MyCarrier, LLC v. Project44, LLC

CourtCourt of Chancery of Delaware
DecidedMarch 3, 2025
DocketC.A. No. 2024-0705-KSJM
StatusPublished

This text of MyCarrier, LLC v. Project44, LLC (MyCarrier, LLC v. Project44, LLC) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MyCarrier, LLC v. Project44, LLC, (Del. Ct. App. 2025).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

MYCARRIER, LLC, ) ) Plaintiff, ) Counterclaim Defendant, ) ) v. ) C.A. No. 2024-0705-KSJM ) PROJECT44, LLC, ) ) Defendant, ) Counterclaim Plaintiff. )

MEMORANDUM OPINION

Date Submitted: January 23, 2025 Date Decided: March 3, 2025

Raymond J. DiCamillo, Sandy Xu, Kaitlyn R. Zavatsky, RICHARDS, LAYTON & FINGER, P.A., Wilmington, Delaware; Jeffrey A. Simes, Samuel J. Rubin, Alexandra V. Bargoot, GOODWIN PROCTER LLP, New York, New York; Counsel for Plaintiff and Counterclaim Defendant, MyCarrier, LLC.

Ryan D. Stottman, Taylor A. Christensen, MORRIS, NICHOLS, ARSHT & TUNNELL LLP, Wilmington, Delaware; Lazar Raynal, Barry Kamar, KING & SPALDING LLP, Atlanta, Georgia; Counsel for Defendant and Counterclaim Plaintiff, Project44, LLC.

McCORMICK, C. Plaintiff MyCarrier, LLC licenses application programming interfaces (“APIs”)

from Defendant Project 44, Inc. (“P44”) pursuant to a master services agreement. P44

has moved for a preliminary injunction to prevent MyCarrier from developing its own

version of a functionality that P44’s software provides. P44 also seeks to prevent

MyCarrier from working with a P44 competitor to sell services that P44 offers. This

decision denies the motion.

I. FACTUAL BACKGROUND

The facts are drawn from excerpts of deposition testimony lodged with the

court, 100 exhibits submitted with briefing, and the affidavits of the parties’

competing experts.1

A. Events Leading To The Agreement

P44 is a Chicago-based software-as-a-service company that operates in the

supply-chain management industry. P44’s software transmits information

throughout the shipping industry among shippers, carriers, data providers, and

1 This decision cites to the parties’ submissions in Docket C.A. No. 2024-0705-KSJM

by “Dkt.,” and to the following exhibits submitted with briefing by “Ex.” number: Exs. 1 through 58 to Transmittal Affidavit of Taylor A. Christensen, Dkt. 94; Exs. 59 through 114 to Transmittal Affidavit of Kaitlyn R. Zavatsky, Dkts. 105, 106; Exs. 115 through 125 to P44’s Reply Brief, Dkt. 110. This decision also cites to the Transcript of the Hearing on P44’s Motion for a Preliminary Injunction, Dkt. 123 (“1/23/25 Hr’g Tr.”). The parties submitted as exhibits deposition transcript excerpts (“Dep. Tr.”) of the following witnesses: P44 CTO Parthasarathy Ramachandran, Exs. 2, 64; P44 Senior Product Manager Ilias Pagonis, Exs. 3, 94, 119; P44 CEO Jett McCandless, Exs. 5, 60, 120; MyCarrier CEO Michael Bookout, Exs. 6, 97; and former MyCarrier CRO Charles Thomas Barnes, Exs. 12, 118. Because the court does not rely on the Affidavits of Michael Bookout, John Hess, and Lance Healy (Dkts. 103, 104, and 107), P44’s Motion to Exclude the Affidavits (Dkt. 109) is moot. Transportation Management Systems (“TMS”). 2 P44 transmits this information

through APIs—a set of rules or protocols that allow software systems to communicate

with each other to exchange data, features, and functionality.3

MyCarrier offers a web-based shipping management platform that provides

“one-stop shopping” for “less-than-truckload” (“LTL”) shipments—shipments that are

larger than a parcel but smaller than a full truckload. MyCarrier uses P44’s Freight

API platform to connect carriers and shippers in the supply chain by providing data

and information regarding shipments.4 P44 essentially serves as the pipe through

which MyCarrier accesses the systems of the carriers that it then connects to the

shippers.5

The Freight API has four products: LTL Visibility, LTL Dispatch, LTL Rating,

and LTL Documents.6 LTL Visibility provides shipment tracking capabilities. LTL

Rating allows users to retrieve quotes (i.e., rates) from an array of carriers through a

“one to many” API call, in which P44’s system makes a multitude of API calls to

carriers to retrieve rates data. 7 LTL Dispatch allows shippers to facilitate

2 Project44 – Company, https://www.project44.com/company/ (last visited February

28, 2025); 1/23/25 Hr’g Tr. at 10–11. 3 Ex. 1 ¶ 35.

4 McCandless Dep. Tr. at 31:17–32:5; Ex. 11 (“Agr.”) at -427, “Ex. A: Product Definitions”; 1/23/25 Hr’g Tr. at 10–11. 5 McCandless Dep. Tr. at 288:9–13; Hess Dep. Tr. at 80:5–7.

6 Agr. at -425.

7 Pagonis Dep. Tr. at 50:21–51:2.

2 transactions by automatically sending an “API call” to a carrier’s pickup API.8 LTL

Documents allows parties to upload and share documents related to LTL shipments.9

MyCarrier and P44 first entered into a services contract in 2017 (the “2017

Agreement”).10 Under the 2017 Agreement, P44 provided MyCarrier services at a

steep discount resulting in a negative gross margin. P44’s willingness to support an

early-stage company like MyCarrier was due in part to MyCarrier’s unique network

of connections, which had the potential to expand P44’s network and data feeds into

a lucrative but difficult-to-access market.11

The 2017 Agreement was set to expire in December 2023. In July 2023,

MyCarrier’s CEO Michael Bookout approached P44’s CEO Jett McCandless about

renewing the agreement. McCandless stated that the parties needed to find a way to

bring the MyCarrier account to a positive gross margin for P44.12 McCandless gave

Bookout two options: end the contract and “[s]eparate as friends” so that MyCarrier

“can build APIs directly” or renew the contract for a five-year term with increased

pricing.13 During the meeting, Bookout made it “100 percent” clear that he wanted

to stay with P44.14 And the parties negotiated new terms into the fall of 2023.

8 Id. at 47:1–13; Agr. at -427, “Ex. A: Product Definitions.”

9 Agr. at -427, “Ex. A: Product Definitions.”

10 Ex. 58 ¶ 14.

11 McCandless Dep. Tr. at 90:9–11, 164:4–22, 252:20–253:2, 253:13–15, 284:6–13.

12 Ex. 7 at -247; McCandless Dep. Tr. at 90:4–11.

13 Ex. 7 at -247.

14 Bookout Dep. Tr. at 36:3–5.

3 B. The Proxy Project

Bookout’s representation that he “100 percent” wanted to stay with P44 was

an overstatement. In fact, at the time he made that statement, MyCarrier was

actively looking for ways to replace P44, including by building their own “proxy”

software.15

By July 2023, MyCarrier had begun working on what it called the “LTL Carrier

Proxy Project” (the “Proxy Project”). 16 A July 2023 document bearing that title

outlined MyCarrier’s vision for “[d]eliver[ing] a solution that can be stood up next to

P44 and provide an alternative to their rating and booking services.”17 MyCarrier’s

“solution” was to “incrementally introduc[e] a proxy system that could eventually

replace the P44 system.”18

Customer complaints with P44’s product supplied one of the motivations for

the Proxy Project. According to Bookout, MyCarrier customers were increasingly

complaining about P44’s electronic bill of lading (“eBOL”) functionality.19 EBOL is

the electronic form of paper bills of lading, which are documents populated with

information from a shipper detailing the type, quantity, and destination of the goods

being carried.20 By automatically generating the information needed to effectuate a

15 Ex. 15 (document titled “LTL Carrier Proxy Project”); Ex. 16 at -083, -085 (showing

that MyCarrier was seriously considering not signing the contract with P44). 16 Ex. 15; 1/23/25 Hr’g Tr. at 15, 29.

17 Ex. 15 at -013.

18 Id. at -014.

19 Ex. 73 at -375; Ex. 31 at -090; Bookout Dep. Tr. at 72:8–23.

20 McCandless Dep. Tr.

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Bluebook (online)
MyCarrier, LLC v. Project44, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mycarrier-llc-v-project44-llc-delch-2025.