Geadau v. Evans
3:25-cv-00335
S.D. Cal.May 21, 2025Background
- Plaintiff Raul Geadau, a Fortnite map creator, entered into an agreement with Defendants Nathan Evans, Michael Hindi, and Big Fish Studios LLC to contribute to the development of Fortnite maps in exchange for equity and monthly payments.
- The agreements between the parties were confirmed via text messages, but Plaintiff alleges both the initial and amended agreements were ambiguous and conflicting.
- Plaintiff developed approximately 14 Fortnite maps, generating substantial revenue for the partnership, but was later denied ownership interest and revenue share after being terminated.
- Plaintiff brought multiple claims including intellectual property violations, breach of contract, wage violations, and other equitable claims.
- Defendants filed a motion to dismiss on various grounds, including improper pleading, statute of frauds, remedies not being causes of action, and improper requests for injunctive and punitive relief.
- The matter was decided on the papers, with the Court granting in part and denying in part the motion to dismiss.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Shotgun pleading | Complaint is sufficiently clear and separates claims | Complaint lumps allegations, making it unclear against whom claims are | Denied; complaint is adequately specific and separates claims and parties |
| Statute of Frauds bars contract claims | There are writings (texts); contract could be performed in under a year | Agreement subject to Statute of Frauds and not in valid writing | Denied; agreement could be performed within a year and texts suffice to satisfy writing requirements |
| Declaratory relief is not an independent COA | Entitled to declaratory relief under DJA and California law | Not an independent cause of action, just a remedy | Granted as to DJA (dismissed claim), denied as to California law (claim allowed) |
| Accounting/Constructive trust not independent COA | Permitted under California law | Constructive trust is a remedy, not a cause of action | Denied; such claims can be pleaded as independent actions under California law |
| Punitive damages on contract/implied covenant | Sufficiently pled fraud/malice; available on these claims | Not available for contract/implied covenant claims; insufficient facts | Granted for contract claims (dismissed punitive damages), denied for others (remains for non-contract) |
| Injunctive relief prayer insufficient | Properly stated claims for injunctive relief | No allegations of irreparable harm or lack of adequate legal remedy | Granted; dismissed without prejudice due to no showing of irreparable harm or inadequacy of legal remedy |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (standard for sufficiency of pleadings under Rule 12(b)(6))
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleading under Rule 8(a))
- Foley v. Interactive Data Corp., 765 P.2d 373 (Cal. 1988) (statute of frauds in the context of indefinite/at-will employment agreements)
- Miller v. Nat’l Am. Life Ins. Co., 126 Cal. Rptr. 731 (Cal. Ct. App. 1976) (punitive damages unavailable for ordinary breach of contract claims)
- Teselle v. McLoughlin, 92 Cal. Rptr. 3d 696 (Cal. Ct. App. 2009) (accounting as an independent cause of action under California law)