Cenlin Taiwan Ltd. v. Centon, Ltd.

In this diversity case under Washington law, Cenlin Taiwan Ltd. appeals the district court’s summary judgment in favor of the Bank of California (“BankCal”). Cenlin primarily argues BankCal improperly collected payment under letters of credit for which Cenlin had ultimate liability.- Cenlin also contends it should have been permitted to amend the complaint to clarify breach of warranty and negligence claims and add a claim for fraud. We have jurisdiction under 28' U.S.C. § 1291, and we affirm.

I

' Cenlin arranged to buy fruit from Centón Ltd. for export from Washington to Taiwan. Consistent with many international transactions, this arrangement included letters of credit issued by Cenlin’s banks in favor of Centón, the “beneficiary.” BankCal had a business relationship with Centón and notified Centón when the credits were issued. BankCal thus served as the “advising bank.” Cenlin was the “customer” of the credits, and its banks were the “issuers.”

The credits allowed Centón to receive payment for fruit delivered to Cenlin. To draw against the credits, Centón had only to present the credits for payment, together with appropriate documentation of orders, deliveries and the like.…