Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Robo-Team NA, Inc. v. Robotics

United States District Court, District of Columbia

April 26, 2018

ROBO-TEAM NA, INC., Plaintiff,
v.
ENDEAVOR ROBOTICS, et al., Defendants.

          MEMORANDUM OPINION

          TREVOR N. MCFADDEN, UNITED STATES DISTRICT JUDGE.

         Robo-Team NA, Inc., sells tactical ground robotics systems to United States government agencies including all branches of the military, the Department of Homeland Security, and the Federal Bureau of Investigation. Endeavor Robotics competes with Robo-Team for government contracts in this field. According to Robo-Team, Endeavor Robotics hired Sachem, a defense-focused lobbying firm, to spread a false rumor that the Chinese government controls Robo-Team and uses it to steal military technology from the United States. Robo-Team has sued Endeavor Robotics and Sachem for defamation, tortious interference with contractual and other business relationships, civil conspiracy, and unfair competition. Both Defendants moved to dismiss Robo-Team's claims under the Federal Rules of Civil Procedure. Both Defendants also argued that Robo-Team's lawsuit is a Strategic Lawsuit Against Public Participation, or SLAPP, and have moved to dismiss the case under the District of Columbia's Anti-SLAPP statute, which provides for the recovery of costs. Because this Court lacks personal jurisdiction over the Defendants, the motions to dismiss under the Federal Rules of Civil Procedure will be granted and the Anti-SLAPP motions will be dismissed.

         I. BACKGROUND

         Robo-Team is a subsidiary of an Israeli company and has its principal place of business in Gaithersburg, Maryland. Compl. ¶ 8. Endeavor has its principal place of business in Chelmsford, Massachusetts, but conducts business with the United States government in the District of Columbia. Id. at ¶¶ 9, 12. Sachem has its principal place of business in Boston, Massachusetts, but conducts lobbying activities in the District of Columbia. Id. at ¶¶ 10, 13.

         Robo-Team alleges that it has been competing with Endeavor for government contracts since at least 2014, and that Endeavor has been spreading false information about Robo-Team during that time. Id. at ¶¶ 16-17. Robo-Team alleges that Endeavor's “campaign of defamatory statements” intensified after Robo-Team defeated Endeavor in a competition for a particularly significant contract with the Air Force in 2015 and then declined Endeavor's proposals to partner on future federal bids and other projects. Id. at ¶¶ 17-19.

         In late 2016 and early 2017 the Army began the competitive process for awarding two of the biggest robotics contracts offered by the military in the last 15 years. Id. at ¶¶ 20-21. Each contract was worth hundreds of millions of dollars. Id. Robo-Team alleges that Endeavor hired Sachem to damage Robo-Team's reputation and prevent it from competing successfully for these contracts, for other business, and for future federal contracts, including one contract that is expected to have a value of approximately $1 billion. Id. at ¶ 24. Sachem prepared a memorandum that was distributed on Capitol Hill and that included in its discussion of “Foreign Threats” a description of Robo-Team's alleged connections with China and alleged violation of International Traffic in Arms Regulations. Id. at ¶ 23; see also Id. Ex. 1.

         The allegations in Sachem's memorandum were repeated in a letter from Congressman Seth Moulton to Frank Kendall, the Undersecretary of Defense for Acquisition, Technology, and Logistics, asking that “the Department of the Army . . . carefully examine the evidence of Chinese influence when considering award of [the two major contracts mentioned above].” Id. at ¶¶ 27-29; see also Id. Ex. 2. They also appear to be echoed in a letter to Undersecretary Kendall that was signed by six other Members of Congress and circulated with supporting materials about Robo-Team's connections with China. Id. at ¶¶ 31-33; see also Id. Ex. 3. At least one Endeavor employee told one of Robo-Team's government contracting customers that the company had been purchased by the Chinese government. Id. at ¶ 25.

         Robo-Team alleges that the rumors Endeavor and Sachem spread damaged Robo-Team's customer relationships and good will, delayed orders and contracts, and forced Robo-Team to spend countless hours on damage control with current and prospective clients. Id. at ¶¶ 37. More specifically, Robo-Team alleged in June 2017 that it was still in the process of responding to a series of complex Requests for Information issued by the Department of State and the Department of Defense in February 2017, that dozens of current and prospective clients had reported concerns about Endeavor's allegations about Robo-Team's connections with the Chinese government, and that it had also had to deal with an inquiry by the Wall Street Journal. Id. at ¶¶ 34-37.

         Robo-Team sued Endeavor and Sachem for defamation, tortious interference with contractual and other business relationships, civil conspiracy, and unfair competition. Id. at 11-14. Before me now are four motions to dismiss, two by each Defendant. Each Defendant has moved under the Federal Rules of Civil Procedure to dismiss Robo-Team's claims for lack of jurisdiction and for failure to state a claim. Each Defendant has also moved to dismiss under the District of Columbia's Anti-SLAPP statute and has requested an award of costs, including attorney's fees, pursuant to that statute.

         II. LEGAL STANDARD

         To hear a claim against a defendant, a court must have personal jurisdiction over that defendant. Under the Due Process Clause, this means that the defendant must “have certain minimum contacts with [‘the territory of the forum, ' which is to say, the geographic area under the court's authority, ] such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Int'l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945). Depending on the defendant's forum contacts, a court's personal jurisdiction over a defendant may be general, allowing the court to hear any claim against the defendant, or specific, allowing the court to hear claims against the defendant only if those claims arise from the defendant's forum contacts. Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011). A plaintiff bears the burden of establishing a factual basis for personal jurisdiction. Crane v. New York Zoological Soc., 894 F.2d 454, 456 (D.C. Cir. 1990).

         III. ANALYSIS

         A. This Court Lacks General Jurisdiction Because the District of Columbia Is Not the Defendants' Place of Incorporation or Principal Place of Business

         A district court may exercise general jurisdiction over all claims against a corporate defendant if the corporation's “affiliations with the State are so continuous and systematic as to render [it] essentially at home” in the territory subject to the court's authority. Daimler AG v. Bauman, 571 U.S. 117, 761 (2014). Although the Supreme Court has not foreclosed the possibility of an “exceptional case, ” a corporation is generally considered to be at home only in the place of its incorporation and in its principal place of business. See Id. & n.19. Endeavor is incorporated in Delaware, and Sachem is incorporated in Massachusetts. Endeavor's Mot. Dismiss, 5; id. Ex. A ¶ 6; Secretary of the Commonwealth of Massachusetts, Business Entity Summary for Sachem Strategies, LLC, available at http://corp.sec.state.ma.us/CorpWeb/ CorpSearch/CorpSummary.aspx?FEIN=001046166&SEARCHTYPE=1 (last accessed April 6, 2018).[1] Robo-Team's own Complaint alleges that both Endeavor and Sachem have their principal places of business in Massachusetts. Compl. ΒΆΒΆ 9-10. And Robo-Team has not argued ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.