Caradigm USA LLC v. Pruithealth, Inc., No. 19-11648 (11th Cir. 2020)
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Pruitt is a healthcare provider and Caradigm is in the business of delivering software solutions to healthcare providers. Caradigm filed suit against Pruitt for breach of contract, alleging that Pruitt had anticipatorily breached the parties' contract, entitling Caradigm to the contract's full value, plus interest and attorney's fees. On summary judgment, the district court decided that Pruitt had anticipatorily breached the contract and that Caradigm was thus entitled to the full value of the deal. After a four-day trial, a jury awarded Caradigm $11 million.
The Eleventh Circuit held that the district court did not reversibly err in most of the ways that Pruitt claimed, and thus affirmed the awards of contract damages and fees, as well as the determination that Caradigm is entitled to recover interest on the damages award. However, the court held that the district court erred by compounding the interest, and vacated that award and remanded for the district court to calculate interest in simple terms.
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