Ward v. International Business Machines Corporation

CourtDistrict Court, D. Maryland
DecidedMarch 27, 2025
Docket1:24-cv-00685
StatusUnknown

This text of Ward v. International Business Machines Corporation (Ward v. International Business Machines Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ward v. International Business Machines Corporation, (D. Md. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

* TAMMY WARD, □ Plaintiff, ‘ * v. * Civil No. 24-0685-BAH INTERNATIONAL BUSINESS MACHINES CORPORATION, * Defendant. * * # *& * * * * * * * * * * MEMORANDUM OPINION

Plaintiff Tammy Ward brought suit against International Business Machines Corporation (“IBM”) alleging multiple claims, including breach of contract, unjust enrichment, and violation of the Maryland Wage Payment and Collection Law. ECF 19 (Amended Complaint). Pending before the Court is Defendant’s motion to dismiss (the “Motion”) several of Plaintiffs claims. ECF 20. Plaintiff filed an opposition, ECF 21, and Defendant filed a reply, ECF 22. All filings include memoranda of law, while the complaint and the Motion include exhibits.! The Court has reviewed all relevant filings and finds that no hearing is necessary. See Loc. R. 105.6 (D. Md. 2023). Accordingly, for the reasons stated below, the Motion its DENIED. I. BACKGROUND

A. Scope of Plaintiff's Employment with Defendant — Plaintiff was originally employed by IBM from 1982 until 2014. ECF 19, at 191. In August 2019, Plaintiff was rehired as a senior sales specialist in the Technology Lifecycle Services

! The Court references all filings by their respective ECF numbers and page numbers by the ECF- generated page numbers at the top of the page.

(“Services”) department.” Jd. 42. She reports that she received consistently positive performance evaluations as well as numerous company awards throughout her time working for IBM. /d. at 2 4-10. While employed as a senior Services sales specialist, Plaintiff reported directly to sales manager Ross Biello (“Biello”) and Biello reported to Adam Lawrence (“Lawrence”), General Manager of IBM’s Financial Services Market. ECF 19, at 3 9] 15-16. Plaintiff alleges that Linda York (“York”), Vice President of the company’s Services department for the Americas, was Biello’s “dotted line,” which means that Biello “receive[d] work assignments from and □□□□□□ completed work to [ ] York.” fd. at 417. In 2023, York assumed the role of Vice President of IBM’s Worldwide Services Sales, replacing the previous holder Yasser Eissa, who remained Vice President during the times relevant to the case at hand. Jd. 4 18-19, For her work as a sales specialist, Plaintiff was compensated by a base salary as well as commission earnings. ECF 19, at 3 § 20. Every six months, IBM provided Plaintiff with an “Incentive Plan Letter” (“Incentive Plan’) that detailed her compensation plan for the first and second half of each year. /d. Each Incentive Plan incorporated particular quota amounts, including for primary contracts values and secondary revenue, and calculated Plaintif? s commission payment accordingly. fd. at 3-4 JJ 22~25. Plaintiff avers that none of the Incentive Plans applied to any other compensation program offered by IBM. Id at 4-5 Jf 26-27. In her role as a sales specialist for the Services department, Plaintiff handled transactions “valued at less than $25 million in Maintenance Contract Value.” ECF 19, at 5 28. She did not typically work on deals valued over $25 million, nor did IBM require (even or permit) her to, Id.

' 2 Plaintiff indicates that this department was called “TSS” prior to being renamed in July 2022. ECF 19, at 2 43.

{7 31-32. Instead, where Plaintiff qualified deals above $25 million in value, the Service Department transferred the sales opportunity to a “Complex Solution Executive” and Plaintiff was not compensated for such deals. /d@. 933. Plaintiff avers that a contract’s value is calculated based “on the first three years of a contract.” fd. ]34. When Plaintiff closed on the sub-$25 million contracts that came within the remit of her position, the contract was registered in a database and Plaintiff thereafter received payment on that contract “without any need for prior approval” from IBM. Jd. 35-36. B. Factual Allegations Plaintiffs claims stem from two deals she worked on in 2021 and 2022. ECF 19, at 7 44. me, 1. ADPRedHatDeal . In January 2021, Plaintiff “was assigned to the ADP Red Hat deal” (“Red Hat deal”). ECF’ 19, at 7 945. In the course of early working sessions, executives from ADP asked that the closure of the deal be postponed from the fourth quarter of 2021 to the first quarter of 2022. Jd. at { 47- 50. On January 12, 2022, Plaintiff and other sales specialists in the Service Department received a notification from IBM informing them of a new incentive plan (the “Q1 Incentive”) aimed at bringing pending deals to closure. ECF 19, at 8 | 53. The terms of the Q1 Incentive envisioned that sellers working on existing deals could transfer the lead role on those deals to new sellers and “continue to assist the new seller on the transferred deal, in exchange for receiving a portion of the commission they would have earned if they had remained [lead] on the deal.” Jd. 53-54. Plaintiff stresses that the Q1 Incentive notification announcement did not refer to, incorporate, or use the language of the terms and conditions of any Incentive Plan she had previously received, nor did it reserve any discretionary right of amendment to IBM. Jd. at 8-9 □□

55-64. She further avers that Defendant continues to have “custody and control of all documents concerning” the Q1 Incentive plan. □□□ at 99 65. Pursuant to the Q1 Incentive, Plaintiff agreed to transfer the lead role on the Red Hat deal to another seller, Ed Wetlage. ECF 19, at 9 72. She.attests that she agreed to take up the offered Q1 Incentive because she understood that “she would be compensated” for the extra work performed under the terms of the program. Jd. 68,71. After the Red Hat deal was transferred, Plaintiff continued to assist in completing it even though she was no longer leading the effort to do so. /d at 10977. Plaintiff notes that “Twlorking on deals that were assigned to other sellers was not something [she] was normally required to do” in her role as a sales specialist but reiterates that she did so because she believed she would be compensated for her assistance under the terms of the Q1 Incentive. /d. §{] 78-79. Plaintiff was still listed as a member of the team working on the Red Hat deal as of March 11, 2022. Id. ¥ 80. The Red Hat contract was executed on March 30, 2022 in the amount of $6.2 million. ECF 19, at 11 82. Because the deal was closed within the first quarter of 2022, Plaintiff argues, she was entitled to “a portion of the commission that she would have earned if she had remained the seller on that [ ] contract” pursuant to the Q1 Incentive. Id. { 83. However, despite receiving recognition as a member of the team that brought the deal to completion, see id. at 11-12 " 85— 86, Plaintiff did not receive the promised commission payment, see id. at 14 7 97. 2. JPMorgan Chase Deal On July 1, 2021, Plaintiff was assigned to cover JBM’s account with JPMorgan Chase (“JPMorgan”). ECF 19, at 19 § 134. The previous sales team covering the account had lost a substantial contract with JPMorgan and Plaintiff indicates that she received the assignment in order to “turn around the account” for the company. /d. 7 135-36. Plaintiff notes that she successfully

repaired IBM’s relationship with JPMorgan and secured a one-year technology support contract effective October 1, 2021. fd at 20 J 142. This contract was valued at over $19 million. Jd. In the second quarter of 2022, Plaintiff “initiated conversation” with JPMorgan for “the upcoming one-year renewal” option for the technology services contract. ECF 19, at 20143. As a one-year option, the contract renewal would have been valued at nearly $15 million, a figure within Plaintiffs usual compensation plan “for deals valued at less than $25 million[.]” /d@. 4] 145.

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