Skyhook Wireless, Inc. v. Google Inc., 12 N.E.3d 440

Skyhook Wireless developed XPS, a location service that combines GPS, cell-tower, and Wi‑Fi data; Google provides competing Network Location Provider (NLP) as part of Google Mobile Services (GMS) bundled on Android devices.
Motorola and Samsung entered contracts with Google to ship Android devices preloaded with GMS Apps and to meet Google’s Android Compatibility Definition Document (CDD) and testing requirements; those contracts required Google’s written approval for device distribution.
Motorola (Sept. 2009) and Samsung (May/Dec. 2009 amendment) separately contracted with Skyhook to preload XPS on some Android devices; Skyhook’s XPS reported hybrid (satellite + network) data via the GPS Provider API and sought to block Google’s collection of network location data.
Google objected, asserting XPS’s use of the GPS Provider API to report non‑satellite data violated the documented API behavior in the SDK/CDD and would “contaminate” Google’s location database; Google also insisted GMS Apps remain fully functional, including data collection.
Google directed Motorola and Samsung not to ship devices with the original XPS implementation; Motorola later terminated its Skyhook agreement, and Samsung declined to use XPS citing cost and Google Locator adequacy.
Skyhook sued under theories of intentional interference with contract and advantageous relations and violation of G. L. c. 93A; the trial judge granted Google summary judgment, and the Appeals Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Google intentionally interfered with Skyhook’s contract with Motorola (and relationships with Motorola/Samsung) by improper motive	Google’s stated technical/data‑integrity reasons were pretext; real motive was to exclude Skyhook from Android market	Google lawfully asserted contractual compatibility and app‑function rights; acted to protect its product/database, not to unlawfully harm Skyhook	No improper motive; contractual assertions were legitimate — interference not wrongful as a matter of law
Whether Google used improper means (e.g., threats, misrepresentation) to induce breach	Google misinterpreted/over‑enforced contracts to pressure manufacturers to drop Skyhook	Google had express contractual rights to enforce CDD/API behavior and require accurate reproduction of GMS Apps; its actions were assertion of legal rights, not improper means	No improper means: exercising contractual rights is lawful; no evidence of threats or misrepresentation
Whether Skyhook’s G. L. c. 93A claim applies (primarily and substantially in MA)	Skyhook is based in Massachusetts; lost royalties and harm to its business in MA satisfy §11 territoriality	Google’s conduct and communications occurred outside MA (California, Illinois, South Korea); situs of conduct and loss are largely foreign/international	c.93A does not apply as a matter of law; Massachusetts was not the primary and substantial locus of the challenged conduct

Drakopoulos v. U.S. Bank Natl. Assn., 465 Mass. 775 (2013) (standard for reviewing facts on summary judgment)
Go‑Best Assets Ltd. v. Citizens Bank of Mass., 463 Mass. 50 (2012) (de novo review of summary judgment)
Juliano v. Simpson, 461 Mass. 527 (2012) (summary judgment principles)
Kourouvacilis v. General Motors Corp., 410 Mass. 706 (1991) (summary judgment review standard)
United Truck Leasing Corp. v. Geltman, 406 Mass. 811 (1990) (elements of intentional interference with contract)
Blackstone v. Cashman, 448 Mass. 255 (2007) (elements of interference with advantageous relations)
Pembroke Country Club, Inc. v. Regency Sav. Bank, F.S.B., 62 Mass. App. Ct. 34 (2004) (economic self‑interest as not necessarily improper motive in interference claims)
Kuwaiti Danish Computer Co. v. Digital Equip. Corp., 438 Mass. 459 (2003) (G. L. c. 93A §11 — "primarily and substantially" territorial test)
Yankee Candle Co. v. Bridgewater Candle Co., 259 F.3d 25 (1st Cir. 2001) (application of §11 when conduct and deception occurred outside MA)