Jakubiak v. QuantumScape Corporation

Background

The court had consolidated three cases involving claims against QuantumScape Corporation: the Jakubiak Action, the BJI Action, and the Assante Action. In an earlier related proceeding, the court dismissed Jeffrey Jakubiak’s negligent-misrepresentation claim. The plaintiffs in the BJI and Assante Actions brought their own negligent-misrepresentation claims.

QuantumScape moved to dismiss the negligent-misrepresentation counts in the amended complaint in the BJI Action and the complaint in the Assante Action. The parties relied on briefing and arguments previously submitted in the Jakubiak Action. The opinion states that the main difference among the actions was where the plaintiffs lived and where they took actions related to the dispute: Florida for Jakubiak, and New Jersey or California for the other plaintiffs.

Court’s Analysis

The court determined that New York law applied to the negligent-misrepresentation claims because New York had the greatest interest in the litigation. Under New York law, a negligent-misrepresentation claim requires a special relationship between the plaintiff and the defendant. The court concluded that the plaintiffs did not allege such a relationship with QuantumScape.

Ruling

The court granted QuantumScape’s motion. It dismissed the plaintiffs’ negligent-misrepresentation claims in the BJI and Assante Actions. The court also ordered Jakubiak and the other plaintiffs to file a consolidated complaint by January 21, 2022. The Clerk was directed to close the motion at Dkt. No. 54. The opinion does not specify whether the claim dismissals were with or without prejudice.