Ergowerx International, LLC v. Maxell Corp. of America
The Court previously dismissed federal claims filed by plaintiff Ergowerx International, LLC (Smartfish) against defendant Maxell Corporation of America (Maxell). The remaining claim was for breach of contract. The Court first addressed whether it had original diversity jurisdiction. Maxell argued that complete diversity was lacking, while Smartfish incorrectly asserted that alienage jurisdiction under 28 U.S.C. § 1332(a)(2) did not require complete diversity. The Court clarified that alienage jurisdiction is a form of diversity jurisdiction and requires complete diversity. Since Smartfish, as an LLC, takes the citizenship of its members (including New Jersey), and Maxell is a citizen of New Jersey, complete diversity was absent, and thus the Court lacked original jurisdiction. The Court then declined to exercise supplemental jurisdiction over the state-law breach-of-contract claim, citing the early stage of the litigation, the dismissal of all federal claims, and the values of judicial economy, convenience, fairness, and comity. The breach-of-contract claim was dismissed without prejudice, allowing Smartfish to pursue it in state court.