L3Harris Technologies, Inc. v. Moog Inc.

CourtDistrict Court, M.D. Florida
DecidedFebruary 24, 2025
Docket6:24-cv-00602
StatusUnknown

This text of L3Harris Technologies, Inc. v. Moog Inc. (L3Harris Technologies, Inc. v. Moog Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
L3Harris Technologies, Inc. v. Moog Inc., (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

L3HARRIS TECHNOLOGIES, INC.,

Plaintiff,

v. Case No: 6:24-cv-602-JSS-RMN

MOOG INC.,

Defendant. ___________________________________/ ORDER Plaintiff, L3Harris Technologies, Inc., moves to dismiss the counterclaim (Dkt. 18 at 21–46) filed by Defendant, Moog Inc., for failure to state a claim pursuant to Federal Rule of Civil Procedure 12(b)(6). (Dkt. 20.) Defendant opposes the motion. (Dkt. 24.) For the reasons outlined below, the court denies the motion. BACKGROUND1 The parties work in the aerospace industry. (Dkt. 18 at 21.) Plaintiff is a general contractor with a history of working on projects for the United States government. (Id. at 21–22.) Defendant constructs components for satellites. (Id. at 21, 23–24.) In 2020 and 2021, the parties entered into four contracts. (Id. at 24.) Through the contracts,

1 The court accepts the well-pleaded factual allegations in the counterclaim as true and construes them in the light most favorable to Defendant. See Harry v. Marchant, 291 F.3d 767, 769 (11th Cir. 2002) (en banc). In addition, although the parties’ contracts are not attached to the counterclaim, the court considers the contracts because they are central to Defendant’s claims and their authenticity is not in dispute. See SFM Holdings, Ltd. v. Banc of Am. Sec., LLC, 600 F.3d 1334, 1337 (11th Cir. 2010) (explaining that the court did not err when in ruling on a motion to dismiss, it considered a contract not attached to the complaint because the contract was central to the plaintiff’s claim and its authenticity was not challenged). the parties agreed that in exchange for payment from Plaintiff, Defendant would build satellite components required for two government projects and would deliver the components to Plaintiff. (Id. at 22, 24; see Dkts. 26-1, 26-6, 26-7, 26-9.)

Each contract incorporates Plaintiff’s standard terms. (Dkt. 18 at 24; see Dkts. 26-1, 26-6, 26-7, 26-9.) Each contract includes provisions about payment, the scope of the work to be performed, modification of the contract, changes to the work and equitable adjustments resulting from change orders, limitation of Defendant’s liability to Plaintiff, and Defendant’s responsibility to supervise its own subcontractors. (See,

e.g., Dkt. 26-1 at 15–18, 23, 29.) Each contract also contains a disputes clause, which states that Florida law generally governs the contract and which affords the parties “recourse to an action at law or in equity” to resolve disputes, and a merger clause, which provides that the contract “supersedes any prior offers, negotiations, and

agreements concerning the [contract’s] subject matter . . . and constitutes the entire agreement between the [p]arties.” (E.g., id. at 15, 28.) The contracts’ modification provisions purport to prohibit modification through subsequent course of dealing or oral agreement. (E.g., id. at 17.) Defendant alleges that while it concentrated on constructing satellite

components in accordance with the contracts, Plaintiff demanded that Defendant “make numerous, significant changes to . . . designs and specifications” for the satellite components. (Dkt. 18 at 25–26.) In Defendant’s words, Plaintiff “requested most of these changes orally” and, “in most cases, sought to expand the scope of [Defendant]’s work beyond what had been originally contemplated by the parties.” (Id. at 26.) Defendant attributes the numerous changes to the inadequacy and lack of clarity of Plaintiff’s initial instructions and to Plaintiff’s failure to “anticipate[] the work it would need [Defendant] to perform.” (Id. at 28.) Defendant categorizes the

changes demanded by Plaintiff as either formal or constructive: whereas formal changes went through a process involving written estimates and executed change orders, constructive changes were not memorialized in such writings. (See id. at 25– 31.)

The estimates Defendant prepared for the formal changes described how the changes “would impact the cost of [Defendant]’s overall work and the project’s schedule” and requested that Plaintiff “equitably adjust the . . . price and schedule accordingly.” (Id. at 26.) “More often than not,” Defendant claims, after it presented Plaintiff with an estimate, Plaintiff “demanded that [it] revise the [estimate] to reduce

the proposed cost and schedule impact.” (Id.) According to Defendant, Plaintiff frequently “demand[ed] multiple rounds of revisions until [it] received the terms it wanted.” (Id.) Accordingly, Defendant states, when the terms of the estimates were finalized in corresponding change orders executed by the parties, the change orders “did not reflect the actual costs that [Defendant] incurred in implementing the

changes, or the actual amount of time that such changes required.” (Id. at 28.) Indeed, Defendant claims that the change orders often “departed from the terms that had been agreed upon in the [estimate] or were otherwise inadequate to properly compensate [Defendant] for its time and costs.” (Id. at 27.) Further, in Defendant’s view, “some change orders contained terms that were impossible to achieve.” (Id.) Allegedly, to get Defendant to go along with the revisions, Plaintiff gave Defendant “assurances that [Plaintiff] would ‘make good’ on the additional costs it knew [Defendant] was incurring.” (Id. at 26.) “Based on these assurances,”

Defendant claims, it continued its work and “incurred significant additional costs.” (Id.) As to the constructive changes, Plaintiff allegedly interfered with Defendant’s work by having its employees “communicate directly with” Defendant’s employees “to demand that [Defendant] complete additional tasks beyond [Defendant]’s agreed

scope of work.” (Id. at 29.) According to Defendant, Plaintiff also “improperly contacted [Defendant]’s suppliers . . . without [Defendant]’s permission and without a . . . representative [from Defendant] present.” (Id. at 30.) The government projects experienced significant delays, which the parties

attribute to one another. (See Dkts. 1, 18.) As relevant here, Defendant blames the delays on Plaintiff’s “significant and repeated changes to [Defendant]’s scope of work, refusals to accept reasonable schedule adjustments to accommodate the additional work, and delay in providing necessary parts” to Defendant. (Dkt. 18 at 36.) Given the delays and Defendant’s alleged delivery of satellite components that did not meet

agreed specifications, Plaintiff filed a complaint against Defendant for breaches of the four contracts. (Dkt. 1.) Defendant filed an answer denying any liability to Plaintiff, raising a variety of affirmative defenses (some of which go to the validity of the contracts), and asserting a counterclaim. (Dkt. 18.) In general, Defendant complains in the counterclaim that although it performed its contractual obligations by building and delivering the satellite components, Plaintiff has withheld payment from it and has failed to compensate it for the extra work Plaintiff required it to do. (See id.)

APPLICABLE STANDARDS In deciding a motion to dismiss a counterclaim for failure to state a claim, a court “accept[s] the allegations in the [counterclaim] as true and construe[s] them in the light most favorable to the [defendant].” Henley v. Payne, 945 F.3d 1320, 1326 (11th Cir. 2019). “To survive a motion to dismiss, a [counterclaim] must contain sufficient

factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v.

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