Key Tronic Corporation v. Cognitive LLC

CourtDistrict Court, E.D. Washington
DecidedFebruary 10, 2025
Docket2:24-cv-00249
StatusUnknown

This text of Key Tronic Corporation v. Cognitive LLC (Key Tronic Corporation v. Cognitive LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Key Tronic Corporation v. Cognitive LLC, (E.D. Wash. 2025).

Opinion

4 U.S. F DIL ISE TD R I IN C TT H CE O URT EASTERN DISTRICT OF WASHINGTON 5 Feb 10, 2025

SEAN F. MCAVOY, CLERK 7

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF WASHINGTON 10

12 KEY TRONIC CORPORATION, 13 No. 2:24-CV-00249-RLP Plaintiff, 14

15 v. ORDER GRANTING MOTION TO DISMISS IN PART AND DENYING IN 16 COGNITIVE LLC, PART

17 Defendant. 18

19 Before the Court is Defendant Cognitive LLC’s Motion to Dismiss, ECF No. 13, 20 requesting dismissal of Plaintiff Key Tronic Corporation’s complaint. The Court heard 21 22 oral argument on February 5, 2025. Attorney Abigail Staggers appeared for Plaintiff Key 23 Tronic Corporation and attorney Todd Adolphson appeared for Defendant Cognitive LLC. 24 Plaintiff Key Tronic Corporation and Defendant Cognitive LLC entered into a 25 26 Manufacturing Services Agreement (MSA) in December 2020. Key Tronic agreed to 27 manufacture and supply certain thermal printers for Cognitive. The MSA contains an 28 initial price agreement, but also provides terms by which Key Tronic could increase the 1 2 price if costs increased. Pursuant to the terms of the MSA, Key Tronic sent notice to 3 Cognitive of a price increase. According to Key Tronic, Cognitive agreed to pay the 4 5 increased price, later repudiated the agreement, and owed amounts remain unpaid. Key 6 Tronic filed suit alleging Cognitive breached the MSA, asserting three causes of action for: 7 (1) breach of contract and implied covenant of good faith and fair dealing; (2) breach of 8 9 contractual duty to indemnify; and (3) promissory estoppel. 10 Defendant Cognitive moves to dismiss for failure to state a claim under FRCP 11 12 12(b)(6). Cognitive contends the Complaint alleges insufficient facts to support the claims. 13 Specifically, Cognitive argues: (1) the MSA agreement and correspondence related to the 14 claim must be considered; (2) the claim is not ripe under the terms of the MSA; (3) the 15 16 Complaint contains insufficient allegations regarding claims for amounts for Aged and 17 On-Hand Inventory, the price increase, the Purchase Price Variance (PPV) and repudiation 18 19 of the contract; (4) the claim for breach of the duty of good faith and fair dealing does not 20 allege any facts that are not part of the breach of contract claim; (5) the claim for 21 indemnification is not allowed; (6) the claim for promissory estoppel is not allowed; and 22 23 (7) the claim for incidental damages should be dismissed under the terms of the contract. 24 The Court GRANTS the motion to dismiss in part and DENIES in part. Key Tronic 25 26 has alleged sufficient facts to make a plausible claim for breach of contract and implied 27 covenant of good faith and fair dealing, for breach of the contractual duty to indemnify, 28 and, alternatively, for promissory estoppel, and the motion to dismiss is DENIED as to 1 2 those claims. The Court GRANTS the motion to dismiss regarding the request for 3 incidental damages which are precluded by the contract. 4 5 BACKGROUND 6 Key Tronic is a contract manufacturing service provider located in Spokane Valley, 7 8 Washington. ECF 1 at 1-2. Key Tronic specializes in full product assembly, molding, 9 fabrication, and engineering services for complex electro-mechanical products. ECF No. 1 10 at 2, ¶ 2.1. Cognitive LLC is a provider of label, barcode, point of sale, and receipt printers 11 12 located in Illinois. Id. At 1-2. In December 2020, Key Tronic and Cognitive entered into a 13 Manufacturing Services Agreement (MSA), wherein Key Tronic agreed to supply certain 14 15 thermal printers to Cognitive. Id. at ¶ 2.3; ECF No. 13 at 7. 16 According to the MSA, Cognitive agreed to provide Key Tronic with 12-month 17 rolling forecasts for products, which would authorize Key Tronic to purchase needed parts 18 19 and materials but would not be authorization to manufacture products. Id. at 2-3, ¶¶ 2.5, 20 2.6. Key Tronic agreed to provide notice to Cognitive of “Aged Inventory,” consisting of 21 22 parts and materials On-Hand for more than 90 days. Cognitive agreed, at Key Tronic’s 23 option, to either: (1) pay an immediate cash deposit in the amount of the Aged Inventory at 24 cost plus ten percent, plus an inventory storage fee of two percent if Key Tronic retained 25 26 possession; or (2) immediately purchase all of the Aged Inventory at cost plus ten percent, 27 plus packing and shipping costs or scrap costs; or (3) immediately provide Key Tronic 28 with a Proposed Purchase Order to consume the Aged Inventory into manufactured 1 2 product within 30 days. Id. 3 The MSA also provides that either upon its own initiative or upon Cognitive’s 4 5 request, Key Tronic would from time to time provide to Cognitive a written Aged 6 Inventory report detailing the Aged Inventory On-Hand. Id. at 3-4. Cognitive agreed to 7 notify Key Tronic of any good faith disagreement regarding the Aged Inventory report 8 9 within 10 days, and no response indicated acceptance of the report and the reasonableness 10 of Key Tronic’s management of the Aged Inventory. Id. Cognitive agreed that failure to 11 12 provide written notice of any disagreement within 10 days waives the right to dispute the 13 contents of the Aged Inventory report. Id. 14 The MSA requires payment of “all invoices for Products within sixty (60) days of 15 16 the date of the invoice.” ECF No. 14 at 11. The MSA contains an initial price agreement, 17 but also provides terms by which Key Tronic could increase the price if costs increased. 18 19 ECF No. 1 at 4, ¶ 2.8. Section 6e provides: 20 If Supplier’s costs are increased in any way . . . Supplier, at its option, shall 21 prepare and deliver a price update to Buyer. Supplier will provide reasonable documentation to justify the price change. Supplier and Buyer must agree to 22 any price changes in writing in an amendment to the Agreement or Accepted 23 Purchaser Order as appropriate, such agreement will not be unreasonably 24 withheld by Buyer. Notwithstanding any terms in this Agreement which may be to the contrary, any price updates or price increases shall not be applied 25 retroactively to any Accepted Purchase Orders and/or any Purchase Orders 26 previously submitted by the Buyer; and any price updates or price increases shall only apply going forward to any Purchase Orders not yet submitted by 27 the Buyer at the time of the price update(s) or price increase(s), unless 28 otherwise agreed to in writing by the Parties. 1 Id.; ECF No. 14 at 11. 2 3 On January 26, 2023, pursuant to Section 6e of the MSA, Key Tronic sent notice of 4 a price increase to Cognitive. ECF No. 1 at 5, ¶ 2.11. The parties disagree about whether 5 there was agreement to the price increase and, to the extent there was an agreement, the 6 7 date of its application to orders. ECF Nos. 13, 15. The relationship between the parties 8 deteriorated as the parties corresponded about the price increase and related matters. ECF 9 10 Nos. 13 at 7-9; 15 at 3-4. 11 In July 2024, Key Tronic filed a Complaint alleging Cognitive breached the MSA 12 by failing to pay amounts that have been invoiced and are past due, including payments for 13 14 Aged Inventory and amounts related to its price increase. ECF No. 1. Key Tronic alleges 15 damages of: 16 17 • $263,641.50 for Aged Inventory; • $97,469.87 for a Purchase Price Variance (pursuant to the price increase); 18 • $320,388.28 for invoiced products; and 19 • $596,508.32 for On-Hand Inventory; and 20 • Interest of one percent per month on overdue amounts; • Storage costs of two percent per month for Aged Inventory and On-Hand 21 Inventory; 22 • Costs to package and ship or scrap the Aged Inventory and On-Hand Inventory; 23 • Statutory interest as allowed; 24 • Incidental and consequential damages; 25 • Attorneys’ fees and costs.

26 Id. at 13-14.

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Key Tronic Corporation v. Cognitive LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/key-tronic-corporation-v-cognitive-llc-waed-2025.