Super Micro Computer, Inc. v. R Associates, Inc.
- Jeffrey White
- 4:20-cv-07975
- U.S. District Court · Northern District of California
- 6
In Super Micro Computer v. R Associates, Magistrate Judge Kim recommended default judgment for Super Micro, with $105,668.35 damages and $62,358.81 prejudgment interest.
Super Micro Computer, Inc. would receive the recommended default judgment and monetary award if adopted; R Associates, Inc. would be subject to the recommended judgment. The opinion is a report and recommendation, not a stated final judgment.
What happened
In Super Micro Computer, Inc. v. R Associates, Inc., Super Micro said R Associates ordered equipment, received it, and failed to pay the full amount. Super Micro sought $215,655.85 for breach of contract and related claims. R Associates did not defend the case.
The court found that it had authority over the dispute and R Associates, and that R Associates had been properly served. It also found that Super Micro’s allegations and supporting evidence showed a contract breach. Because R Associates had not participated, the court evaluated the request as a default judgment, which is a judgment against a party that failed to defend itself.
Magistrate Judge Allie Kim recommended granting the default-judgment motion but reducing the requested prejudgment interest to the amount accrued. The recommendation proposed $105,668.35 in damages and $62,358.81 in prejudgment interest. The parties could object within 14 days after service of the recommendation.
The detailed version
- Super Micro Computer, Inc. v. R Associates, Inc. · No. 4:20-cv-07975
- Jeffrey White
- Mar. 15, 2021
Background
Super Micro Computer, Inc. alleged that R Associates, Inc. ordered equipment through four purchase orders between September 14 and October 12, 2018. Super Micro said it shipped the equipment, but R Associates did not pay the full invoice amount. R Associates returned some products and paid $12,591; Super Micro issued a $1,547.75 credit for the returned products. Super Micro alleged that $215,655.85 remained due.
Super Micro asserted claims for breach of contract, account stated, open book account, and quantum valebant. Its standard terms and conditions allegedly provided that R Associates consented to the exclusive jurisdiction of state and federal courts in Santa Clara County, California. R Associates did not litigate the action.
Jurisdiction and service
The court found diversity jurisdiction because the opinion identifies Super Micro as a Delaware corporation with its principal place of business in San Jose, California, and R Associates as a Texas corporation with its principal place of business in Houston, Texas. The amount in controversy exceeded $75,000.
The court also found specific personal jurisdiction over R Associates. It reasoned that R Associates purposefully conducted business in California by contracting with Super Micro, that Super Micro’s claims arose from that transaction, and that the forum-selection provision supported jurisdiction. The court found service adequate because R Associates’s service agent was served on November 20, 2020.
Default-judgment analysis
A default judgment is a judgment entered against a party that failed to defend the case. Applying the factors used to evaluate such a request, the court concluded that Super Micro would likely be left without a remedy if the motion were denied; that the complaint sufficiently alleged a contract breach; and that the requested recovery was tied to the alleged unpaid equipment. The court also noted that the policy favoring decisions on the merits weighed against default judgment, but concluded that the other factors favored entering judgment because R Associates had failed to litigate.
For the contract claim, the court concluded that Super Micro sufficiently alleged and demonstrated that a contract existed, Super Micro performed by providing the equipment, R Associates breached the agreement by failing to pay, and Super Micro suffered damages. Because this was a default-judgment motion, the well-pleaded allegations were treated as true, but the amount of damages still had to be supported.
Recommended remedy and disposition
The report and recommendation recommends granting Super Micro’s motion for default judgment, but reducing the requested prejudgment interest to the amount accrued as of the recommendation. Its conclusion recommends awarding $105,668.35 in damages and $62,358.81 in prejudgment interest. The report also states that Super Micro should serve R Associates with a copy and file proof of service, and that objections could be filed within 14 days after service.
The opinion contains an apparent internal inconsistency: an earlier section says the court recommends awarding $215,655.85 in damages, while the conclusion recommends $105,668.35 in damages plus $62,358.81 in prejudgment interest. The supplied case metadata identifies Jeffrey White as the judge, but the opinion is signed by Allie Kim, United States Magistrate Judge; this summary identifies the signing judicial officer.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.