UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

ROBERT BOSCH LLC and 

BOSCH AUTOMOTIVE PRODUCTS 

(SUZHOU) CO., LTD.,

Plaintiffs, Case No. 2:15-cv-11832-AC-EAS

v. Hon. Avern Cohn

J.S.T. MFG. CO., LTD., 

J.S.T. SALES AMERICA INC., and

J.S.T. CORPORATION,

Defendants.

__________________________________________________________________/

S. Thomas Wienner (P29233) Alan N. Salpeter

Seth D. Gould (P45465) Dina M. Hayes

Daniel K. Beitz (P47451) KAYE SCHOLER LLP 

WIENNER & GOULD, P.C. Attorneys for Plaintiffs

Attorneys for Plaintiffs 70 West Madison Street, Ste. 4200

950 W. University Dr., Ste. 350 Three First National Plaza

Rochester, MI 48307 Chicago, IL 60602

(248) 841-9400 (312) 583-2300

twienner@wiennergould.com alan.salpeter@kayescholer.com

sgould@wiennergould.com dina.hayes@kayescholer.com

dbeitz@wiennergould.com

Bruce L. Sendek (P28095)

BUTZEL LONG PC

Attorneys for Defendants

150 W. Jefferson Ave., Ste. 100

Detroit, MI 48226

(313) 225-7000

sendek@butzel.com

__________________________________________________________________/

FIRST AMENDED COMPLAINT VERIFIED

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INTRODUCTION

1. Plaintiffs Robert Bosch LLC and Bosch Automotive Products 

(Suzhou) Co., Ltd. (jointly “Bosch”), by and through their counsel, Wienner & 

Gould, P.C. and Kaye Scholer LLP, bring this action to stop Defendants J.S.T.

Mfg. Co., Ltd. (“JST Japan”), J.S.T. Corporation (“JST Illinois”), and J.S.T.

Sales America Inc. (“JST America”) from cutting off Bosch’s supply of electric 

plastic connectors, part numbers 6002.JE0.402 and 3284.489.855, used in 

General Motors and Daihatsu vehicles, respectively (jointly, “Connectors”).

(JST Japan, JST Illinois, and JST America are collectively referred to herein as 

“JST” or “Defendants.”)

2. Bosch brings this action after JST suddenly, unexpectedly, and 

unlawfully announced that it would be stopping the supply of Connectors to 

Bosch. JST disputes Bosch’s right to certify a different supplier for different 

connector parts at plants not subject to the parties’ supply agreements. JST also 

claims that Bosch disclosed JST’s confidential information to other suppliers. 

Both claims are baseless. 

3. In any event, such claims are to be resolved, as the parties agreed, 

by mediation and arbitration, and Defendants are contractually required to 

continue supplying the Connectors pending a resolution of these contract 

disputes through mediation and arbitration (which have not yet occurred). 

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4. A shutdown in the supply of Connectors will be catastrophic. 

Bosch assembles the Connectors supplied by JST into body control modules and 

airbag control modules that Bosch sells to General Motors and Daihatsu (a 

Toyota affiliate), respectively. 

5. With respect to General Motors, JST’s refusal to ship Connectors 

will jeopardize approximately 3.8 million General Motors vehicles annually, 

which represents 46% of General Motors’ global volume production. The 

following vehicles will be threatened: (a) Chevrolet: Equinox, Aveo, Trax, 

Camaro, Colorado, Canon, Volt, Cruze, Malibu, Trailblazer, S10, Spark, Legacy, 

Orlando, and Tracker; (b) Buick: Regal, Verano, Lacrosse, SRX, ELR, CT6, 

Excelle, Anthem, and Encore; (c) GMC: Terrain; (d) Opel: Astra, Corsa, 

Insignia, and Mokka; and (e) Holden: Trax and Cruze (“GM affected vehicles”).

6. Bosch is the sole supplier of the body control modules for the GM 

affected vehicles. General Motors cannot manufacture those vehicles without the 

body control modules supplied by Bosch, and Bosch cannot manufacture the 

body control modules without the Connectors supplied by JST.

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7. Daihatsu, likewise, will be significantly harmed by JST’s cessation 

of supply.1

 

8. Absent injunctive relief, Bosch will begin to run out of Connectors 

in its production facilities as early as the second half of June 2015. 

9. Without JST’s supply of Connectors, Bosch’s deliveries to General 

Motors and Daihatsu will therefore halt, and these customers will be unable to 

continue to manufacture and sell the affected vehicles within weeks.

PARTIES AND JURISDICTION

10. Robert Bosch LLC is a Delaware limited liability company with its 

principal place of business in Farmington Hills, Michigan. Robert Bosch LLC 

conducts business in this judicial district. 

11. Bosch Automotive Products (Suzhou) Co., Ltd. is a Chinese 

corporation with its principal place of business in Suzhou, China. 

12. JST Japan is a Japanese corporation with its principal place of 

business in Osaka, Japan. JST Japan conducts business in this judicial district. 

 1

 Additionally, JST has threatened to cut off the supply of different connectors 

for other programs, which involve customers other than General Motors and 

Daihatsu. Bosch’s Verified Amended Complaint does not presently request 

injunctive and other relief associated with these other programs and customers, 

but Bosch reserves the right to amend its pleadings in the event that JST’s actions 

threaten a shutdown on these other programs. 

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13. JST Illinois is an Illinois corporation with its principal place of 

business in Illinois. JST Illinois conducts business in this judicial district.

14. Upon information and belief, JST America is an Illinois corporation 

with its principal place of business in Illinois. JST America conducts business in 

this judicial district.

15. JST America and JST Illinois are authorized agents of JST Japan, 

conducting business on its behalf with full authority to bind JST Japan in business 

transactions within this judicial district.

16. Venue and jurisdiction are proper in this Court because there is 

diversity of citizenship and the amount in controversy, exclusive of interest and 

attorney fees, is in excess of $75,000.

GENERAL ALLEGATIONS

17. JST has supplied Connectors to Bosch since 2008.

18. Bosch assembles the Connectors into body and airbag control 

modules, which Bosch sells to General Motors and Daihatsu, respectively. 

19. The following agreements detail and govern the supply relationship 

between Bosch and JST: (a) Master Pricing Contract, No. K01MC12AB6/1, 

dated February 15, 2013 and Master Pricing Contract, No. K01YC14AB6/0, 

dated January 1, 2014 (jointly, “Pricing Contracts,” Ex. A.); (b) the Robert Bosch 

LLC North American Terms and Conditions of Purchase (“POTC,” Ex. B); 

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(c) the Confidential Information and Non-Disclosure Agreement and Grant of 

License effective March 1, 2005 (“Non-Disclosure Agreement,” Ex. C.); (d) a 

Corporate Agreement dated April 29, 2009 (“Corporate Agreement,” Ex. D.); 

and (e) Pre-Production Agreement dated May 4, 2007 (“Pre-Production 

Agreement,” Ex. E.).

20. The Pricing Contracts, among other things, obligate JST to provide

the Connectors for the General Motors production over a five-year period (2012-

2017). (Ex. A.) 

21. The POTC is explicitly incorporated by reference into the Pricing 

Contracts (“. . . the Robert Bosch LLC Terms and Conditions shall apply”) and 

governs the dispute resolution procedures between Bosch and JST regarding the 

Connectors.

22. The Non-Disclosure Agreement pertains to the obligations to 

protect certain confidential information of the parties.

23. The Corporate Agreement contains specific provisions regarding 

termination and cancellation of the supply relationship, including proper notice 

requirements. Section 18 of the Corporate Agreement imposes a “resupply 

obligation” on JST continuing for 10 years. (Ex. D.) And Section 3 allows 

Bosch to extend supply for 8 months after expiration of any supply agreement. 

(Ex. D.)

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24. The Pre-Production Agreement, among other things, sets the pricing 

schedule for the Connectors. (Ex. E.)

25. The Non-Disclosure Agreement, Corporate Agreement, 

Pre-Production Agreement, Pricing Contracts, and related scheduling 

agreements, releases, and POTC are collectively referred to as the “Supply 

Agreements.”

SUPPLY DISPUTE

26. Earlier this year, in late February 2015, JST advised Bosch that it 

would no longer supply Connectors for the body control modules Bosch supplies 

to General Motors (cutting Bosch off in March 2015), because Bosch certified an 

additional supplier in order to meet demands for a different part not subject to 

the Supply Agreements. 

27. In March 2015, the top automotive purchasing executive in the 

Bosch group of companies, Albin Ettle, traveled from Germany to Singapore to 

meet with JST’s president, Masao Yoshimura. Although the Supply Agreements 

obligate JST to supply Bosch’s requirements for the Connectors through 2017, 

JST demanded that Bosch make a final “spot buy” for 13 months’ worth of 

supply with a volume commitment of 300,000 Connectors per month for the 

General Motors production. Faced with the prospect of immediate production 

shutdowns, Bosch agreed to these new terms to mitigate its damages and as a 

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gesture of good faith (Bosch did so under protest). 

28. With the understanding that such modifications had resolved the 

parties’ supply dispute, Bosch issued a Purchase Order on May 14, 2015. 

29. Unexpectedly, on May 15, 2015, JST reneged on the proposed 

contract modifications, sent correspondence attempting to immediately cancel 

the Supply Agreements, and advised Bosch that JST would no longer ship 

Connectors to Bosch for the General Motors production, nor honor Bosch 

releases issued after May 8, 2015. (Ex. F.) Thereafter, JST has announced that it 

will not supply Connectors necessary for Bosch to continue to produce airbag 

control modules for Daihatsu.

30. JST has also refused Bosch’s requests to participate in additional 

negotiations. (Ex. G.)

31. JST’s conduct is improper and contrary to JST’s supply obligations 

under the Supply Agreements.

32. Upon information and belief, JST refuses to continue performance 

because of a contract dispute relating to whether the Supply Agreements entitle 

JST to be the exclusive supplier for all types of connector parts purchased by 

Bosch or just the Connectors (i.e., whether Bosch may obtain different connector 

parts for other projects from a different supplier). 

33. Upon information and belief, JST threatens a cessation of supply 

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because JST wants Bosch to give up its right to source different connector 

business to a different supplier. 

34. With respect to body control modules supplied to General Motors, 

Bosch has fulfilled its commitment to source JST for 100% of the Connectors 

ordered by two Bosch plants subject to the Supply Agreements (Suzhou, China 

and Juarez, Mexico). 

35. There is nothing in the Supply Agreements that prohibits Bosch 

from using a different supplier for different parts for other Bosch facilities, which 

are not subject to the Supply Agreements.

36. JST’s demand for exclusivity beyond what is required by the 

Supply Agreements is improper. 

37. JST also claims, incorrectly, that Bosch has provided confidential 

information of JST to other suppliers. 

38. Bosch denies any wrongdoing, particularly any breach of the 

Supply Agreements or any other agreement with JST.

39. Bosch has continued to place orders for and accept shipments of, 

and pay for, the Connectors despite the parties’ disagreements as to exclusivity. 

JST AGREED TO CONTINUE SUPPLYING

CONNECTORS PENDING MEDIATION AND ARBITRATION

40. With respect to Connectors supplied by JST for body control 

modules supplied to General Motors, JST agreed to resolve any contract dispute, 

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not in this proceeding, but via good faith discussions, mediation and arbitration. 

(Ex. B, POTC ¶ 32.1, parties agree to participate in (a) “good faith 

negotiations,” (b) “non-binding mediation by a mediator approved by both 

parties,” and, then, if necessary, (c) “binding arbitration.” Id; emphasis added.)

41. “[Pending mediation or arbitration,] the parties shall continue to 

perform their obligations under the Contract.” (Ex. B, POTC ¶ 32.1; emphasis 

added.)

42. No mediation or arbitration has occurred.

43. Under these circumstances, JST may not cease supply to improve 

its bargaining position on this, or any, contract dispute with Bosch. 

44. Moreover, JST has agreed that monetary damages are not a 

sufficient remedy for [Bosch for] any actual, anticipated or threatened breach of 

the Supply Agreements by JST, and that “[Bosch is] entitled to specific 

performance including injunctive or other equitable relief” as a remedy for any 

JST breach of its “obligations in connection with the production or delivery of 

[the Connectors].” (Ex. B, POTC ¶ 8.2 (emphasis added).) 

45. JST’s dispute, to the extent applicable to the Daihatsu-related 

Connectors, is subject to different purchase terms and conditions, which 

authorize a lawsuit in this jurisdiction.

46. If JST fails to produce and deliver the Connectors to Bosch, Bosch 

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will not be able to continue its supply of control modules as early as the second 

half of June 2015.

47. Daihatsu and General Motors will be unable to continue to 

manufacture and sell their vehicles within weeks. 

48. The financial and reputational damage to Bosch, General Motors, 

and Daihatsu will be irreparable, immediate, and devastating.

49. On May 15, 2015, Bosch wrote to JST, stating that, if JST stopped 

shipments of the Connectors, Bosch would have to take action to prevent an 

imminent and catastrophic production shutdown. (Ex. G.)

50. Bosch cannot, because of the time required to resource and 

revalidate the Connectors and prepare them for delivery to General Motors and 

Daihatsu, easily or quickly resource this business to another supplier. 

51. At present, JST and another company, Foxconn, supply connectors 

to Bosch for other General Motors programs that are separate and distinct from 

the programs mentioned in paragraph 5 above. 

52. Foxconn, however, lacks the capacity to take over JST’s business.2

 2 Bosch validated Foxconn previously for different connectors in different Bosch 

plants, which are not subject to the Supply Agreements. Bosch turned to Foxconn 

because JST had indicated an inability to supply these different connector parts 

required at non-Supply Agreement-plants.

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53. JST’s Connectors are necessary and critical to numerous General 

Motors and Daihatsu programs, and Bosch’s inability to provide these 

components will cause immediate and severe harm to Bosch, General Motors, 

and Daihatsu.

COUNT I

INJUNCTIVE RELIEF

54. Bosch incorporates by reference all preceding paragraphs.

55. JST agreed to supply Bosch with the Connectors until at least 2017.

56. Nevertheless, JST recently stated that it will stop supplying the 

Connectors to Bosch and sent correspondence purportedly cancelling all of the 

Supply Agreements.

57. The Supply Agreements, by their own terms, require JST to 

continue supply (e.g., Connectors for control modules supplied to General 

Motors must be supplied through 2017).

58. JST’s actions threaten the “just-in-time” supply chain for numerous 

General Motors and Daihatsu programs, and Bosch’s delivery of control modules 

(using the Connectors) will halt as early as the second half of June 2015 if JST

is permitted to cease shipment of the contracted Connectors.

59. Bosch cannot obtain the Connectors from a substitute source in 

sufficient quantities and in sufficient time to prevent irreparable harm to Bosch, 

General Motors, and Daihatsu.

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60. As a direct result of JST’s improper actions, the harm to Bosch is 

immediate, irreparable and not quantifiable (let alone easily quantifiable) by a 

court of law. 

61. There is no harm to JST by requiring the continued supply of 

Connectors in accordance with the parties’ Supply Agreements.

62. Every day that goes by when the Connectors are not being 

manufactured and prepared for delivery to Bosch intensifies Bosch’s urgent 

predicament with General Motors and Daihatsu.

63. In the absence of injunctive relief, Bosch will suffer irreparable 

harm in the form of lost goodwill and permanent damage to its customer 

relationships.

WHEREFORE, Bosch requests that this Court enter the following orders:

a. Temporary, preliminary, and permanent injunctive relief, under 

Fed. R. Civ. P. 65, preventing JST from taking any action 

inconsistent with its supply obligations to Bosch;

b. Temporary, preliminary, and permanent mandatory injunctive relief, 

under Fed. R. Civ. P. 65, requiring JST to supply Bosch pursuant 

to the Supply Agreements to satisfy Bosch’s reasonable 

requirements for the General Motors and Daihatsu programs

specified above;

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c. An award of legal fees and other costs arising out of JST’s breach of 

contract; and

d. All other relief that this Court deems just, equitable, or 

appropriate under the circumstances.

COUNT II

BREACH OF CONTRACT

(Bosch asserts this Count in the event JST refuses to mediate and/or arbitrate its 

contract dispute with Bosch and if this Court does not order binding arbitration.)

64. Bosch incorporates by reference all preceding paragraphs.

65. Bosch and JST are parties to the Supply Agreements.

66. Bosch has fully complied with all of its obligations under the 

Supply Agreements.

67. By refusing to supply Bosch with Connectors under the Supply 

Agreements, JST has anticipatorily repudiated and breached the Supply 

Agreements. 

68. As a direct and proximate result of JST’s breach, Bosch has suffered 

and will continue to suffer substantial damages.

WHEREFORE, Bosch requests that this Court enter a judgment in its favor 

and against JST in an amount in excess of $75,000.00 to which it is found to be 

entitled, plus interest, costs, and attorneys’ fees.

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COUNT III

SPECIFIC PERFORMANCE

(Bosch asserts this Count in the event JST refuses to mediate and/or arbitrate its 

contract dispute with Bosch and if this Court does not order binding arbitration.)

69. Bosch incorporates by reference all preceding paragraphs.

70. There is no adequate remedy at law for the harm caused by JST’s 

actual and anticipatory breach of the Supply Agreements.

71. Pursuant to MCL § 440.2716, Bosch is entitled to specific 

performance. Section 2716 states, in pertinent part, that “[s]pecific performance 

may be decreed where the goods are unique or in other proper circumstances.” 

72. Proper circumstances exist here because the Connectors are unique, 

and Bosch is not able to obtain an alternative source of supply in sufficient 

quantities and in sufficient time to avoid irreparable harm. 

WHEREFORE, Bosch requests that this Court enter the following orders:

a. JST is ordered to supply Connectors to Bosch pursuant to the 

parties’ Supply Agreements until further order of Court; and 

b. JST is ordered to comply with the dispute resolution procedures 

agreed to in the Supply Agreements until further order of Court.

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COUNT IV

TORTIOUS INTERFERENCE WITH CONTRACT

(AGAINST JST JAPAN ONLY)

(Bosch asserts this Count in the event JST refuses to mediate and/or arbitrate its 

contract dispute with Bosch and if this Court does not order binding arbitration.)

73. Bosch incorporates by reference all preceding paragraphs.

74. Bosch and General Motors are parties to agreements providing, 

among other things, for Bosch to supply body control modules to General Motors.

75. Bosch and Daihatsu are parties to agreements providing, among 

other things, for Bosch to supply airbag control modules to Daihatsu.

76. JST Japan is well aware of Bosch’s supply agreements with General 

Motors and Daihatsu.

77. JST Japan recently stated that it will stop the supply of Connectors to 

Bosch and JST purportedly cancelled all Supply Agreements with Bosch with the 

unlawful and tortious intention of disrupting Bosch’s business relationships with 

General Motors and Daihatsu. Upon information and belief, JST Japan seeks to 

leverage the consequent supply disruption as a means of obtaining more favorable 

contract rights than those presently afforded to JST Japan under the Supply 

Agreements with Bosch.

78. Such interference by JST Japan is without reasonable justification, 

tortious and has caused injury and damages to Bosch. 

79. Such interference by JST Japan, if not ended shortly by injunctive 

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order, will directly cause Bosch to breach its agreements with General Motors and 

Daihatsu.

80. Bosch’s injury and damages will continue and dramatically increase 

unless injunctive relief is granted in Bosch’s favor against JST Japan.

WHEREFORE, Bosch requests that this Court enter a judgment in its favor 

and against JST Japan in an amount in excess of $75,000.00 to which it is found 

to be entitled, plus interest, costs, and attorneys’ fees.

COUNT V

TORTIOUS INTERFERENCE WITH CONTRACT

(AGAINST JST AMERICA AND JST ILLINOIS ONLY)

(Bosch asserts this Count in the event JST refuses to mediate and/or arbitrate its 

contract dispute with Bosch and if this Court does not order binding arbitration. 

Moreover, Bosch pleads Count V alternatively in the event no privity of contract is 

found between Bosch and JST America and/or JST Illinois.)

81. Bosch incorporates by reference all preceding paragraphs.

82. Bosch and JST Japan are parties to the Supply Agreements, which, 

among other things, require JST Japan to supply the Connectors to Bosch.

83. Similarly, Bosch and General Motors are parties to agreements, 

which, among other things, require Bosch to supply certain body control modules

to General Motors. 

84. Bosch also is a party to agreements with Daihatsu, which, among 

other things, require Bosch to supply certain airbag control modules to Daihatsu.

85. JST America and/or JST Illinois are well aware of the foregoing 

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contracts between (a) Bosch and JST Japan; (b) Bosch and General Motors, and 

(c) Bosch and Daihatsu.

86. JST America and/or JST Illinois recently sent Bosch notices of 

cancellation of the Supply Agreements. 

87. JST America and/or JST Illinois also recently advised Bosch that 

they are stopping all supply of the Connectors.

88. Such interference by JST America and/or JST Illinois is unlawful, 

tortious, and without legitimate business purpose. These defendants are disrupting 

supply as a means of obtaining more favorable contract rights than those presently 

afforded in Supply Agreements with Bosch.

89. Such interference by JST America and/or JST Illinois has caused JST 

Japan to breach the Supply Agreements.

90. Such interference by JST America and/or JST Illinois, if not ended 

shortly by injunctive order, will cause Bosch to breach the agreements with 

General Motors and Daihatsu.

91. Such interference by JST America and/or JST Illinois has caused 

injury and damages to Bosch. 

92. Bosch’s injury and damages will continue and dramatically increase 

unless injunctive relief is granted in Bosch’s favor against JST.

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WHEREFORE, Bosch requests that this Court enter a judgment in its favor 

and against JST America and/or JST Illinois in an amount in excess of 

$75,000.00 to which it is found to be entitled, plus interest, costs, and attorneys’ 

fees.

/s/ S. Thomas Wienner (P29233)

Seth D. Gould (P45465)

WIENNER & GOULD, P.C.

950 W. University Dr., Ste. 350

Rochester, MI 48307

twienner@wiennergould.com

sgould@wiennergould.com

-- and --

Alan N. Salpeter

Dina M. Hayes

KAYE SCHOLER LLP

Three First National Plaza

70 West Madison Street, Ste. 4200

Chicago, IL 60602

alan.salpeter@kayescholer.com

dina.hayes@kayescholer.com

Attorneys for Plaintiffs

Dated: May 25, 2015

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

ROBERT BOSCH LLC and 

BOSCH AUTOMOTIVE PRODUCTS 

(SUZHOU) CO., LTD.,

Plaintiffs, Case No. 2:15-cv-11832-AC-EAS

v. Hon. Avern Cohn

J.S.T. MFG. CO., LTD., 

J.S.T. SALES AMERICA INC., and

J.S.T. CORPORATION,

Defendants.

__________________________________________________________________/

S. Thomas Wienner (P29233) Alan N. Salpeter

Seth D. Gould (P45465) Dina M. Hayes

Daniel K. Beitz (P47451) KAYE SCHOLER LLP 

WIENNER & GOULD, P.C. Attorneys for Plaintiffs

Attorneys for Plaintiffs 70 West Madison Street, Ste. 4200

950 W. University Dr., Ste. 350 Three First National Plaza

Rochester, MI 48307 Chicago, IL 60602

(248) 841-9400 (312) 583-2300

twienner@wiennergould.com alan.salpeter@kayescholer.com

sgould@wiennergould.com dina.hayes@kayescholer.com

dbeitz@wiennergould.com

Bruce L. Sendek (P28095)

BUTZEL LONG PC

Attorneys for Defendants

150 W. Jefferson Ave., Ste. 100

Detroit, MI 48226

(313) 225-7000

sendek@butzel.com

__________________________________________________________________/

CERTIFICATE OF SERVICE

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CERTIFICATE OF SERVICE

I hereby certify that on today’s date, I caused the electronic filing of First 

Amended Complaint Verified with the Clerk of the Court using the electronic case 

filing system which will send notification of such filing to all filing users indicated 

on the electronic notice list through the Court's electronic filing system.

/s/ S. Thomas Wienner (P29233)

Seth D. Gould (P45465)

WIENNER & GOULD, P.C.

950 W. University Dr., Ste. 350

Rochester, MI 48307

(248) 841-9400; Fax: 652-2729

twienner@wiennergould.com

sgould@wiennergould.com

Dated: May 25, 2015

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