Landale Signs and Neon, Ltd. v. Runnion Equipment Company, 1:16-cv-07619

Landale Signs contracted in April 2016 to buy a crane from Runnion Equipment for $87,625; both parties signed a written contract.
After contracting, Landale received wiring instructions from email addresses that mimicked Runnion’s domain but misspelled “equipment.”
Landale ignored one set of fraudulent instructions (April 18) but followed a second set (May 12) and wired funds to an account in Virginia on May 13; by May 16 Landale discovered the fraud.
Landale alleges a breach of express and implied contract, claiming Runnion failed to protect its confidential information enabling a third-party (John Doe) to divert the funds.
Runnion moved for summary judgment; the court granted summary judgment to Runnion on the express-contract claim (no contractual confidentiality term or oral promise) and on the implied-contract claim for failure to prove causation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether express contract included a confidentiality obligation	Landale contends contract implied duties to protect payment/customer info	Runnion: written contract contains no confidentiality term; no oral promise was made	Court: No express confidentiality term or oral promise; summary judgment for Runnion on express claim
Whether parties formed an implied-in-fact confidentiality contract	Landale: parties’ conduct surrounding transaction created an implied confidentiality agreement	Runnion: no meeting of minds or intent to create such an obligation	Court: assumed arguendo an implied agreement could exist but did not decide formation because claim fails on causation
Whether Runnion proximately caused Landale’s loss (causation in fact)	Landale: third-party phishing/hacking must have originated from Runnion’s insecure IT; relied on IT consultant affidavit	Runnion: no evidence its employees disclosed info or that its systems were breached due to its negligence	Court: Landale failed to prove cause in fact; consultant affidavit was speculative and disregarded; summary judgment for Runnion
Admissibility/weight of plaintiff’s IT consultant affidavit	Swindlehurst opined breach likely originated from Runnion’s IT after limited review	Runnion: affidavit is speculative, lacks foundation, contains hearsay	Court: affidavit disregarded as speculative and hearsay; insufficient to create a triable issue

Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (summary judgment standard and reasonable jury inquiry)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (party moving for summary judgment bears initial burden)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (nonmovant must present more than metaphysical doubt)
Spitz v. Proven Winners N. Am., 759 F.3d 724 (7th Cir. 2014) (elements of breach of contract under Illinois law)
In re Emerald Casino, Inc., 867 F.3d 743 (7th Cir. 2017) (Illinois proximate-causation requirement in contract damages)
Stagman v. Ryan, 176 F.3d 986 (7th Cir. 1999) (district courts may disregard speculative affidavits)
Gunville v. Walker, 583 F.3d 979 (7th Cir. 2009) (courts may disregard hearsay in affidavits on summary judgment)