Case 7:14-cv VB Document 25 Filed 03/02/15 Page 1 of 8 : : : :

Similar documents
Plaintiff John Kelleher brings this action under the Americans with Disabilities Act, 42

Plaintiff Betty, Inc. ( Betty ), brings this action asserting copyright infringement and

Case 7:12-cv VB Document 26 Filed 04/18/13 Page 1 of 11 : : : : : :

Case 1:17-cv DPG Document 48 Entered on FLSD Docket 03/30/2018 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON. DAVID C. MCCARTY, et al., : Case No.

Case: 1:16-cv Document #: 21 Filed: 03/27/17 Page 1 of 5 PageID #:84

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS MEMORANDUM AND ORDER

Case 1:14-cv FDS Document 24 Filed 06/26/14 Page 1 of 7 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS. ) ) Civil No. v.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA VERSUS NO ORDER AND REASONS ON MOTION

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION CASE NO. 3:12-CV REDRIDGE FINANCE GROUP, LLC

: : Defendants. : Plaintiff Palmer/Kane LLC ( Palmer Kane ) brings this action alleging

Case 2:15-cv CDJ Document 31 Filed 03/16/16 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 1:13-cv RHB Doc #14 Filed 04/17/14 Page 1 of 8 Page ID#88

Case 5:15-cv JGB-KK Document 18 Filed 01/07/16 Page 1 of 9 Page ID #:265

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) Presently before the Court is Defendants Connecticut General

Case 1:14-cv LTS Document 41 Filed 07/24/15 Page 1 of 10

Case: 1:18-cv Document #: 18 Filed: 10/03/18 Page 1 of 5 PageID #:55

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI JACKSON DIVISION. v. CIVIL ACTION NO.

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA * * * ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

Case 7:13-cv VB Document 73 Filed 02/04/15 Page 1 of 13

Case 2:11-cv JES-CM Document 196 Filed 08/18/14 Page 1 of 9 PageID 3358

Case 1:14-cv JMF Document 29 Filed 04/20/15 Page 1 of 9. : : Plaintiff, : : Defendants.

Case 3:10-cv L Document 22 Filed 08/19/10 Page 1 of 9 PageID 101 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

Case 3:10-cv RBL Document 40 Filed 04/11/12 Page 1 of 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT TACOMA

Case 3:13-cv L Document 109 Filed 08/21/15 Page 1 of 11 PageID 3052

Case 1:11-cv RLV Document 103 Filed 08/23/12 Page 1 of 7 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION.

HOUSTON SPECIALTY INSURANCE COMPANY v. TITLEWORKS OF SOUTHWE...

Case 3:11-cv DPJ -FKB Document 26 Filed 01/05/12 Page 1 of 10

operated (then known as ClinNet Solutions, LLC, whose members were Martin Clegg,

Case 0:16-cv WPD Document 64 Entered on FLSD Docket 01/19/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

433 Main Street Realty, LLC et al v. Darwin National Assurance Company Doc. 33

Case 1:17-cv TNM Document 29 Filed 06/22/18 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MEMORANDUM OPINION

Case: 1:15-cv PAG Doc #: 28 Filed: 08/28/15 1 of 6. PageID #: 140 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

Case: 1:12-cv Document #: 55 Filed: 02/25/13 Page 1 of 9 PageID #:525

Case 1:10-cv CFL Document 41 Filed 09/27/12 Page 1 of 9 UNITED STATES COURT OF FEDERAL CLAIMS

Case 1:17-cv TNM Document 14 Filed 01/12/18 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 0:17-cv WPD Document 16 Entered on FLSD Docket 12/11/2017 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

United States District Court District of Massachusetts MEMORANDUM & ORDER

IN THE UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT

Case 3:11-cv BEN-MDD Document 29-1 Filed 03/05/12 Page 1 of 9 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA * * * Plaintiff(s), Defendant(s).

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION. v. Case No. 8:13-cv-3136-T-33EAJ ORDER

SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA CIVIL DIVISION. Case No CA B v. Judge Robert R. Rigsby ) ) ) ) ) ORDER

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

Support. ECF No. 16. On September 9, 2016, the Plaintiff filed

-BGC Channel Bio, LLC et al v. Illinois Family Farms et al Doc. 18

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Case 3:10-cv MLC -DEA Document 10 Filed 06/24/10 Page 1 of 8 PageID: 112

Plaintiffs, 1:11-CV-1533 (MAD/CFH)

3:14-cv MGL Date Filed 10/23/14 Entry Number 24 Page 1 of 5

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA. Before the Court is Twin City Fire Insurance Company s ( Twin City ) Motion for

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO CIV-MARRA/HOPKINS OPINION AND ORDER

DECISION and ORDER. Before the Court is Defendants renewed motion to dismiss this matter involving

Case 3:16-cv JST Document 56 Filed 02/08/17 Page 1 of 9 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case No. 2:15-bk-20206, Adversary Proceeding No. 2:15-ap United States Bankruptcy Court, S.D. West Virginia, Charleston. March 28, 2016.

In The United States Court of Federal Claims No C

EQEEL BHATTI, 1:16-cv-257. Defendants.

Case 2:15-cv SDW-SCM Document 10 Filed 05/21/15 Page 1 of 8 PageID: 287 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY OPINION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA. Plaintiffs,

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION MEMORANDUM OPINION AND ORDER

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA. Alexandria Division ) ) This matter is before the Court on Defendant Catalin

){

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION : : : : : : : : : : ORDER

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA. Plaintiff, Defendant.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

2:12-cv DPH-MKM Doc # 10 Filed 04/30/13 Pg 1 of 7 Pg ID 99 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case 1:12-cv ABJ Document 14 Filed 06/19/13 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

RULING AND ORDER ON DEFENDANTS MOTION TO DISMISS. Gorss Motels, Inc. ( Gorss Motels or Plaintiff ) filed this class action Complaint on

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY. THIS MATTER comes before the Court on Plaintiff AT&T Mobility Services LLC s

MEMORANDUM AND ORDER - versus - 14-cv Plaintiff, Defendant.

Case 2:11-cv DDP-MRW Document 23 Filed 02/19/13 Page 1 of 5 Page ID #:110 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Case: 1:15-cv Document #: 34 Filed: 01/20/16 Page 1 of 6 PageID #:132

Case 1:15-cv KLM Document 34 Filed 09/16/16 USDC Colorado Page 1 of 12 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION. v. CIVIL ACTION NO. 3:15-CV-2145-B MEMORANDUM OPINION AND ORDER BACKGROUND

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ALEXANDRIA DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

Case 1:11-cv JEC Document 10 Filed 03/14/12 Page 1 of 11

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION REPORT AND RECOMMENDATION

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN SCREENING ORDER

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

2:16-cv SJM-RSW Doc # 19 Filed 08/31/17 Pg 1 of 9 Pg ID 349 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION


UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION. Case No. 3:16-cv-178-J-MCR ORDER

Case 1:13-cv LPS Document 34 Filed 07/17/15 Page 1 of 8 PageID #: 964

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION. v. Case No: 2:16-cv-833-FtM-99CM OPINION AND ORDER

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

Case SWH Doc 72 Filed 06/16/17 Entered 06/16/17 10:30:36 Page 1 of 8

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION (at Lexington) ) ) ) ) ) ) ) ) ) ) ) *** *** *** ***

Transcription:

Case 714-cv-04694-VB Document 25 Filed 03/02/15 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------x INTERNATIONAL BUSINESS MACHINES CORPORATION, Plaintiff, v. MITHKAL SMADI, Defendant. --------------------------------------------------------------x MEMORANDUM DECISION 14 CV 4694 (VB) Briccetti, J. Plaintiff International Business Machines Corporation ( IBM ) brings this diversity action alleging it is due $243,710.91 for the value of rescinded stock options and equity awards previously granted to its former employee, defendant Mithkal Smadi. Now pending is defendant s motion to dismiss the second amended complaint ( SAC ), for failure to state a claim. (Doc. #17). For the following reasons, the motion is DENIED. The Court has subject matter jurisdiction pursuant to 28 U.S.C. 1332. BACKGROUND IBM alleges that during the course of defendant s employment as a Distinguished Engineer with the company, defendant received stock options and equity awards (collectively, Awards ) under the IBM 2001 Long-Term Performance Plan (the Plan ) and various Equity Award Agreements ( EAAs ). (SAC 3-4, 6). The Terms and Conditions of Your Equity Award Effective June 8, 2011 ( Terms and Conditions, collectively with the Plan and EAAs, the Award Agreements ) provided defendant with the terms and conditions of his Awards. (SAC 4, Cooper Decl. Ex. B). IBM alleges these Awards were designed to attract, motivate and retain selected employees by making long-term incentive and other awards. (SAC 8). 1

Case 714-cv-04694-VB Document 25 Filed 03/02/15 Page 2 of 8 Section 13(a) of the Plan provides, in pertinent part [IBM] may cancel, rescind, suspend, withhold or otherwise limit or restrict any unexpired, unpaid, or deferred Awards at any time if the Participant... engages in any Detrimental Activity. For the purposes of this Section 13, Detrimental Activity shall include (i) the rendering of services for any organization or engaging directly or indirectly in any business which is or becomes competitive with the Company, or which organization or business, or the rendering of services to such organization or business, is or becomes otherwise prejudicial to or in conflict with the interests of the Company. (SAC 14). Section 13(b) provides, in pertinent part In the event a Participant fails to comply with the provisions of [Section 13(a)] prior to, or during the Rescission Period, then any exercise, payment or delivery may be rescinded within two years after such exercise, payment or delivery. (SAC 15). The Rescission Period is defined as the twelve month period after any exercise, payment or delivery pursuant to an Award. (SAC 49). Moreover, various EAAs executed by defendant during the course of his employment allowed IBM to cancel, modify, rescind, suspend, withhold or otherwise limit or restrict the EAA if he were to render services for a competitor prior to, or during the Rescission Period. (SAC 16). According to IBM, defendant exercised Awards on May 8, June 6, and June 8, 2012, realizing gains totaling $243,710.91. (SAC 24-33, 35). IBM alleges plaintiff voluntarily terminated his employment on March 13, 2013, and soon thereafter commenced employment with Microsoft Corporation. (SAC 9, 10, 18, 46). IBM deemed this to be Detrimental Activity within the Rescission Period. As a result, on May 28, 2013, IBM notified defendant it had rescinded his recently exercised Awards, and demanded repayment of defendant s gain of $243,710.91. (SAC 40-43). IBM alleges defendant has failed and refused to make the requested payment. (SAC 44). IBM seeks $243,710.91 from defendant for the monetary value of his rescinded Awards, plus all costs and expenses incurred in connection with the instant action. Defendant moves to 2

Case 714-cv-04694-VB Document 25 Filed 03/02/15 Page 3 of 8 dismiss, arguing rescission is an extraordinary remedy not permitted here, the Plan is unenforceable, and the Award Agreements limit IBM s recovery to unvested Awards. DISCUSSION I. Legal Standard In deciding a motion to dismiss pursuant to Rule 12(b)(6), the Court evaluates the sufficiency of the complaint under the two-pronged approach announced by the Supreme Court in Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). First, [t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, are not entitled to the assumption of truth and are thus not sufficient to withstand a motion to dismiss. Id. at 678; Hayden v. Paterson, 594 F.3d 150, 161 (2d Cir. 2010). Second, [w]hen there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement for relief. Ashcroft v. Iqbal, 556 U.S. at 679. To survive a Rule 12(b)(6) motion to dismiss, the allegations in the complaint must meet a standard of plausibility. Id. at 678; Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564 (2007). A claim is facially plausible when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. Ashcroft v. Iqbal, 556 U.S. at 678. The plausibility standard is not akin to a probability requirement, but it asks for more than a sheer possibility that a defendant has acted unlawfully. Id. II. Breach of the Award Agreements Both parties fail to brief the real issue in this case namely, whether defendant breached the Award Agreements when he failed to return the gain realized from his exercise of Awards on May 8, June 6, and June 8, 2012. Instead, the parties briefed defendant s motion as if the SAC alleged a claim for rescission. IBM is not seeking rescission. 3

Case 714-cv-04694-VB Document 25 Filed 03/02/15 Page 4 of 8 IBM does not wish to return to the status quo, i.e., for defendant to return to work at IBM. Rather, IBM seeks repayment of defendant s gain from the rescinded Awards, and, although inartfully pleaded, 1 the SAC purports to allege a claim for breach of contract. Put another way, IBM is claiming that when defendant failed to repay or return the monetary value of his rescinded Awards, he breached an agreement he made with IBM; and that IBM s damages are equal to the gain defendant realized from his exercise of the Awards. To state a claim for breach of contract under New York law, a complaint need only allege (1) the existence of an agreement, (2) adequate performance of the contract by the plaintiff, (3) breach of contract by the defendant, and (4) damages. Harsco Corp. v. Segui, 91 F.3d 337, 348 (2d Cir. 1996). The SAC adequately alleges the four elements of a claim for breach of contract. IBM has alleged (i) the existence of the Award Agreements; (ii) IBM s performance under said agreements; (iii) defendant s failure to return the monetary value of Awards he received during the Rescission Period; 2 and (iv) $243,710.91 in damages. Defendant argues the Plan is unenforceable because it is not reasonably tailored to protect IBM s legitimate business interests and it retroactively assigns meaning to the term Detrimental Activity based upon future performance. The Court disagrees. 1 IBM labels its claim as a First Cause of Action and simply states there is due and owing from Defendant to IBM the amount of $243,710.91. (SAC at 7, 58). 2 IBM argues [d]efendant s post-separation employment with Microsoft, a direct competitor of IBM, constitutes a fundamental breach of [the Plan]. (Pl. s Opp n at 7). That is simply not true. The breach occurred when defendant allegedly failed to return the monetary value of Awards. To accept IBM s argument would bind all incentivized employees to IBM forever. 4

Case 714-cv-04694-VB Document 25 Filed 03/02/15 Page 5 of 8 A. Employee Choice Doctrine The employee choice doctrine renders the Plan enforceable. While New York courts disfavor restrictive covenants in the employment context and will generally enforce them only to the extent they are reasonable and necessary to protect valid business interests, there is one salient exception. Lucente v. International Bus. Machs. Corp., 310 F.3d 243, 254 (2d Cir. 2002). New York courts will enforce a restrictive covenant without regard to its reasonableness if the employee has been afforded the choice between not competing (and thereby preserving his benefits) or competing (and thereby risking forfeiture). Id.; see also Morris v. Schroder Capital Mgmt. Int l, 7 N.Y.3d 616, 620-21 (2006). This is called the employee choice doctrine. The employee choice doctrine is applicable if the employee left his employment voluntarily, see Morris v. Schroder Capital Mgmt. Int l, 481 F.3d 86, 88 (2d Cir. 2007), and the employer can demonstrate its continued willingness to employ the party who covenanted not to compete. See Lucente v. International Bus. Machs. Corp., 310 F.3d at 254. The employee choice doctrine is applicable here. Defendant was afforded the choice of continuing to receive Awards by refraining from competing with IBM, or forfeiting the monetary value of Awards by competing with IBM. IBM alleges defendant left his position voluntarily, and IBM demonstrated its continued willingness to employ defendant by paying out the Awards he exercised in May and June of 2012. It matters not that defendant was deprived of a past benefit, as the doctrine may be applied where the benefit has already been paid. Tasciyan v. Marsh USA, Inc., 2007 WL 950091, at *3 (S.D.N.Y. Mar. 28, 2007); see also International Bus. Machs. Corp. v. Martson, 37 F. Supp. 2d 613, 619 (S.D.N.Y. 1999) (doctrine applicable where employee received award subject to forfeiture, then violated the non-compete provision of the 5

Case 714-cv-04694-VB Document 25 Filed 03/02/15 Page 6 of 8 award). The employee choice doctrine permits the Plan to condition acceptance of Awards on defendant s choice, and therefore, is enforceable under New York law. B. Meaning of Detrimental Activity It appears defendant argues the Plan is unenforceable because it assigns meaning to the term Detrimental Activity based upon future performance. 3 (Def. s R. at 1). It is unclear how the Plan does such a thing. Detrimental Activity is defined as engagement in any business which is competitive with IBM. IBM now alleges defendant accepted employment at IBM s competitor, Microsoft, and thus committed a Detrimental Activity. Defendant explains the Plan ascribes meaning to Detrimental Activity based upon future performance because IBM s former employees [are] subject to IBM s whim years after shares are exercised. (Pl. s R. at 2). That explanation is nonsensical. Simply because the Plan calls for rescission of Awards within two years after their exercise, and is thus unfavorable to defendant at this juncture, does not mean IBM retroactively defined Detrimental Activity. 4 As such, defendant s arguments are unavailing. Detrimental Activity is not defined by 3 Defendant also appears to argue the term Detrimental Activity is unreasonably broad. However, as discussed above, the reasonableness of the term is moot because the employee choice doctrine applies. 4 Moreover, the cases defendant cites in support of his argument are inapplicable. In Saunders v. City of N.Y., 2009 WL 90621, at *2 (S.D.N.Y. Jan. 13, 2009), the court held a term in a Collective Bargaining Agreement could not be defined by the employee s subsequent acquiescent conduct. Here, there is no comparable allegation of subsequent acquiescent conduct. In Slatt v. Slatt, 64 N.Y.2d 966, 967 (1985), the court held an alimony agreement contained unambiguous language evincing the intent of the parties to subject all of the defendant-husband s payments to a cost of living increase. It is unclear how that case, or the law therein, is applicable to defendant s argument. Fiore v. Fiore, 46 N.Y.2d 971 (1979), Rodolitz v. Neptune Paper Prods., 22 N.Y.2d 383 (1968), and Sperling v. Great Am. Indemn. Co., 7 N.Y.2d 442 (1960), are similarly inapplicable. 6

Case 714-cv-04694-VB Document 25 Filed 03/02/15 Page 7 of 8 future performance. III. Recovery of Vested Awards Finally, defendant argues the plain language of the Award Agreements limits IBM s recovery to those Awards that had neither fully vested nor expired, or, in the alternative, that the Award Agreements are internally inconsistent and therefore ambiguous. Both arguments are unavailing. As to the first argument, the plain language of the Award Agreements may permit recovery of unvested and unexpired Awards, but the Award Agreements also permit recovery of any Award. Pursuant to Section 13(b) of the Plan, in the event a participant fails to comply with Section 13(a), then any exercise, payment or delivery may be rescinded within two years after such exercise, payment or delivery. (SAC 15 (emphasis added)). Also, EAAs executed by defendant allowed IBM to cancel, modify, rescind, suspend, withhold or otherwise limit or restrict [the EAA]... including without limitation, canceling or rescinding. (SAC 16). As to defendant s alternative argument, any alleged ambiguity in the Award Agreements must be construed in IBM s favor at this early stage of the case. When the language of a contract is ambiguous, its construction presents a question of fact, precluding dismissal of a breach of contract claim on a Rule 12(b)(6) motion. Crowley v. VisionMaker, LLC, 512 F. Supp. 2d 144, 152 (S.D.N.Y. 2007) (quoting Jackson Heights Medical Grp., P.C. v. Complex Corp., 222 A.D.2d 409, 411 (2d Dep t 1995)). Therefore, while a court is not obliged to accept the allegations of the complaint as to how to construe a contract, it should resolve any contractual ambiguities in favor of the plaintiff on a motion to dismiss. Maniolos v. U.S., 741 F. Supp. 2d 555, 567 (S.D.N.Y. 2010) (quoting Subaru Distribs. Corp. v. Subaru of Am., Inc., 425 F.3d 119, 122 (2d Cir. 2005)). If, as defendant argues, there is ambiguity in the Award 7

Case 714-cv-04694-VB Document 25 Filed 03/02/15 Page 8 of 8 Agreements, on a motion to dismiss, that ambiguity must be construed in IBM s favor. Accordingly, IBM s recovery cannot be limited by defendant s interpretation at this early stage of the proceedings. CONCLUSION Defendant s motion to dismiss the second amended complaint is DENIED. The Clerk is instructed to terminate the motion. (Doc. #17). Dated March 2, 2015 White Plains, NY SO ORDERED Vincent L. Briccetti United States District Judge 8