RealWheels Corp. v. Crossan

2021 IL App (1st) 120809-U
CourtAppellate Court of Illinois
DecidedJune 21, 2021
Docket1-12-0809
StatusUnpublished

This text of 2021 IL App (1st) 120809-U (RealWheels Corp. v. Crossan) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
RealWheels Corp. v. Crossan, 2021 IL App (1st) 120809-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (1st) 120809-U No. 1-20-0809 June 21, 2021

FIRST DIVISION

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

IN THE

APPELLATE COURT OF ILLINOIS

FIRST DISTRICT

REALWHEELS CORPORATION, ) Appeal from the Circuit Court ) Of Cook County. Law Division Plaintiff-Appellant, ) ) v. ) ) The Honorable JOHN R. CROSSAN and CROSSAN ) Patrick J. Sherlock, INTELLECTUAL PROPERTY LAW, LLC ) Judge Presiding. ) Defendant-Appellee. )

JUSTICE WALKER delivered the judgment of the court. Justice Hyman and Justice Coghlan concurred in the judgment.

ORDER

¶1 Held: The circuit court's order granting summary judgment to defendants is affirmed where the defendants presented evidence that plaintiff had not sustained damages, and the plaintiff did not present evidence of a reasonable basis for calculating damages or an affidavit explaining the additional discovery needed to prove damages.

¶2 RealWheels Corporation sued John Crossan for legal malpractice, alleging that

RealWheels lost the rights to patent an invention because Crossan failed to file a timely patent

application. The circuit court granted summary judgment in favor of Crossan based on a No. 1-18-0812

finding that RealWheels could not prove damages. RealWheels argues that the court should

not have entered summary judgment, the court improperly shifted the burden of production,

and the court relied on inadmissible materials as evidence. We find that RealWheels failed to

refute Crossan’s evidence that RealWheels suffered no damages. Accordingly, we affirm the

circuit court’s judgment.

¶3 I. BACKGROUND

¶4 RealWheels sold aerodynamic wheel covers, used mostly on trucks to improve gas

mileage. In 2016, RealWheels invented a “twist and lock” wheel cover that drivers could

install without tools. Two competitors, FlowBelow and Deflektor, also invented wheel covers

drivers could install without tools. The three competitors used significantly different

mechanisms for their wheel covers. FlowBelow and Deflektor obtained patents for their wheel

covers.

¶5 In February 2016, Crossan, as RealWheels’s attorney, filed a provisional application for a

patent for the twist and lock wheel covers. When filing a revision of the provisional

application, Crossan promised to remind RealWheels in January 2017 that RealWheels would

need to file a regular patent application by February 15, 2017. January and February 2017

passed with no contact between Crossan and RealWheels. In February 2018, after Crossan

had retired, John Polka, president of RealWheels, discovered that no regular patent application

had been filed. Polka spoke with new attorneys to determine whether RealWheels could take

any steps to get twist and lock wheel covers patented. The attorneys informed Polka that

RealWheels had lost the opportunity to patent its twist and lock invention. RealWheels filed

its complaint against Crossan in April 2018.

2 No. 1-18-0812

¶6 Crossan filed his motion for summary judgment in November 2019, after the date set for

completion of fact discovery, but before the parties finished deposing expert witnesses.

Crossan chose not to depose RealWheels’s expert witnesses. Crossan appended to his motion

for summary judgment Polka’s deposition. Polka testified that he tried to sell his twist and

lock wheel covers to two trucking companies, International and Schneider. International chose

FlowBelow’s wheel covers, and Schneider chose Deflektor’s. Polka admitted that no one from

FlowBelow or Schneider told him why they did not purchase RealWheels’s products. Polka

“would have to speculate” about the reasons International and Deflektor chose to buy the other

wheel covers. Polka admitted that he explained the twist and lock invention in a brochure and

in RealWheels’s internet postings, and “all the people who look at the internet and see [the]

brochure, anyone who wants to in the entire world can just copy it” because RealWheels has

no patent. Polka did not know whether anyone had copied the invention.

¶7 RealWheels’s sales of twist and lock wheel covers fell from $198,000 in 2016 to $111,000

in 2017 and $110,000 in 2018. In his deposition, Polka said sales fell because RealWheels

stopped pushing the product once it discovered the patent problem. Crossan pointed out that

Polka said he discovered the patent problem in February 2018, well after RealWheels’s sales

of the product had sharply decreased.

¶8 Crossan argued that Polka’s deposition showed RealWheels had not suffered any damages

due to the failure to file the patent application. RealWheels, in its response to the motion for

summary judgment, did not present any affidavits from its experts, and it did not present a Rule

191(b) affidavit explaining its need for further discovery. Ill. S. Ct. R. 191(b) (eff.). The

3 No. 1-18-0812

circuit court granted Crossan’s motion for summary judgment and later denied RealWheels’s

motion for reconsideration. RealWheels now appeals.

¶9 II. ANALYSIS

¶ 10 RealWheels contends that the circuit court should not have entered summary judgment in

favor of Crossan, the court considered inadmissible materials and improperly shifted the

burden of production, and the court should have granted RealWheels’s motion for

reconsideration.

¶ 11 The circuit court should enter summary judgment only “when the pleadings, depositions,

admissions, and affidavits fail to establish a genuine issue of material fact, thereby entitling

the movant to judgment as a matter of law.” General Auto Service Station v. Maniatis, 328 Ill.

App. 3d 537, 543 (2002). “A defendant who moves for summary judgment may meet its initial

burden of production in at least two ways: (1) by affirmatively disproving the plaintiff's case

by introducing evidence that, if uncontroverted, would entitle the movant to judgment as a

matter of law (traditional test) (citation), or (2) by establishing that the nonmovant lacks

sufficient evidence to prove an essential element of the cause of action (Celotex test). (***

Celotex Corp. v. Catrett, 477 U.S. 317, 323, 106 S.Ct. 2548, 2552, 91 L.Ed.2d 265, 273 (1986)

***).” Williams v. Covenant Medical Center, 316 Ill. App. 3d 682, 688 (2000). We review the

order granting summary judgment de novo. In re Estate of Rennick, 181 Ill. 2d 395, 401 (1998).

¶ 12 RealWheels characterizes Crossan’s motion as a Celotex motion, challenging RealWheels

to produce evidence of damages, but Crossan relies on Polka’s deposition as proof that

RealWheels suffered no compensable damages. “Inasmuch as the damages claimed by

defendant, as set forth in his examination before trial, are neither actual nor ascertainable and

4 No. 1-18-0812

are speculative in nature, he failed to establish a prima facie case of legal malpractice.” Collard

& Roe, P.C. v. Vlacancich, 6 Misc. 3d 17, 18–19, 789 N.Y.S.2d 599, 600 (2004); see IGEN,

Inc. v. White, 250 A.D.2d 463, 464-65 (1998) (“What plaintiff's argument overlooks is that it

has sustained no injury unless there has been an infringement against which its patent would

have afforded a right of recovery”). We find the evidence supporting the motion sufficient to

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Related

Williams v. Covenant Medical Center
737 N.E.2d 662 (Appellate Court of Illinois, 2000)
General Auto Service Station v. Maniatis
765 N.E.2d 1176 (Appellate Court of Illinois, 2002)
Arthur v. Lutheran General Hospital, Inc.
692 N.E.2d 1238 (Appellate Court of Illinois, 1998)
In Re Estate of Rennick
692 N.E.2d 1150 (Illinois Supreme Court, 1998)
Robidoux v. Oliphant
775 N.E.2d 987 (Illinois Supreme Court, 2002)
Astech International, LLC v. Husick
676 F. Supp. 2d 389 (E.D. Pennsylvania, 2009)
Meriturn Partners, LLC v. Banner and Witcoff, Ltd.
2015 IL App (1st) 131883 (Appellate Court of Illinois, 2015)
IGEN, Inc. v. White
250 A.D.2d 463 (Appellate Division of the Supreme Court of New York, 1998)
Collard & Roe, P.C. v. Vlacancich
6 Misc. 3d 17 (Appellate Terms of the Supreme Court of New York, 2004)

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Bluebook (online)
2021 IL App (1st) 120809-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/realwheels-corp-v-crossan-illappct-2021.