BuyFigure.com, Inc. v. Autotrader.com, Inc.
76 A.3d 554
| Pa. Super. Ct. | 2013Background
- Appellant BuyFigure.com developed a guaranteed trade-in invention; Hollenshead, a shareholder and RMH principal, allegedly misused it.
- Hollenshead had an employment agreement with invention ownership belonging to Appellant.
- Hollenshead resigned as CEO in 2001; alleged misappropriation began 2002 and continued.
- Federal Action in 2007 dismissed most claims as time-barred; only Lanham Act claim survived then was dismissed.
- In 2010, Appellant filed a state action against Hollenshead and Autotrader seeking ownership, injunction, accounting, and damages.
- Trial court granted Hollenshead summary judgment based on res judicata, collateral estoppel, statute of limitations, and adverse possession; Appellant challenged, court reconsidered ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Law-of-the-case/co-ordinate jurisdiction reversal allowed | Appellant argues improper sua sponte reversal by coordinate judge. | Hollenshead contends reconsideration appropriate; law of the case not binding. | Reconsideration proper; law-of-the-case rule not controlling. |
| Adverse possession and statute of limitations applicability | Appellant disputes adverse-possession as title transfer and time-bar justification. | Hollenshead argues open, adverse possession valid; limits bar remedy. | Courts properly applied adverse possession and limitations to grant summary judgment. |
| Res judicata/Collateral estoppel preclusion vs. Autotrader license | Appellant claims no identity of issues or parties; not precluded. | Doubted; privity with licensee Autotrader and prior federal ruling bind state action. | Res judicata/collateral estoppel barred Appellant's claims. |
| Due process in reconsideration of motions | Appellant asserts denial of meaningful opportunity due to reconsideration. | Procedural steps provided; due process satisfied. | Due process satisfied; no merit in challenge. |
Key Cases Cited
- Commonwealth v. Starr, 541 Pa. 564, 664 A.2d 1326 (1995) (law-of-the-case reconsideration guidance; not binding to bar review)
- Day v. Volkswagenwerk Aktiengesellschaft, 318 Pa. Super. 225, 464 A.2d 1313 (1983) (identity of issues and parties for res judicata analysis)
- Stevenson v. Silverman, 417 Pa. 187, 208 A.2d 786 (1965) (ultimate issues decided; collateral estoppel applicability)
- Hochman v. Mortgage Fin. Corp., 289 Pa. 260, 137 A.2d 252 (1927) (core test for res judicata doctrine—same parties and issues)
- Callowhill Center Associates, LLC v. Zoning Board of Adjustment, 2 A.3d 802 (Pa. Cmwlth. 2010) (collateral estoppel extends to matters that could have been raised)