OmegaGenesis Corp. v. Mayo Foundation, No. 15-3346 (8th Cir. 2017)
Annotate this CaseOmega filed suit against Mayo, alleging claims of fraud, negligent misrepresentation, breach of contract, and breach of the implied covenant of good faith and fair dealing. The parties had entered into an Exclusive Patent License Agreement in which Omega, a start-up company, agreed to, among other things, pursue Mayo's pending patent application. After the patent application was abandoned when the U.S. Patent and Trademark Office denied an elected group of claims as anticipated by prior art, Omega alleged damages because it relied on Mayo's pre-Agreement false representations. The court concluded that the Agreement and the patent application file squarely contradict Omega's general, conclusory allegation of reasonable reliance. Therefore, the district court properly dismissed these claims grounded in fraud for failure to state plausible claims of reasonable reliance. Accordingly, the court affirmed the judgment.
Court Description: Loken, Author, with Riley and Benton, Circuit Judges] Civil case - Fraud. The parties' agreement and defendant's patent application file squarely contradict plaintiff's general, conclusory allegation of reasonable reliance, and the court properly dismissed the claims grounded in fraud for failure to state plausible claims of reasonable reliance.
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