Sitelink Software, LLC v. Red Nova Labs, Inc.

2016 NCBC 43
CourtNorth Carolina Business Court
DecidedJune 14, 2016
Docket14-CVS-9922
StatusPublished

This text of 2016 NCBC 43 (Sitelink Software, LLC v. Red Nova Labs, Inc.) is published on Counsel Stack Legal Research, covering North Carolina Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sitelink Software, LLC v. Red Nova Labs, Inc., 2016 NCBC 43 (N.C. Super. Ct. 2016).

Opinion

SiteLink Software, LLC v. Red Nova Labs, Inc., 2016 NCBC 43.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF WAKE 14 CVS 9922

SITELINK SOFTWARE, LLC, ) ) Plaintiff, ) ) v. ) ORDER & OPINION ) RED NOVA LABS, INC., ) ) Defendant. ) )

{1} THIS MATTER is before the Court on Plaintiff SiteLink Software, LLC’s Motion to Dismiss Counterclaims of Defendant Red Nova Labs, Inc. (“Motion”), brought under Rule 12(b)(6) of the North Carolina Rules of Civil Procedure (“Rule(s)”). For the reasons discussed below, the Court GRANTS the Motion and DISMISSES the challenged counterclaims without prejudice. Daughtry, Woodard, Lawrence & Starling by Luther D. Starling, Jr. for Plaintiff.

Morningstar Law Group by W. Swain Wood, J. Christopher Jackson, and John T. Kivus for Defendant. Gale, Chief Judge.

I. INTRODUCTION

{2} This lawsuit is between two companies that develop and market facility-management software for the self-storage industry. The dispute centers on the ability of Red Nova Labs, Inc. (“Red Nova”) and its customers to access SiteLink Software, LLC’s (“SiteLink”) application-programming interface (“API”) and underlying database. {3} SiteLink issues licenses to use its API and facility-management software, but conditions those licenses on the user’s agreement not to purchase any product or service from SiteLink’s competitors in the self-storage management- software industry, including Red Nova. {4} SiteLink contends that Red Nova improperly accessed SiteLink’s API by competing with SiteLink while the API license agreement was still in place and by later accessing the API without SiteLink’s consent. Red Nova claims that SiteLink’s API licensing agreement imposes a restraint of trade in violation of North Carolina’s antitrust laws, and that SiteLink has engaged in unfair methods of competition, including tortiously interfering with Red Nova’s contracts.

II. PROCEDURAL HISTORY

{5} SiteLink initiated this action on July 24, 2014, by filing a verified complaint in Wake County District Court. On September 29, 2014, Red Nova filed an answer, counterclaims, and a motion to transfer the matter to Wake County Superior Court. {6} The district court entered a consent order to transfer the case to the superior-court division on October 28, 2014. That same day, Red Nova filed a notice of designation, and the matter was designated as a mandatory complex business case. The case was assigned to the undersigned on October 29, 2014. {7} The Court entered a Consent Preliminary Injunction on May 4, 2015. {8} SiteLink filed its Amended Verified Complaint for Permanent Injunction and Other Relief (“Amended Complaint”) on August 4, 2015. {9} Red Nova filed its answer to the Amended Complaint on August 14, 2015, along with counterclaims for (1) tortious interference with contract, (2) anticipatory repudiation of contract, (3) defamation, and (4) unfair and deceptive trade practices and antitrust violations under sections 75-1, 75-1.1, 75-2, and 75-2.1 of the North Carolina General Statutes, N.C. Gen. Stat. §§ 75-1, -1.1, -2, -2.1 (2015). {10} SiteLink filed its Motion to dismiss some but not all of Red Nova’s counterclaims on September 11, 2015. In particular, the Motion targets Red Nova’s counterclaims that assert violations of sections 75-1, 75-2, and 75-2.1 (the “antitrust claims”); violations of section 75-1.1, to the extent that claim is based on SiteLink’s API licensing agreement; and claims for tortious interference with contract and anticipatory repudiation of contract, to the extent those claims are based on SiteLink’s API licensing agreement. {11} Red Nova filed an amended answer and counterclaims on November 25, 2015, for the sole purpose of amending the factual allegations relating to its defamation claim.1 {12} The Motion has been fully briefed, argued, and is ripe for ruling.

III. STATEMENT OF FACTS

A. The Parties

{13} SiteLink is a North Carolina limited-liability company with a principal place of business located in Wake County, North Carolina. {14} Red Nova is a Kansas corporation with a principal place of business located in Johnson County, Kansas. {15} Both SiteLink and Red Nova provide facility-management software to clients that own or operate self-storage facilities.

B. Facility-Management Software in the Self-Storage Industry

{16} The self-storage industry comprises storage-facility owners and operators who rent storage space to consumers. (Def.’s Am. Answer, Defenses, and Countercls. to Pl.’s First Am. Compl. (“Am. Countercls.”) ¶ 14.) Storage-facility owners and operators use software technology to perform a variety of functions, including internal office tasks and external customer-facing operations. (Am. Countercls. ¶ 15.) {17} Less than half of all self-storage-facility operators use customized, facility-specific management software to manage their internal office functions.

1 SiteLink moved to dismiss the defamation counterclaim in its Motion. After the Motion was filed, Red Nova amended its defamation counterclaim to add more-specific factual allegations. SiteLink has withdrawn its Motion as to that claim. Because the amendment modified only the defamation claim, the Court allowed the parties to proceed with briefing and oral argument on the Motion, even though the filing of an amended pleading ordinarily would moot an earlier-filed motion to dismiss that pleading. Red Nova refers to this type of software as facility-management software (“FMS”).2 (Am. Countercls. ¶ 15.) {18} SiteLink has provided an FMS package since 2006 and currently provides FMS to approximately eleven thousand facility locations, which equals “approximately 35–40% of the addressable market of self-storage facilities in the United States.” (Am. Countercls. ¶ 12.) The Court understands that market to include the portion of self-storage-facility owners or operators that use some type of facility- or business-management software, but not the self-storage facility owners and operators that use less-specialized software, such as a noncustomized database or accounting program. {19} Apart from FMS packages, self-storage-facility owners and operators use Internet-based services, such as lead generation and website design, to increase the number of units rented at their storage facilities. (Am. Countercls. ¶ 15.) For example, a self-storage-facility owner might contract with a third-party company for access to software that compiles information about potential customers.

C. SiteLink’s API

{20} SiteLink does not provide Internet-based services, but it maintains a “Partner” program through which it allows third-party Internet-based-service providers to use its API to access real-time data for mutual customers. (Am. Countercls. ¶¶ 27–29.) The API facilitates communication between software applications, which allows the third-party companies to provide services to SiteLink and the third-party companies’ mutual customers (e.g., a website that contains payment functions and integrates with SiteLink’s FMS). {21} Use of the API is subject to SiteLink’s licensing terms. (Am. Countercls. ¶¶ 28–30.)

2 SiteLink refers to its management software as business-management software, or BMS, rather

than FMS. For purposes of this Order & Opinion, the labels “FMS” and “BMS” refer to the same type of software. {22} When Red Nova began its operations in 2009, it offered only online- marketing and website-design services. By 2011, Red Nova had begun to offer other online services, including Internet-based lead generation. (Am. Countercls. ¶ 16.) At that time, Red Nova used SiteLink’s API to provide Internet-based services to SiteLink’s FMS customers but did not offer its own FMS platform. (Am. Countercls.

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Bluebook (online)
2016 NCBC 43, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sitelink-software-llc-v-red-nova-labs-inc-ncbizct-2016.