Dorfman, J. | May 20, 2026
Granting the plaintiff's motion to remand the case back to district court.
At issue is a purchase order in an amount less than $1 million issued under a 2003 master service agreement, pursuant to which the defendant claims to have paid the plaintiff over $7.8 million to date. The defendant argued that a qualified transaction "springs" into existence upon the execution of the first purchase order or invoice resulting in the payment of over $5 million.
The Court rejected the argument because the historical purchase orders on which the defendant relies spanned more than two decades, involved differing scopes of work, and were performed at diverse facilities – potentially operated by different affiliated entities. Only one such purchase order is at issue in this case. The remainder are not in controversy.