KMC Systems, Inc. v. Biomerieux, Inc.

Superior Court of Delaware·Decided September 17, 2026·No. N25C-12-451 KMM CCLD·Published

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

KMC SYSTEMS, INC., )

)

Plaintiff, )

) C.A. No. N25C-12-451 KMM v. ) (CCLD)

)

BIOMÉRIEUX, INC., )

)

Defendant. )

Date Submitted: June 5, 2026 Date Decided: September 17, 2026

Upon Defendant’s Partial Motion to Dismiss – GRANTED

MEMORANDUM OPINION AND ORDER

Ethan H. Townsend (argued), Taylor A. Christensen, MCDERMOTT WILL & SCHULTE LLP, Wilmington, Delaware, Daniel R. Campbell, MCDERMOTT WILL & SCHULTE LLP, Chicago Illinois, Attorneys for Plaintiff.

Steven L. Caponi (argued), K&L GATES LLP, Wilmington, Delaware Attorneys for Defendant.

Miller, J.

I. INTRODUCTION

Plaintiff KMC Systems, Inc. (“KMC”) and Defendant bioMérieux, Inc.

(“bioMérieux”) entered into a Master Services Agreement (the “MSA” or

“Agreement”), pursuant to which KMC manufactured certain products for

bioMérieux. After a dispute arose, the parties terminated the MSA through a

termination agreement, in which KMC preserved its pricing claim.

KMC asserts three counts: breach of contract based on the MSA (Count I),

breach of contract based on the termination agreement (Count II), and unjust

enrichment (Count III).

This dispute centers on whether the parties’ agreement requires a purchase

price adjustment (or true-up) for increased raw material costs after the product was

delivered and invoiced. bioMérieux moves to dismiss the MSA contract claim,

arguing that the Agreement does not provide for a post-performance payment

mechanism. bioMérieux moves to dismiss the unjust enrichment claim, arguing that

it cannot survive because the parties’ relationship is governed by an express contract.

In determining whether the Agreement creates a purchase price adjustment

obligation, as alleged by KMC, the Court looks to the parties’ contract. The MSA

and related agreements simply do not create such an obligation. Thus, Count I fails

to state a claim. Because KMC’s unjust enrichment claim is premised on the same

alleged price adjustment obligation arising from a relationship governed by a

contract, that claim likewise cannot survive. Accordingly, bioMérieux’s motion is

GRANTED.

II. FACTUAL BACKGROUND 1 0F

A. The MSA

On July 10, 2020, KMC and bioMérieux entered into the MSA. 2 At that time, 1F

KMC manufactured mass spectrometry diagnostic instruments and related ancillary

components and software components (collectively the “Product”) for bioMérieux. 3 2F

Under the MSA, KMC agreed to serve as the exclusive manufacturer and

supplier of the Product, and bioMérieux agreed to purchase the Product from KMC. 4 3F

The MSA established a contractual framework governing how the parties forecasted

demand, placed purchase orders, addressed price, made payment, and administered

their ongoing commercial relationship. 5 4F

The process began with forecasting. Every quarter, bioMérieux was required

to issue a twelve-month forecast for the Product, with the first three months being a

Binding Forecast and the remainder was a Non-Binding Forecast. 6 The forecasts 5F

were updated monthly. 7 Section 4.1 further provided that “[t]he Non-Binding 6F

1 The facts are derived from the Complaint (D.I. 1) and the documents incorporated therein by reference. 2 Compl. ¶ 24. 3 Id. 4 Id. 5 Compl., Ex. A - MSA, § 4, 9, 10. 6 Capitalized terms not defined herein have the meaning ascribed to them in the MSA. 7 MSA, § 4.1.

Forecast shall be used to determine material release quantities to be authorized by

bioMérieux which will be used in the Unit price calculations per Appendix 6.” 8 The7F

forecast “exclude[ed] Spare Parts.” 9 8F

The parties also agreed to an ordering process. KMC was required to sell

quantities of the Product “as may be ordered by bioMérieux.” 10 bioMérieux placed 9F

a purchase order for the Product, which may specify the Product description,

quantity, delivery date, and delivery instructions. 11 Section 4.4.3 required KMC to 0F

“communicate regularly with bioMérieux regarding supply levels and KMC’s ability

to meet the Binding and Non-Binding Forecasts and placed purchase orders.” 1211F

Next, Section 9.1 set forth the parties’ pricing, invoicing, and payment

terms. 13 It required KMC to sell the Product to bioMérieux at the prices quoted in 12F

Appendix 6 and render invoices following delivery of Products. 14 Payment for 13F

approved and undisputed invoices was due “within forty-five (45) days of receipt of

such invoice.” 15 Section 9.2 directed KMC to provide a breakdown of the costs of 14F

8 Id. 9 Id. 10 Id. 11 Id. 12 Id., § 4.4.3. 13 Id., § 9.1. 14 Id., § 9.1.1, 9.1.2. 15 Id., §§ 9.1, 9.1.3.

the Product as of the Effective Date of the MSA “in order for the Parties to monitor

their relationship in the long term.” 16 15F

Finally, the MSA established additional mechanisms governing the parties’

ongoing commercial relationship. Foreseeing that “processes used for the

manufacture of the Products [were] likely to improve during the Term of [the]

Agreement to their mutual benefit,” the parties agreed to establish a Productivity

Program “designed to share the economic benefits thereof with bioMérieux.” 17 The 16F

parties agreed to meet quarterly during the Initial Term 18 and at least annually 17F

thereafter, “to review the compliance of the Parties with the terms of this

Agreement” and “to discuss perspectives, methods, and improvements to be

implemented during the coming year.” 19 18F

B. Appendix 6 - Unit Transfer Price and Rate Sheet

The prices at which KMC was required to sell the Product to bioMérieux were

set forth in Appendix 6 to the MSA, which contained four principal components. 20 19F

First, it established pricing in a table organized by Unit Count and Build Duration.

Second, it set forth provisions governing the establishment and adjustment of prices.

Third, it allocated responsibilities for monitoring raw material costs and

16 Id., § 9.2. 17 Id., § 9.3. 18 The Initial Term was three years. 19 MSA, § 10.1. 20 MSA, § 1.4. Compl., Ex. A, at 49-50 – Appendix 6.

productivity-based price adjustments. Finally, it provided pricing terms for Spare

Parts.

The appendix contained a pricing chart for three periods based on Unit Count

and Build Duration. 21 Period 1 applied to 1–60 units with a six-month Build 20F

Duration, Period 2 applied to 61–260 units with a twelve-month Build Duration, and

Period 3 applied to 261–500 units with a Build Duration exceeding twelve months. 22 21F

For each period, Appendix 6 identified the total price, which was the total of a

specified Raw Material and Laser Cost (a negotiated markup was applied to each) 23 22F

plus a specified labor cost. 24 These prices were based on 500 units (which later 23F

became known as “Lot 1”) and was to remain in effect through delivery of these

Products. 25 Appendix 6 went on to state that the prices were subject to the following 24F

conditions:

• Raw material cost is calculated from the master [Bill of Materials “BOM”] spreadsheet that is maintained by KMC. • Adjustment of material or labor costs for changes due to Engineering Change Orders[.] • Labor costs and material mark up within each Period are based on achieving Unit Count within the identified Build Duration. If the Unit Count is not ordered for the relevant Period, bioMérieux and KMC will reconcile the unit transfer price annually. 26 25F

21 Appendix 6 at 49.

22 Id.

23 The Raw Material cost remained the same, while the RM factor changed in each of the three periods. 24 Appendix 6 at 49. 25 Id. bioMérieux was not committed to actually purchasing 500 Products. Id. 26 Appendix 6 at 50.

Appendix 6 stated that new prices “will need to be established during Period

3 based on material release quantity, annual volume, and build duration.” 27 The 26F

appendix further provided that, “[n]evertheless, the Parties already acknowledge and

agree that for identical or increased material release quantity, annual volume and

build duration, the eventual increase, if any, should be limited to the Raw Material

and to the KMC hourly [labor] rates not to exceed 5% of the current rates in this

Appendix 6.” 28 The parties agreed that “[f]or supporting that discussion KMC will 27F

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