A Blank Rome team representing Gülipek Kumas Ve İplik Ve (“Gülipek Tech”), a Türkiye-based yarn manufacturer, obtained dismissal with prejudice of Frontline Fabrics, Inc.’s negligence claim in the U.S. District Court for the Eastern District of Pennsylvania (Frontline Fabrics, Inc. v. Gülipek Kumas Ve İplik Ve, et al., Case No. 25-7342-KSM).
Frontline, a Pennsylvania-based manufacturer of flame-resistant products, alleged it lost approximately $1.4 million after alleging that criminals impersonated a Gülipek Tech employee, and directed it to route payments to a fraudulent bank account. It claimed Gülipek Tech negligently failed to secure its computer systems, detect the intrusion, or warn it of the compromise.
In a 30-page opinion issued September 1, 2026, U.S. District Judge Karen Spencer Marston granted Gülipek Tech’s motion to dismiss the negligence claim with prejudice. The Court held that Gülipek Tech did not owe Frontline a cognizable duty of care under Pennsylvania law. The Court distinguished the Pennsylvania Supreme Court’s decision in Dittman v. UPMC — which recognized a cybersecurity duty for entities that affirmatively collect and store sensitive personal data — finding that Gülipek Tech’s routine business communications about invoices and a planned bank account were not affirmative, risk-causing conduct warranting a heightened duty. Applying the five-factor Althaus test, the Court found that policy considerations did not support a new duty.
Because Gülipek Tech owed no duty of care as a matter of law the Court dismissed the claim with prejudice.
The Blank Rome team was led by Bradley L. Henry in coordination with Mehmet Baysan, Fieldfisher (London), and Egemen Egemenoğlu, Egemenoğlu (Türkiye).