Great Lakes Yacht Sales Inc v. Seabring Marine Industries Inc, 2:19-cv-01543

Plaintiff Great Lakes Yacht Sales, Inc. (Great Lakes) was appointed a non-exclusive retail dealer by defendant Seabring Marine Industries, Inc. d/b/a Monterey Boats (Monterey) under a written Dealer Agreement entered August 30, 2016.
Dealer Agreement required Great Lakes to maintain facilities, inventory, trained personnel, identify itself as a Monterey dealer, promote and advertise Monterey products, carry current model inventory, and permitted use of Monterey marks.
Great Lakes purchased seven yachts as part of becoming a dealer; at termination it had two Monterey boats in inventory worth $519,506.02.
Monterey notified Great Lakes on March 13, 2019 that the dealer relationship would terminate April 12, 2019; Monterey refused Great Lakes’ demand to repurchase the two boats.
Great Lakes sued under the Wisconsin Fair Dealership Law (WFDL), Wis. Stat. ch. 135, alleging Monterey’s refusal to repurchase violates the WFDL; Monterey moved to dismiss under Fed. R. Civ. P. 12(b)(6).
The magistrate judge denied the motion to dismiss, holding the complaint plausibly alleges facts sufficient to give fair notice and to permit a reasonable inference that a WFDL "dealer" relationship (community of interest) existed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complaint plausibly alleges a WFDL "dealership"/community of interest sufficient to survive a Rule 12(b)(6) motion	Complaint alleges contractual obligations (facility, inventory, personnel), marketing/promotional duties, required inventory levels, and use of Monterey marks — plausibly showing interdependence and continuing financial interest	Complaint fails to plead the Ziegler guideposts (continuing financial interest and interdependence) with sufficient detail to establish a WFDL dealer	Denied dismissal: the alleged duties and obligations give fair notice and make it plausible Great Lakes and Monterey shared a community of interest; detailed proof reserved for later stages
Whether plaintiff was required at pleading stage to allege all Ziegler facets or evidentiary facts supporting community of interest	Plaintiff need not plead every facet or evidentiary fact at the outset; plausibility suffices	Defendant contends plaintiff must plead facts satisfying Ziegler guideposts now	Court held plaintiff need only plead facts that make a dealer relationship plausible; detailed facets and proof are for discovery/trier of fact

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (established the federal "plausibility" pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (clarified plausibility and distinguished conclusory allegations)
Erickson v. Pardus, 551 U.S. 89 (2007) (pleadings need not contain detailed factual allegations to give fair notice)
W. Bend Mut. Ins. Co. v. Schumacher, 844 F.3d 670 (7th Cir. 2016) (on a Rule 12(b)(6) motion, court accepts complaint allegations as true)
Vincent v. City Colls. of Chi., 485 F.3d 919 (7th Cir. 2007) (plaintiff need not allege proof-level facts at the pleading stage)
Ziegler Co. v. Rexnord, 139 Wis.2d 593, 407 N.W.2d 873 (Wis. 1987) (identified continuing financial interest and interdependence guideposts for WFDL "community of interest")
Cent. Corp. v. Research Prods. Corp., 272 Wis.2d 561, 681 N.W.2d 178 (Wis. 2004) (articulated ten non-exhaustive facets courts weigh to determine dealer status under WFDL)
Water Quality Store, LLC v. Dynasty Spas, Inc., 328 Wis.2d 717, 789 N.W.2d 595 (Wis. Ct. App. 2010) (applied Ziegler and the ten-facet analysis to WFDL dealer inquiries)