BALTIMORE (LN) — U.S. District Judge Lydia Kay Griggsby granted partial summary judgment to SRI International on Tuesday, dismissing a Maryland defense contractor’s trademark and contract claims arising from a joint lobbying effort for $21 million in Navy funding.
Titan Systems, LLC, sued the California-based research institute, alleging SRI violated its Lanham Act rights and breached an implied-in-fact contract by using the term “MADDIS” in briefing materials presented to Congress.
Titan, a company providing custom design and integration support for military systems, claimed it developed the Multi-Agency Data Dissemination and Interoperability Services concept alongside SRI.
The dispute centers on the MADDIS Campaign, a late-2020 initiative to lobby Congress to appropriate funds for Navy interoperability technology.
Titan alleged that Greg Makrakis, its president and former Navy employee, was almost exclusively responsible for drafting early versions of the MADDIS PowerPoint presentation.
SRI contended Makrakis’s role was administrative and that it independently updated the presentation and lobbied Congress without Titan’s involvement.
Congress appropriated $21 million for the MADDIS technology across fiscal years 2021, 2022, and 2024.
SRI subsequently received gross revenues of approximately $13.8 million for two government contracts related to the project.
Titan did not participate proposal process for these contracts and received no proceeds.
Judge Griggsby granted SRI’s motion for summary judgment on Titan’s unjust enrichment and breach of implied-in-fact contract claims.
The court found Titan failed to prove it conferred a cognizable benefit on SRI, noting the connection between Titan’s early contributions and SRI’s contract awards was “too remote and tenuous.”
Griggsby also ruled the parties never reached an agreement definite enough to form an enforceable contract, as they never agreed in writing to a specific profit-sharing formula or scope of work.
Titan’s Lanham Act claim survived summary judgment because material facts remained in dispute regarding whether the company used the mark in commerce and whether SRI’s use caused consumer confusion.
Titan argued that government officials were confused by SRI’s use of the MADDIS mark, while SRI pointed to the absence of actual confusion evidence.
The case proceeds to trial on the trademark claim.
Griggsby is a George W. Bush appointee.