Tension Envelope Corp. v. JBM Envelope Co., No. 16-3728 (8th Cir. 2017)
Annotate this CaseTension Envelope filed suit against JBM, its former supplier, for selling directly to its customers after promising not to do so. The court affirmed the district court's grant of summary judgment to JBM on the breach of contract claim because no enforceable requirements contract existed between the companies; on the promissory estoppel claim based on the statute of frauds; on the fraudulent misrepresentation claims; on the fraudulent nondisclosure claim where JBM had no duty to disclose its plans to market envelopes; on the tortious interference claim where there was no evidence Tension used improper means to sell to plaintiff's customers; the unfair competition claim; and the misappropriation of trade secrets claim under Missouri law.
Court Description: Gruender, Author, with Wollman and Melloy, Circuit Judges] Civil case - Contracts. The district court did not err in determining defendant did not breach a requirements contract by selling directly to plaintiff's customers, as there was no enforceable requirements contract between the plaintiff and defendant; the Missouri statute of frauds barred plaintiff's claim under the doctrine of promissory estoppel; with respect to plaintiff's claim for material misrepresentation, assuming for the sake of argument that plaintiff could show falsity of a statement that defendant was a "trade-only manufacturer," it could not show that it had any right to rely on the statement, especially where it repeatedly asked for, and defendant repeatedly refused to sign, a non-compete agreement; the other statements plaintiff relied on also failed to meet the test for fraudulent misrepresentation; defendant had no duty to disclose its plans to market envelopes directly and plaintiff's fraudulent nondisclosure claim was properly rejected; there was no evidence defendant used improper means to sell to plaintiff's customers - such as threats, violence or defamation - and plaintiff failed to state a claim for tortious interference; plaintiff failed to support its claim of unfair competition; the information upon which plaintiff based its claim for misappropriation of trade secrets - identity of customers and their requirements - did not qualify as trade secrets under Missouri law.
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