No. 167. For the reasons discussed below, the Court determines that the negligence claims are not duplicative, and Reforma’s motion to dismiss is denied. The New York Court of Appeals has noted that where, as here, “the parties’ relationship

3 All references to Rules are to the Federal Rules of Civil Procedure. In all quotations from cases, the Court omits citations, alterations, emphases, internal quotation marks, and ellipses, unless otherwise indicated. initially is formed by contract, but there is a claim that the contract was performed negligently,” the claim “falls in the borderland between tort and contract, an area which has long perplexed courts.” Sommer v. Federal Signal Corp., 593 N.E.2d 1365 (1992). Tort claims that are merely duplicative of a contract claim are generally subject to dismissal. For example, “a fraud claim that arises from the same facts as an accompanying contract claim, seeks identical damages and does not allege a breach of any duty collateral to or independent of the parties’ agreements is

subject to dismissal as redundant of the contract claim.” Cronos Grp. Ltd. v. XComIP, LLC, 64 N.Y.S.3d 186 (N.Y. App. Div. 2017). “It is well settled under New York law that a contract action cannot be converted to one for fraud merely by alleging that the contracting party did not intend to meet its contractual obligations.” Int’l CableTel Inc. v. Le Groupe Videotron Ltee, 978 F. Supp. 483, 487 (S.D.N.Y. 1997) (Sotomayor, J.). In Bridgestone/Firestone, the Second Circuit surveyed New York state case law and determined that, to be “sufficiently distinct” from a contract claim so as to withstand dismissal, a fraud claim must fall into one of three exceptions, including, as relevant here, where the plaintiff seeks special damages on that claim. See Bridgestone/Firestone, Inc. v. Recovery Credit Servs., Inc., 98 F.3d 13, 19-20 (2d Cir. 1996). Although Bridgestone/Firestone was a fraud case, courts

in this District have applied the Bridgestone/Firestone factors in negligent misrepresentation cases like this one.4 Thus the Court’s previous Order, ECF No. 92, relied on

4 See e.g., Serifos Mar. Corp. v. Glencore Singapore Pte Ltd., No. 22 Civ. 8012, 2023 WL 6317996, at *5 (S.D.N.Y. Sept. 28, 2023) (applying the three Bridgestone/Firestone factors but dismissing the intentional misrepresentation and gross negligence claims because they only “vaguely demand damages in an amount to be determined”).

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JoySuds, LLC v. N.V. Labs, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/joysuds-llc-v-nv-labs-inc-nysd-2024.