Bitmain Technologies Georgia Limited v. Hylmen LLC
6:24-cv-03183
W.D. Mo.Jun 16, 2025Background
- The dispute concerns the possession, storage, and storage fees for Bitcoin Miners between Bitmain Technologies Georgia Limited (Plaintiff) and Hylmen, LLC (Defendant), among others.
- Plaintiff is a Georgia corporation; Hylmen, LLC is a Wyoming LLC, and other defendants are residents or corporations in various states.
- Defendant Hylmen filed a First Amended Counter-Petition alleging quantum meruit, unjust enrichment, and constructive contract against Plaintiff.
- Plaintiff moved to dismiss, arguing that an express contract existed between Defendant Hylmen and Blockquarry (a third party), governing the same subject matter.
- Defendant Hylmen did not file a response to the motion to dismiss.
- The case is before the federal district court under diversity jurisdiction, with an amount in controversy exceeding $75,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Quantum meruit & unjust enrichment claims | Existence of express contract with Blockquarry bars quasi-contract claims. | (No response filed.) | Claims dismissed; express contract governs subject matter. |
| Constructive contract claim | Same as unjust enrichment/quantum meruit; barred by existence of express contract. | (No response filed.) | Claim dismissed; recovery must rest on contract alone. |
| Sufficiency of short-and-plain statement | Allegations are conclusory, not enough for relief. | (No response filed.) | Dismissal of Counter-Petition for failure to state a claim. |
| Relationship between parties | No direct contract between Hylmen and Plaintiff, all claims derive from Blockquarry contract | (No response filed.) | Hylmen failed to allege contract with Plaintiff; claims dismissed. |
Key Cases Cited
- Zutz v. Nelson, 601 F.3d 842 (8th Cir. 2010) (complaint must allege facts sufficient to state plausible claim for relief)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions alone do not suffice to state a claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must have enough facts to state a facially plausible claim)
- 32nd St. Surgery Ctr. LLC v. Right Choice Managed Care, 820 F.3d 950 (8th Cir. 2016) (quantum meruit and unjust enrichment are precluded by express contract on same subject)
- Coons v. Mineta, 410 F.3d 1036 (8th Cir. 2005) (facts must be viewed in light most favorable to nonmovant at motion to dismiss stage)