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Apex Ventures v. ByteStream Solutions

Software Development Agreement Dispute | Contract Value: $485,000
Sergei Tokmakov, Esq. | Cal Bar #279869 | Book Consultation
Client Workroom
December 23, 2025
$485K
Contract Value
$127K
Amount Disputed
4
Key Issues
12
Documents
3
Parties
Executive Summary Active Dispute

Apex Ventures LLC engaged ByteStream Solutions Inc. for custom enterprise software development under a $485,000 fixed-price contract executed March 15, 2025. The project involved building a proprietary inventory management system with AI-powered forecasting capabilities.

After multiple missed milestones and delivery of a product that failed acceptance testing, Apex withheld the final payment of $127,000. ByteStream has threatened litigation claiming the deliverables met specifications, while Apex maintains the software fails critical performance benchmarks outlined in the SOW.

Resolution deadline: January 15, 2026 (contractual dispute resolution period expires)

Core Legal Issues Analysis
Critical Breach of Contract

ByteStream failed to deliver software meeting SOW specifications by the agreed deadline.

  • Document all missed milestones
  • Compile acceptance test failures
  • ? Calculate actual damages
  • ? Review cure period requirements
High Performance Standards

Delivered software fails to meet contractual performance benchmarks.

  • API response time > 500ms (spec: <200ms)
  • Database queries timeout under load
  • ? Get independent technical assessment
High IP Ownership

Dispute over ownership of custom code and derivative works.

  • Review IP assignment clause
  • ? Identify third-party libraries used
  • ? Verify license compliance
Medium Dispute Resolution

Contract requires mediation before litigation.

  • Review ADR clause
  • ? Identify qualified mediators
  • ? Prepare mediation brief
Recommended Strategy Action Plan

Two-Track Approach

Track 1: Negotiated Resolution
Send formal demand letter outlining breaches and propose settlement at 60% of disputed amount ($76,200) in exchange for full IP transfer and release.
Track 2: Litigation Preparation
Preserve all communications, obtain independent technical evaluation, and prepare breach of contract claim with damages calculation.

Immediate Action Items

Priority Action Purpose
1 Send formal breach notice Trigger cure period under Section 8.2 of the Agreement
2 Document all deficiencies Create detailed technical report of specification failures
3 Engage technical expert Independent assessment of software quality and specification compliance
4 Calculate actual damages Include delay costs, remediation expenses, lost business opportunity

Detailed Issue Analysis

1 Material Breach Analysis Critical

KEY QUESTIONS:

  • Does the failure to meet performance specifications constitute material breach?
  • Has ByteStream been given adequate opportunity to cure under Section 8.2?
  • Can Apex recover consequential damages for business disruption?

Breach Evidence Summary:

Specification Required Actual Status
API Response Time < 200ms 580ms average FAIL
Concurrent Users 500+ ~150 before timeout FAIL
Uptime SLA 99.9% 94.2% (test period) FAIL
Data Export All formats CSV only PARTIAL

Attorney Analysis

The documented performance failures likely constitute material breach under California law. The specifications were expressly bargained-for terms, and ByteStream's failure to meet them goes to the essence of the agreement. The cure period under Section 8.2 (30 days from written notice) should be triggered immediately to preserve all remedies.

2 Damages Calculation High Priority
Damage Category Amount Notes
Withheld Payment $127,000 Final milestone payment
Remediation Costs $45,000 (est.) Third-party developer quote to fix issues
Delay Damages $28,000 3-month delay at $9,333/mo operational cost
Lost Business $85,000 (est.) Delayed product launch revenue
TOTAL POTENTIAL DAMAGES $285,000 Subject to limitation of liability clause review

Project Timeline

March 15, 2025
Contract Executed
Software Development Agreement signed. Total value: $485,000. Initial payment of $145,500 (30%) made.
Contract
April 30, 2025
Milestone 1 Delivered
Requirements documentation and system architecture approved. Payment of $97,000 (20%) made.
Payment
June 30, 2025
Milestone 2 Delivered
Core functionality demo accepted with minor issues noted. Payment of $97,000 (20%) made.
Payment
August 15, 2025
Milestone 3 Delayed
ByteStream requests 30-day extension citing "technical challenges with AI integration."
Delay
September 30, 2025
Milestone 3 Partial Delivery
Beta version delivered. Performance testing reveals significant issues. Conditional acceptance pending fixes.
November 1, 2025
Final Delivery Fails Acceptance
Final software delivery fails acceptance testing on 4 of 6 critical performance metrics. Apex rejects delivery.
Breach
November 15, 2025
Payment Withheld
Apex formally notifies ByteStream of rejection and withholds final $127,000 payment pending cure.
Dispute
December 1, 2025
ByteStream Threatens Litigation
ByteStream's counsel sends demand letter claiming full payment owed, threatens lawsuit.
December 23, 2025
Workroom Created
Legal analysis and strategy development in progress.

Document Repository

📁 Core Agreements 3
📕 Software Dev Agreement.pdf
Master agreement - $485,000 fixed price
📕 Statement of Work.pdf
Technical specs and milestones
📕 Change Order #1.pdf
AI feature addition (+$35,000)
📁 Testing & QA 4
📕 Acceptance Test Results.pdf
⚠ 4 of 6 metrics failed
📕 Performance Benchmarks.pdf
Independent technical assessment
📕 Bug Tracking Export.pdf
47 critical/high bugs unresolved
📕 Load Test Logs.pdf
Server timeouts at 150 users
📁 Correspondence 3
📧 Rejection Notice.pdf
Nov 15, 2025 - Formal rejection
📧 ByteStream Demand.pdf
Dec 1, 2025 - Litigation threat
📧 Email Thread.pdf
Full correspondence history
📁 Payments 2
💰 Payment History.pdf
$358,000 paid to date
💰 Invoice #4 (Disputed).pdf
$127,000 - withheld pending cure
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Documents Pending Signature

Document Sent To Status Action
Software Development Agreement - Amendment #2 Marcus Chen (ByteStream CEO) Awaiting
Mutual Release Agreement (Draft) Not yet sent Draft
NDA - Technical Expert Dr. Sarah Williams Signed

Parties & Contacts

Client
Apex Ventures LLC
Delaware LLC | Software company seeking custom inventory system
Opposing Party
ByteStream Solutions Inc.
California corporation | Software development contractor
ByteStream CEO
Marcus Chen
Primary contact and authorized signatory
Apex CEO
Jennifer Park
Client point of contact
Technical Expert
Dr. Sarah Williams
Independent software quality assessor
Opposing Counsel
Thompson & Associates LLP
Representing ByteStream Solutions

Contract Details

Field Details
Contract Type Software Development Agreement (Fixed Price)
Contract Value $485,000
Execution Date March 15, 2025
Governing Law California
Dispute Resolution Mediation required before litigation (Section 12.3)
Venue Los Angeles County, California