Command Cinema Corp. v. VCA Labs, Inc.
Command Cinema (Plaintiff) sued VCA Labs (Defendant) for breach of express contract, conversion, and breach of implied contract regarding the loss of master tapes for two adult films, 'The Last X-Rated Movie' (LXRM) and 'The Firestorm Trilogy' (FT). VCA moved to dismiss and for summary judgment on several claims, and in limine to exclude certain damages. Command cross-moved for summary judgment on conversion. The court denied VCA's summary judgment motion on the FT breach of contract claim but granted Command's summary judgment on both FT and LXRM breach of contract claims. The court granted VCA's summary judgment motions on conversion and implied breach of contract, consequently denying Command's cross-motions on these claims. Regarding damages, the court granted VCA's motion in limine to exclude lost profits for the FT contract but denied it for the LXRM contract, allowing Command to present evidence for lost asset value for LXRM. Punitive damages were also precluded.