Case Explained: MULTIPLE ENERGY TECHNOLOGIES, LLC V. CASDEN

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-07-30 Docket: 2:21-cv-01149- The ninth-circuit reversed in part and affirmed in part the district court’s judgment in favor of Multiple Energy Technologies, LLC against Seth Casden. Regarding the claim for tortious interference with contract under California law, the panel held that corporate agents are ordinarily immune from such suits when acting on behalf of their principal. The court determined that the district court erred by denying immunity solely because Casden acted for his “individual advantage,” clarifying that an agent loses immunity only when acting outside the scope of agency by benefiting himself at the expense of the principal, not merely when advancing personal interests alongside corporate goals. Consequently, the court reversed the judgment on the tortious interference claim and remanded for further proceedings consistent with this standard. Regarding the false advertising claim under the Lanham Act (15 U.S.C. § 1117(a)), the panel reversed the district court’s award of disgorgement of Casden’s salary. The court reasoned that the statute permits recovery of a defendant’s “profits,” which requires proof of the defendant’s sales; because Casden as an individual had no sales, his salary could not be treated as profits distinct from corporate expenses. Finally, the panel affirmed the district court’s award of attorneys’ fees under the Lanham Act, finding no abuse of discretion in deeming the case “exceptional” based on the jury’s finding that Casden’s representations were deliberately or intentionally false. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.