Case Explained: JIANGMEN BENLIDA PRINTED CIRCUIT CO., LTD. Plaintiff-Counter Defendant ROK PRINTED CIRCUIT CO., LTD v. CIRCUITRONIX, LLC Defendant-Counter

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-17 Docket: 0:21-cv-60125-RNS The Eleventh Circuit affirmed the district court’s grant of summary judgment in favor of Circuitronix, LLC on Jiangmen Benlida Printed Circuit Co.’s claims and the jury verdict awarding damages to Circuitronix on its counterclaims. The court held that Benlida was precluded from asserting agency or alter-ego theories of liability against Circuitronix for debts owed by a separate corporate entity, Circuitronix-HK, because these theories were not pleaded in the complaint. Under Federal Rule of Civil Procedure 8(a)(2) and controlling precedent such as *Dukes v. Deaton* and *MSP Recovery Claims*, a plaintiff must provide fair notice of the grounds for its claims in the complaint; new legal theories cannot be raised for the first time at summary judgment or trial without amending the pleadings. Because Benlida failed to allege facts supporting that Circuitronix-HK was an agent or alter ego of Circuitronix, the district court correctly determined that Circuitronix could not be held vicariously liable for Circuitronix-Hk’s invoices under Florida law. Consequently, the court affirmed the summary judgment on both the HK invoices and the Circuitronix invoices, as Benlida’s argument regarding “first-in-first-out” accounting relied entirely on the impermissible theory that payments made by Circuitronix could be applied to a separate corporate entity’s debt. Furthermore, the appellate court found no abuse of discretion in the district court’s exclusion of Benlida’s expert testimony, which was based on the same unpleaded agency and alter-ego theories, rendering the testimony irrelevant to the counterclaims at trial. The practical consequence is that Circuitronix remains liable only for its own invoices, which it has already overpaid, while Benlida receives no recovery for the outstanding debts of Circuitronix-HK. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.