## Facts

- Leopold Meinrath, a European computer-products distributor, organized and owned four “Unicard” companies operating in the Benelux countries and France.
- Unicard held an exclusive distributorship for certain computer products, including a mini-computer originally known as the “Cogar 4.”
- Singer Company acquired control of the product’s manufacturer, renamed the product “Singer 1500,” and sought to expand into the European computer market.
- After negotiations, the parties executed a September 7, 1973 purchase-and-sale transaction under which Singer acquired Unicard’s exclusive distributorship and related assets.
- The transaction included a bonus-compensation arrangement tied to performance; Meinrath received some bonus payments but claimed Singer underpaid and delayed payment of additional amounts.
- Meinrath alleged that Singer’s nonpayment or late payment contributed to the collapse or serious impairment of his other ventures due to lack of funding.
- Meinrath also sought damages based on depreciation of the U.S. dollar against the Belgian franc, asserting that delay reduced the foreign-currency value of the amounts due.
- The case came before the district court on cross-motions for summary judgment in a contract dispute concerning the claimed bonus amounts and requested damages.

## Issues

1. Whether, under New York contract law, a plaintiff seeking damages for late or nonpayment of money may recover consequential damages for losses in separate business ventures, beyond the amount due and interest.
2. Whether a plaintiff may recover damages for currency devaluation when the contract specifies payment in U.S. dollars.

## Decision

- The court granted summary judgment for Singer on Meinrath’s claim for consequential damages arising from late or nonpayment of money, limiting potential recovery to the amount due and interest.
- The court granted summary judgment for Singer on Meinrath’s claim for damages based on devaluation of the U.S. dollar relative to the Belgian franc where the contract required payment in dollars.

## Legal Principles

- Under New York law, when the breach consists of failing to pay money when due, damages are generally limited to the unpaid amount plus interest at the legal rate; collateral business losses are not recoverable as consequential damages for such a breach.
- Notice that delayed payment will harm the creditor’s other ventures does not, by itself, expand a simple monetary payment obligation into liability for speculative losses from separate enterprises.
- Where a contract specifies payment in U.S. dollars, changes in exchange rates do not create an additional element of contract damages; currency risk follows the contractual unit of account.

## Conclusion

The court held that, for a contract requiring payment of money, New York law generally confines damages for nonpayment or delay to the amount due and statutory interest, and it rejected a separate damages claim based on foreign-exchange depreciation when the agreement required payment in U.S. dollars.


Meinrath v. Singer Co., 482 F. Supp. 457 (S.D.N.Y. 1979)