Meltwater News US Inc. v. Tveyes, Inc.
2:24-cv-09699
C.D. Cal.Nov 15, 2024Background
- Meltwater News US Inc. filed suit against TVEyes, Inc., asserting breach of contract, breach of the implied covenant of good faith and fair dealing, and seeking declaratory relief.
- The complaint alleges Meltwater is incorporated in California with a principal place of business there, while TVEyes is incorporated in Delaware with a principal place of business in Connecticut.
- Meltwater sought a Temporary Restraining Order (TRO) and preliminary injunction; TVEyes opposed.
- The Court reviewed the filings and found that evidence (contract amendment and Secretary of State records) suggests Meltwater may actually be incorporated in Delaware.
- If both Meltwater and TVEyes are Delaware corporations, complete diversity of citizenship would not exist, potentially defeating federal subject matter jurisdiction.
- The Court ordered Meltwater to show cause why the case should not be dismissed for lack of subject matter jurisdiction and will not decide the TRO pending resolution of this issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject matter jurisdiction | Meltwater alleges diversity exists | Records show Meltwater is Delaware | Court questions jurisdiction, requires briefing |
| Citizenship of Meltwater | California-incorporated | Delaware-incorporated | Court finds evidence supporting Delaware-link |
| TRO/Preliminary injunction ruling | Entitled to emergency relief | No jurisdiction, so TRO not proper | TRO application stayed pending jurisdiction |
| Court's obligation to check jurisdiction | Jurisdiction not challenged | Jurisdiction is lacking | Court must assure itself of jurisdiction |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts are courts of limited jurisdiction, and the party invoking jurisdiction bears the burden)
- Seven Arts Filmed Entertainment Ltd. v. Content Media Corp. PLC, 733 F.3d 1251 (court need not accept as true allegations contradicted by exhibits or judicially noticed facts)
- Kantor v. Wellesley Galleries, Ltd., 704 F.2d 1088 (diversity jurisdiction is strictly construed)
- Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (court is obliged to inquire about its own jurisdiction sua sponte)