Sonrai Systems, LLC v. Anthony M. Romano
1:16-cv-03371
| N.D. Ill. | Jul 25, 2025Background:
- Sonrai Systems, LLC sued Anthony Romano and Heil Co. d/b/a Environmental Solutions Group, alleging misuse of confidential information to develop Heil’s Enhance/3rd Eye PSV product, allegedly at the expense of Sonrai’s Vector product.
- Sonrai sought large lost-profit damages, claiming Vector would have generated $72.5 million "but for" the defendants’ actions.
- The jury awarded Sonrai $28.9 million, based on diverted sales to Progressive, Waste Management, and Republic Services.
- After trial, Heil moved for judgment as a matter of law (JMOL), arguing Sonrai’s damages theory was defective and the evidence insufficient on all claims.
- Heil also challenged the tort and contract verdicts, arguing the Moorman doctrine barred tort recovery and Sonrai failed to prove any actual use or damages under the contract.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether lost profits are recoverable for Vector (a new business line) | Lost profits should be awarded since Vector is not a "new" business; Sonrai has prior business history. | Lost profits not recoverable as Vector is a new product in a non-established market, with speculative projections. | Not Recoverable |
| Sufficiency of causation and damages evidence | Vector’s losses were directly caused by Defendants’ misuse; damages expert supports lost profits. | Sonrai abandoned Vector, failed to mitigate losses, and damages are conjectural, not linked to actual conduct. | Insufficient |
| Tort claim and punitive damages against Heil | Heil knowingly induced Romano’s data breach and benefited, justifying punitive award. | Moorman doctrine bars tort claim as it is coextensive with contract; insufficient evidence Heil knowingly participated or acted maliciously. | Barred/Insufficient |
| Breach of contract and use of Evaluation Material | Heil misused Sonrai’s confidential Evaluation Material in its product. | Sonrai failed to identify any specific Evaluation Material disclosed or used, and no evidence of use in 3rd Eye PSV product. | Proof Deficient |
Key Cases Cited
- TAS Distrib. Co. v. Cummins Engine Co., 491 F.3d 625 (7th Cir. 2007) (lost profits for new business ventures are generally too speculative without established market and comparable performance data)
- Ivey v. Transunion Rental Screening Sols., Inc., 2022 IL 127903 (Ill. 2022) (new business rule applies unless there is evidence of past, actual profits)
- Smart Mktg. Grp. v. Publ’ns, 624 F.3d 824 (7th Cir. 2010) (rejecting lost profits based on speculative projections without reliable market data)
- Moorman Mfg. Co. v. Nat’l Tank Co., 91 Ill. 2d 69 (Ill. 1982) (economic loss doctrine precludes tort recovery for purely contractual disputes)
- Midland Hotel Corp. v. Reuben H. Donnelley Corp., 118 Ill. 2d 306 (Ill. 1987) (causation and mitigation required for contract damages recovery)
- Hayman v. Autohaus on Edens, Inc., 315 Ill. App. 3d 1075 (Ill. App. Ct. 2009) (punitive damages not recoverable without compensatory damages)