To pursue a Chapter 93A claim, there must be some business,
commercial, or transactional relationship between the plaintiff(s)
and the defendant(s).An indirect commercial link—such as
upstream purchasers—may be sufficient to state a valid claim,
but there must ultimately be some commercial connection between the
plaintiff and defendant.The District of Massachusetts and the
Appeals Court of Massachusetts recently affirmed this requirement
in two separate cases.
First, the District of Massachusetts affirmed this principle
when it denied plaintiffs' motion for leave to conduct limited
discovery, as the allegations in the complaint only highlighted the
commercial relationship between the various defendants and not with
the plaintiff. In Courtemanche v. Motorola
Sols., Inc., plaintiffs brought a putative class action
against a group of commercial defendants and the superintendent of
Massachusetts State Police, alleging that the State Police
unlawfully recorded