Regulus Global Services Mexico SA de CV et al. v. SpektreWorks Incorporated

Summary

The United States District Court for the District of Arizona denied SpektreWorks Incorporated’s partial motion to dismiss a claim for tortious interference with prospective business relations under Arizona law. The court held that Regulus plausibly alleged a valid business expectancy in a Mexican government drone contract, despite not submitting its bid because SpektreWorks allegedly preempted it with an allegedly identical bid. The court concluded that the claim could proceed beyond the Rule 12(b)(6) stage.

Holdings

1. The complaint plausibly alleged a valid and reasonable business expectancy because it specifically identified SEDENA as the existing business relationship and the SEDENA Drone Contract as the expectancy, and alleged facts showing more than a speculative hope of obtaining that contract.
2. The plaintiffs' inability to submit the joint bid did not render their business expectancy unreasonable because they alleged that they were prepared to submit it and were preempted by the defendant's allegedly interfering bid.
3. The court declined to take judicial notice of the publicly available website concerning the SEDENA procurement process.

Questions Presented

1. Whether the complaint plausibly alleged a valid and reasonable business expectancy in the SEDENA drone contract and future Mexican government procurements for purposes of an Arizona tortious-interference claim.
2. Whether the plaintiffs' failure to submit the joint bid defeated their alleged business expectancy as a matter of law at the pleading stage.
3. Whether the court could consider facts from a publicly available website concerning the SEDENA procurement process on the Rule 12(b)(6) motion.

Disposition

other