Coronavirus Reporter Corporation v. Apple Inc

Background

The plaintiffs—Coronavirus Reporter Corporation, Calid Inc., and Greenflight Venture Corporation—alleged that Apple monopolized the app-distribution market for its devices through the App Store’s curation and approval process. They alleged that Apple suppressed or excluded apps competing with Apple or its partners and asserted nine claims based on that conduct.

The plaintiffs filed the case in the District of Wyoming on March 3, 2024, filed an amended complaint on July 26, 2024, and later transferred the case to the Northern District of California. Before this court, Apple moved to dismiss. The plaintiffs asked the court to convert Apple’s motion into a motion for summary judgment.

Claim Preclusion

The court applied res judicata, also called claim preclusion. Claim preclusion generally prevents a party from bringing a later case based on the same cause of action when an earlier case involved the same claims, ended in a final judgment on the merits, and involved identical or legally related parties.

The court found all three requirements satisfied. First, the current case and an earlier round of the dispute arose from the same factual basis: both challenged Apple’s App Store curation and approval practices and alleged the suppression or exclusion of competing apps. The court noted that the plaintiffs conceded they had carried over allegations, claims, and injuries from the earlier case.

Second, the court found that the earlier dismissal was a final judgment on the merits. The earlier dismissal was with prejudice, the Ninth Circuit affirmed the dismissal, and there were no further proceedings. The court therefore concluded that the earlier judgment barred a later suit based on the same claims.

Third, the court found sufficient identity or privity among the parties. Calid Inc. and Apple were the same parties in both cases. The court determined that Coronavirus Reporter Corporation was also a party in the earlier case, despite the addition of “Corporation” to its name in the current case. The court further found Greenflight Venture Corporation in privity with the plaintiff in the earlier case because it was described as Dr. Jeffrey D. Isaacs’s solely owned entity.

Disposition

The court granted Apple’s motion to dismiss all of the plaintiffs’ claims with prejudice. It denied as moot the plaintiffs’ request to convert the dismissal motion into a summary-judgment motion.