LIMO GmbH v. VulcanForms Inc.

CourtDistrict Court, D. Massachusetts
DecidedJuly 28, 2025
Docket1:24-cv-12838
StatusUnknown

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

Bluebook
LIMO GmbH v. VulcanForms Inc., (D. Mass. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS __________________________________________ ) ) LIMO GMBH, ) ) Plaintiff ) ) v. ) ) Case No. 24-cv-12838-DJC ) VULCANFORMS INC., ) ) Defendant. ) ) ) __________________________________________)

MEMORANDUM AND ORDER

CASPER, J. July 28, 2025

I. Introduction

Plaintiff LIMO GmbH (“LIMO”) has filed this lawsuit against Defendant VulcanForms Inc. (“VulcanForms”) alleging breach of contract (Count I), breach of the implied covenant of good faith and fair dealing (Count II), unjust enrichment (Count III), and seeking a declaratory judgment (Count IV). D. 1-3. VulcanForms now has moved to dismiss the complaint for failure to state a claim, D. 10. LIMO has moved to remand the matter to state court, D. 7. For the reasons stated below, the Court DENIES LIMO’s motion for remand, D. 7, and ALLOWS VulcanForms’s motion to dismiss, D. 10. II. Standard of Review A. Motion for Remand Upon the filing of a motion to remand, the Court must assess whether it “would have had original jurisdiction of the case had it been filed in [this] court” initially. BIW Deceived v. Loc. S6, Indus. Union of Marine & Shipbuilding Workers of Am., IAMAW Dist. Lodge 4, 132 F.3d 824, 830 (1st Cir. 1997) (quoting Grubbs v. General Elec. Credit Corp., 405 U.S. 699, 702 (1972)). When a plaintiff files an action in state court and the defendant removes it here, the defendant has the burden of establishing that removal to the district court is proper. Danca v. Private Health Care Sys., Inc., 185 F.3d 1, 4 (1st Cir. 1999). The defendant “must therefore make a ‘colorable’ showing

that a basis for federal jurisdiction exists.” Id. (quoting BIW Deceived, 132 F.3d at 832). B. Motion to Dismiss

On a motion to dismiss for failure to state a claim upon which relief can be granted pursuant to Federal Rule of Civil Procedure 12(b)(6), the Court must determine if the facts alleged “plausibly narrate a claim for relief.” Schatz v. Republican State Leadership Comm., 669 F.3d 50, 55 (1st Cir. 2012). Reading the complaint “as a whole,” the Court must conduct a two-step, context-specific inquiry. García-Catalán v. United States, 734 F.3d 100, 103 (1st Cir. 2013). First, the Court must perform a close reading of the claim to distinguish the factual allegations from the conclusory legal allegations contained therein. Id. Factual allegations must be accepted as true, while conclusory legal conclusions are not entitled credit. Id. Second, the Court must determine whether the factual allegations present a “reasonable inference that the defendant is liable for the misconduct alleged.” Id. (quoting Haley v. City of Boston, 657 F.3d 39, 46 (1st Cir. 2011)). In sum, the complaint must provide sufficient factual allegations for the Court to find the claim “plausible on its face.” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). III. Factual Background

The following facts are based on the allegations in the complaint, which the Court takes as true for the purposes of resolving the motions. LIMO is a German company specializing in developing, commercializing, manufacturing, and selling laser and optics systems. D. 1-3 at 5 ¶ 5. VulcanForms is a Massachusetts-based corporation that develops, commercializes, manufactures, uses, leases, and sells additive manufacturing equipment. Id. at 5-6 ¶¶ 2, 9. On or around August 5, 2017, LIMO and VulcanForms entered into an agreement for a joint development program related to laser systems and “optionally opto-mechanical devices” for VulcanForms. Id. at 6 ¶ 10. Both LIMO and VulcanForms satisfied their respective development obligations under

this agreement’s Statement of Work and VulcanForms paid LIMO $460,000. Id. ¶¶ 12-13. The parties also executed an Amended and Restated Development Agreement (“Amended Agreement”), the contract at issue here, which was also effective as of August 5, 2017, to expand the parties’ prior joint development program. Id. ¶ 14; see id. at 19-44. As outlined in Section 2(i) of the Amended Agreement, LIMO agreed not to enter into any relationship or collaborate with any third party in VulcanForms’s “field of use.” Id. at 7 ¶ 17; see id. at 23. Pursuant to this “exclusivity” provision, in exchange for VulcanForms paying LIMO an amount equal to or more than $460,000, LIMO agreed not to “(a) sell or distribute any Technology or products that are similar to or compete with the Program Technology or [VulcanForms]

products resulting therefrom, (b) sell or distribute any products resulting from the Development Program in the [VulcanForms] Field of Use, or (c) grant licenses for others to sell, distribute, or develop such Technology, for a minimum period of two years from May 23, 2018” until May 23, 2020. Id. at 7-8 ¶¶ 18, 21; see id. at 23. At the end of the initial two-year exclusivity period, VulcanForms “may” extend the exclusivity period for a total of nine years if it either “buys an increasing dollar amount of laser systems or other components, products, or services from LIMO” or “pays an amount equal to the minimum profit expectation of LIMO.” Id. at 8 ¶ 22; see id. at 23-24. Section 2(j)(ii) provided the annual Minimum Purchase and the Minimum Profit requirement per year and LIMO’s exclusivity obligation would terminate “45 days after the end of any calendar year” if VulcanForms failed to meet the requirements. Id. at 8-9 ¶¶ 23-24; see id. at 23-24. VulcanForms made purchase orders throughout the applicable year that satisfied the Minimum Purchase amount for Year 3 (May 23, 2020 – May 22, 2021). Id. at 9-10 ¶¶ 26, 29. As alleged, VulcanForms President and Chief Executive Officer Martin Feldmann (“Mr. Feldmann”)

stated in an April 26, 2022 letter that VulcanForms “intend[ed] to continue paying the Minimum Profit amount from Year 4 to Year 9 (May 23, 2027)” and that VulcanForms “shall satisfy its obligations for Minimum Profit payments by paying $350,000 on or before May 23, 2022.” Id. at 10 ¶ 30. VulcanForms paid the Minimum Profit amount in Year 4 (May 23, 2021 – May 22, 2022) and Year 5 (May 23, 2022 – May 22, 2023). Id. at 9-10 ¶¶ 26, 31-32. For Year 6 (May 23, 2023 – May 22, 2024), VulcanForms did not pay either the Minimum Purchase or the Minimum Profit amounts during the exclusivity period. Id. at 10 ¶ 33. In a June 26, 2024 letter, VulcanForms notified LIMO of its intent to terminate the exclusivity period pursuant to Section 2(j) of the Amended Agreement after LIMO had complied with the exclusivity provision for Year 6 (May

23, 2023 – May 22, 2024), noting that “exclusivity obligations will terminate 45 days after the end of this calendar year, or February 14, 2025.” Id. at 11 ¶¶ 34-35. As alleged, LIMO complied with the exclusivity provision of the Amended Agreement from Year 1 through Year 6, continues to comply with the provision and expected to comply until February 14, 2025. Id. at 12 ¶ 40. On or about July 12, 2024, Focuslight Technologies Inc., LIMO’s parent company, sent a demand letter to Mr. Feldmann, demanding $700,000 for the Minimum Profit corresponding with Year 6 in the Amended Agreement. Id. ¶ 43; see id. at 5 ¶ 6. VulcanForms responded to the demand letter and refused to pay the Minimum Profit amount. Id. at 13 ¶ 44. IV.

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LIMO GmbH v. VulcanForms Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/limo-gmbh-v-vulcanforms-inc-mad-2025.