Syngenta Seeds, Inc. v. Bunge North America, Inc., No. 13-1391 (8th Cir. 2014)
Annotate this CaseSyngenta, producer of a genetically-modified corn seed, filed suit against Bunge, an agricultural produce storage and transport company, alleging breach of an obligation under the United States Warehouse Act (USWA), 7 U.S.C. 241-256; breach of a duty to third party beneficiaries of a licensing agreement between Bunge and the federal government; and false advertising in violation of the Lanham Act, 15 U.S.C. 1125. The court concluded that the text of the USWA and the structure of the Act do not implicitly authorize a private cause of action for violations of a warehouse operator's fair treatment obligations; Syngenta is not a third-party beneficiary of the License Agreement and the district court did not err in dismissing this claim on the pleadings; and the court found it was necessary to remand the Lanham Act claim, in light of Lexmark Int'l, Inc. v. Static Control Components, Inc., for the district court to determine in the first instance whether Syngenta has standing to bring the claim under the zone-of-interests test and proximate causality requirements. Accordingly, the court affirmed the dismissal of the USWA and third-party beneficiary claims, and vacated the grant of summary judgment to Bunge on the Lanham Act claim and remanded for further proceedings.
Court Description: Civil Case - Lanham Act. Action by biotechnology company that produces genetically modified corn may not sue warehouse for damages relating to lost market share, profits and goodwill under the United States Warehouse Act; private right of action is limited to actions with respect to bonds. Neither the text of 7 U.S.C. sec. 247 nor the structure of the USWA demonstrates that Congress intended to imply a private cause of action for violations of a warehouse operator's fair treatment obligation. The district court did not err in dismissing the third-party beneficiary claim under the License Agreement. The district court's grant of summary judgment on a claim of false advertising is remanded for reconsideration in light of the Supreme Court's decision in Lexmark Int'l, Inc. v. Static Control Components, Inc. to determine whether Syngenta has standing to bring a claim under the zone-of-interests test and proximate causality requirement.
The court issued a subsequent related opinion or order on October 20, 2014.
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