Kaufman v. Microsoft Corp.

NOCO Co. v. OJ Commerce, LLC

NOCO Company manufactures and sells battery chargers and related products. Although it sells these products itself, NOCO also authorizes resellers if they sign an agreement. This dispute began when NOCO discovered that OJ Commerce (OJC) was selling NOCO’s products on Amazon without authorization. NOCO complained to Amazon that OJC was selling NOCO’s products in violation of Amazon’s policy. And around the same time, another company also complained to Amazon about OJC. Amazon asked OJC for proof that it was complying with its policy. But OJC didn’t provide adequate documents and Amazon temporarily deactivated OJC’s account. Now, OJC blames NOCO. It argues that NOCO submitted false complaints, and it brings three claims against NOCO: defamation, tortious interference with a business relationship, and a violation of the Ohio Deceptive Trade Practices Act.

To succeed on these claims, though, OJC must establish that NOCO was the proximate cause of its injury. But it can’t do this because three intervening causes broke the causal chain, relieving NOCO of any liability. Thus, the district court rejected OJC’s claims on summary judgment, and we AFFIRM.

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