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ExxonMobil Global Services Co. v. Gensym Corp.

Citations: 54 F. Supp. 3d 707; 2014 WL 4676839Docket: Case No. 1:12-CV-442-JDR

Court: District Court, W.D. Texas; September 17, 2014; Federal District Court

Narrative Opinion Summary

The case involves ExxonMobil's Motion for Partial Summary Judgment against Gensym concerning a breach of the 2008 License Agreement for the G2 Software Platform. ExxonMobil alleged that Gensym failed to provide necessary access codes, contrary to the agreement's terms. The court previously ruled that Gensym must supply access codes irrespective of maintenance service purchases. Gensym, however, withheld these codes in 2011, insisting on a support agreement. ExxonMobil, seeking injunctive relief, filed a lawsuit after repeated requests for the codes were denied. The court found that Gensym's actions constituted an anticipatory breach, as it repudiated its contractual obligation without valid justification. Gensym's evidentiary objections were partially sustained, particularly against hearsay and legal conclusions, but the court ruled in ExxonMobil's favor on the breach issue. The court granted ExxonMobil's motion, determining that there were no material factual disputes warranting a trial on the breach claim, while issues of causation and damages remain unresolved at this stage. Thus, ExxonMobil's right to access the G2 Software Platform was confirmed without the necessity of maintenance agreements, affirming Gensym's breach of contract.

Legal Issues Addressed

Anticipatory Breach of Contract

Application: Gensym's refusal to provide access codes without maintenance payments was deemed an anticipatory breach, as it repudiated its obligations under the 2008 License Agreement.

Reasoning: Gensym engaged in repeated repudiation of its obligation to provide annual access codes under the 2008 License Agreement throughout 2011.

Breach of Contract under Texas Law

Application: The court found that Gensym breached the 2008 License Agreement by failing to provide necessary access codes for the G2 Software Platform, irrespective of maintenance service purchases.

Reasoning: The central issue is whether Gensym breached the agreement by not providing access codes for the G2 Software Platform.

Evidentiary Objections in Summary Judgment

Application: The court considered and ruled on evidentiary objections raised by Gensym, sustaining some objections related to hearsay and legal conclusions while overruling others.

Reasoning: Gensym raised several evidentiary objections to ExxonMobil's summary judgment evidence. The court sustained Gensym's objection to hearsay statements from Andrew Price’s deposition.

Summary Judgment Standards

Application: The court applied summary judgment standards, determining there were no genuine disputes over material facts regarding Gensym's obligation to provide access codes, thus entitling ExxonMobil to partial summary judgment.

Reasoning: The court reviews summary judgment standards, stating that it is appropriate when there are no genuine disputes over material facts and the movant is entitled to judgment as a matter of law.