Shuffle Tech Int’l, LLC v. Wolff Gaming, Inc.

Shuffle makes consumer grade automatic card-shuffling equipment. Wolff distributes casino grade gaming equipment. In 2010 the two signed a letter of intent that Shuffle, with financial assistance from Wolff, would develop casino-grade shuffling equipment, and Wolff would become its exclusive distributor. Before development of the new equipment was completed, Shuffle ended the relationship and sought a declaratory judgment that the agreement was not an enforceable contract. Wolff counterclaimed, claiming breach of contract, fraud, and unjust enrichment. The district judge granted summary judgment in favor of Shuffle with respect both to its claim for declaratory relief and to Wolff’s counterclaims, essentially rescinding the agreement. In its complaint, Shuffle acknowledged that it would have to return $124,940 earnest money to Wolff, but the order failed to mention the earnest money. Shuffle ignored Wolff’s request for a refund. Wolff moved, under FRCP 60, that the court order Shuffle to refund the money. The judge entered a post-judgment order requiring the refund, without mentioning Rule 60 or any other ground for amendment. The Seventh Circuit affirmed, stating that “if the flaw lies in the translation of the original meaning to the judgment, then Rule 60(a) allows a correction.” The correction just made explicit what the parties must have assumed; that with the draft agreement rescinded the earnest money had to be returned. View "Shuffle Tech Int'l, LLC v. Wolff Gaming, Inc." on Justia Law