Druckzentrum Harry Jung GmbH & Co. v. Motorola Mobility LLC
United States Court of Appeals for the Seventh Circuit
774 F.3d 410 (2014)
Druckzentrum (plaintiff), a German printer, had printed Motorola's (defendant) cell-phone manuals for the EMEA region for over a decade. After Motorola introduced a competitive-bidding purchasing program in 2007, Druckzentrum won a new contract that gave it 2% of Motorola's worldwide printing business, let Motorola terminate for various reasons including its own convenience, and contained an integration clause stating the contract was the parties' entire agreement, superseding prior discussions. Less than nine months in, a sharp drop in Motorola's phone sales led it to move all printing to China, and Druckzentrum, having lost that business, went bankrupt. Druckzentrum sued, arguing Motorola had promised it an exclusive two-year right to the EMEA business during the bidding process, even though the signed contract contained no express exclusivity clause. The trial court found no exclusivity right existed and dismissed the claim.
Whether the Uniform Commercial Code permits introducing additional terms into a written contract that contains an integration clause.