Epic Games, Inc. v. Apple Inc.
- Yvonne Rogers
- 4:20-cv-05640
- U.S. District Court · Northern District of California
- 2
In Epic Games v. Apple, Judge Rogers granted Epic’s motion, dismissing Apple’s interference, conversion, and punitive-damages requests with prejudice.
Apple Inc.’s counterclaims for intentional interference with prospective economic advantage and conversion, and its requests for punitive damages, were dismissed with prejudice; Epic Games, Inc. obtained the ruling on its motion.
What happened
In Epic Games, Inc. v. Apple Inc., Epic asked the court to decide the pleadings in its favor on Apple’s counterclaims.
The court’s opinion cited California decisions stating that a contract breach cannot be turned into a separate interference claim merely by alleging that the breach harmed a business, and that a contractual right to payment alone does not establish conversion.
Judge Yvonne Gonzalez Rogers granted Epic’s motion for judgment on the pleadings. Apple’s counterclaims for intentional interference with prospective economic advantage and conversion, along with Apple’s requests for punitive damages, were dismissed with prejudice.
The detailed version
- Epic Games, Inc. v. Apple Inc. · No. 4:20-cv-05640
- Yvonne Rogers
- Nov. 18, 2020
Background
Epic Games, Inc. was the plaintiff and counter-defendant, and Apple Inc. was the defendant and counterclaimant. Epic filed a motion for judgment on the pleadings, a motion asking the court to rule based on the parties’ pleadings when no material factual dispute in those pleadings requires further proceedings. The motion was fully briefed, and the court heard oral argument on November 10, 2020.
Court’s reasoning
The court stated that its reasons were given during the hearing and confirmed in the written order. It cited California decisions addressing the relationship between contract and tort claims. Those decisions state that a contract breach cannot be transformed into tort liability by claiming that the breach interfered with the promisee’s business. The court also cited authority stating that a contractual right to payment, without more, does not establish conversion, which is an unauthorized exercise of control over property to which another person is entitled.
Ruling
The court granted Epic’s motion for judgment on the pleadings. Apple’s counterclaim for intentional interference with prospective economic advantage, Count IV, and its counterclaim for conversion, Count V, were dismissed with prejudice. Apple’s requests for punitive damages were also dismissed with prejudice. The order was signed by Judge Yvonne Gonzalez Rogers.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.