iCIMS, Inc. v. Cigna Corporate Services, LLC

Summary

The United States District Court for the District of New Jersey denied Cigna Corporate Services, LLC’s Rule 12(b)(6) motion to dismiss iCIMS, Inc.’s breach-of-contract claim. The court held that iCIMS sufficiently pleaded breach of the Subscription Agreement as extended by a Renewal. Although the agreement contained a one-year limitations provision, the court found that it was not apparent from the complaint whether the Renewal incorporated a similar limitation, making dismissal at the pleading stage inappropriate.

Holdings

1. The complaint sufficiently pleaded a breach-of-contract claim based on the Subscription Agreement as extended by the Renewal.
2. Dismissal was not appropriate because the contractual limitations bar was not apparent on the face of the complaint.
3. Plaintiff could not amend its pleaded theory through its opposition brief to assert a separate breach-of-contract claim based on the Renewal.

Questions Presented

1. Whether iCIMS sufficiently pleaded the elements of a breach-of-contract claim under New York law.
2. Whether the complaint showed on its face that the claim was barred by the Subscription Agreement's one-year contractual limitations period.
3. Whether the Renewal's terms created an unresolved issue as to whether the shortened limitations period applied.

Disposition

other