Amazon.com Services LLC v. Paradigm Clinical Research Institute Inc
2:21-cv-00753
| W.D. Wash. | Mar 29, 2024Background
- Amazon entered into a $20M contract with Paradigm Clinical Research Institute ("Paradigm"), a California entity, in April 2020 to buy 80 million nitrile gloves during the COVID-19 pandemic.
- Amazon alleges the supply agreement was a scam, as Paradigm lacked the ability or intention to deliver FDA-approved gloves; Paradigm's owners included Dr. Dandillaya and de Borbon.
- Paradigm's owners and associated parties allegedly falsified documentation and misrepresented glove sources, using funds from Amazon for personal uses rather than fulfilling the contract.
- Amazon paid a 50% deposit upfront, but only a fraction of gloves was delivered, and subsequent shipments were found nonconforming or falsely represented.
- After failed deliveries and learning of potential fraud, Amazon canceled the order and demanded a refund; Paradigm did not return funds.
- The court had previously allowed limited jurisdictional discovery after initially finding insufficient grounds to establish personal jurisdiction over the Individual Defendants (Dandillaya, de Borbon).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over Individual Defendants | Veil-piercing: Dandillaya and de Borbon are Paradigm's alter ego, thus their contacts should be attributed to Paradigm, which is subject to jurisdiction. | No purposeful direction at Washington; mere business ties to Amazon insufficient. | Court finds prima facie alter ego showing allows jurisdiction over individuals. |
| Breach of contract claim | Individuals should be liable as alter egos of Paradigm. | Only Paradigm contracted; individuals not liable. | Denied motion—sufficient alter ego allegations. |
| Washington Consumer Protection Act (CPA) claim | Pattern of deceptive business practice violates CPA and affects public interest. | No unfair or deceptive acts; no public interest impact. | Denied motion—plausible CPA claim. |
| Fraud & civil conspiracy | Misrepresentations induced contract; conspiracy with Paradigm and others to commit fraud. | Claims duplicative of contract; not specific enough. | Denied motion—fraud and conspiracy plausibly pled. |
| Voidable/fraudulent transfers (WUVTA claim) | Challenged transfers were to insiders without value and left Paradigm unable to pay. | Individuals can't be liable except as alter egos. | Denied motion—plausible alter ego theory pled. |
Key Cases Cited
- Pebble Beach Co. v. Caddy, 453 F.3d 1151 (9th Cir. 2006) (Plaintiff bears burden of establishing personal jurisdiction.)
- Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797 (9th Cir. 2004) (Three-part test for specific jurisdiction.)
- Williams v. Yamaha Motor Co., 851 F.3d 1015 (9th Cir. 2017) (Alter ego doctrine requirements.)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (Plausibility standard for pleadings.)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (Standard for motion to dismiss.)