Centech Group, Inc. v. Getronicswang Co.

After Centech (plaintiff) failed to perform its prime contract with the Navy, it entered a memorandum of understanding (MOU) with subcontractor I-NET conditionally agreeing to shift responsibility for the contract, later replacing it with a Revised MOU expressly requiring I-NET to identify $10 million in project opportunities for Centech in exchange for I-NET actually assuming the prime contract; when I-NET failed to deliver those opportunities, Centech sued for breach, and I-NET argued (among other defenses) that the Revised MOU lacked new consideration and, alternatively, that Centech argued it had been procured under duress from I-NET's threats to stop performing. The district court granted I-NET summary judgment, and Centech appealed.