District Judge Valerie E. Caproni

 

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Plaintiffs were independent contractors for Motor Information Systems Inc. (Motor), a publisher of vehicle service and repair manuals. Many of Motor’s manuals have transitioned to being online products. When Motor discontinued its Motor/Alldata Systems (MAS) online manual, plaintiffs sued for contract breach, fraud in the inducement, and tortious interference with business relations. District Court granted Motor summary judgment dismissing suit. As to their breach claim, the court noted that plaintiffs presented no evidence that their sales territories were changed, or that Motor acted arbitrarily in violation of governing “Independent Sales Distribution Agreements.” Nor did they show Motor to be marketing or selling the manual products handled by plaintiffs within plaintiffs’ sales territories. Further, under the subject agreements, once Motor discontinued MAS, plaintiffs did not make any sales thereof, and were thus not owed commissions thereon. Plaintiffs fraudulent inducement claim related to their contract breach claim, and thus could not be maintained. Nor did the record show Motor owed plaintiffs a separate legal duty or that plaintiffs sought “special damages” unrecoverable in contract.

District Judge Valerie E. Caproni

 

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Plaintiffs were independent contractors for Motor Information Systems Inc. (Motor), a publisher of vehicle service and repair manuals. Many of Motor’s manuals have transitioned to being online products. When Motor discontinued its Motor/Alldata Systems (MAS) online manual, plaintiffs sued for contract breach, fraud in the inducement, and tortious interference with business relations. District Court granted Motor summary judgment dismissing suit. As to their breach claim, the court noted that plaintiffs presented no evidence that their sales territories were changed, or that Motor acted arbitrarily in violation of governing “Independent Sales Distribution Agreements.” Nor did they show Motor to be marketing or selling the manual products handled by plaintiffs within plaintiffs’ sales territories. Further, under the subject agreements, once Motor discontinued MAS, plaintiffs did not make any sales thereof, and were thus not owed commissions thereon. Plaintiffs fraudulent inducement claim related to their contract breach claim, and thus could not be maintained. Nor did the record show Motor owed plaintiffs a separate legal duty or that plaintiffs sought “special damages” unrecoverable in contract.