Case: 1:23-cv-01636 Document #: 1 Filed: 03/15/23 Page 1 of 17 PageID #:1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

KING SYKES LLC, an Illinois limited liability )

company, )
)
Plaintiff, )
)
vs. )
)
THE CITY OF CHICAGO, a municipal corporation; )
MAURICE COX, in his Official Capacity as )
Commissioner of the Department of Planning and ) No. 23-cv-1636
Development of the City of Chicago; SAMIR )
MAYEKAR, in his Official Capacity as Deputy Mayor ) JURY DEMAND
of the City of Chicago; SOPHIA KING, in her Official )
Capacity as Alderperson for the 4th Ward of the City of )
Chicago; SCOTT GOODMAN; GRIT CHICAGO LLC, )
a Delaware limited liability company; and FARPOINT )
DEVELOPMENT LLC, an Illinois limited liability )
company, )
)
Defendants. )

COMPLAINT

Plaintiff King Sykes LLC, an Illinois limited liability company (“Plaintiff” or “King

Sykes”), by its attorneys, for its Complaint against Defendants City of Chicago (“the City”),

Maurice Cox (“Cox”), Samir Mayekar (“Mayekar”), Sophia King (“King”) (Cox, Mayekar, and

King are referred to collectively as the “Individual City Defendants”), Scott Goodman, GRIT

Chicago LLC (“GRIT Chicago”), and Farpoint Development LLC (“Farpoint”) (Scott Goodman,

GRIT Chicago, and Farpoint are referred to collectively as “Goodman”), alleges as follows:

INTRODUCTION

1. Plaintiff owns a large, valuable piece of property in Chicago’s Bronzeville

neighborhood. Plaintiff’s property is immediately adjacent to the former Michael Reese

Hospital, which is slated for a massive redevelopment by a joint venture between the City and
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Goodman. Plaintiff would like to sell its property. The City and Goodman would like to own

Plaintiff’s property—eventually. But they do not want to buy it yet, and they do not want to pay

fair market value for it. Instead, they would like to make Plaintiff’s property unmarketable until

they are ready to buy it, and then to buy it at a discount.

2. The City (primarily through King and Mayekar) and Goodman (who claims to

speak for his co-venturer, the City) have conspired to scare off potential buyers of the Plaintiff’s

property—including one that even signed a purchase contract. They have done so by making it

known to the marketplace that the City will never give the required approvals necessary to develop

Plaintiff’s property for any use to any buyer other than itself, i.e., the City-Goodman joint venture.

In this way. they have made the Plaintiff’s property unsaleable to any other buyer. Indeed,

Defendants’ motives were laid bare when they told Plaintiff’s potential buyer, a data center

operator, that it would never get the necessary City approvals to operate a data center on Plaintiff’s

property – then assured that very same operator that it would have no problem obtaining the

required approvals if it were to build a data center across the street, on the City’s Michael Reese

property.

3. This conduct by the City and Goodman is actionable pursuant to 42 U.S.C. § 1983

for violations of Plaintiff’s constitutionally protected equal protection rights and rights under the

Takings Clause of the Fifth Amendment, as well as conspiracy by the Individual City Defendants

and Goodman to commit those constitutional violations. In addition, Goodman—no mere

competitor—has engaged in tortious interference with Plaintiff’s prospective economic

opportunity by wrongfully causing a purchaser of the Plaintiff’s property to terminate the deal.

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PARTIES

4. Plaintiff King Sykes LLC is an Illinois limited liability company with its principal

place of business in Chicago, Illinois.

5. Defendant City of Chicago is a municipal corporation, duly incorporated under the

laws of the State of Illinois, and is the employer and principal of the other City Defendants.

6. Defendant Sophia King is an official of the City of Chicago, and since April 2016

has been the Alderperson of the 4th Ward. Under City practices and procedure, King has

substantial control over zoning and other development decisions within the 4th Ward, and has

effective veto power over any such zoning approvals and decisions in the 4th Ward.

7. Defendant Maurice Cox is an employee of the City of Chicago, and is the

Commissioner of the Department of Planning and Development (“DPD”) of the City of Chicago.

8. Defendant Samir Mayekar is an employee of the City of Chicago, and the Deputy

Mayor of the City of Chicago.

9. Defendant Scott Goodman is an individual who resides in Cook County, Illinois.

10. Defendant GRIT Chicago LLC is a Delaware limited liability company with its

principal place of business in Chicago, Illinois. Upon information and belief, Scott Goodman

controls GRIT Chicago LLC through Farpoint Development LLC, its managing member.

11. Defendant Farpoint Development LLC is an Illinois limited liability company with

its principal place of business in Chicago, Illinois. Scott Goodman is a manager of Farpoint

Development LLC. Upon information and belief, Scott Goodman controls Farpoint Development

LLC.

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JURISDICTION AND VENUE

12. Jurisdiction is proper in the United States District Court for the Northern District

of Illinois pursuant to 28 U.S.C. §§ 1331 and 1343(a) because this case involves a civil action

arising under the laws of the United States, specifically 42 U.S.C. § 1983.

13. This Court has supplemental jurisdiction over the claims asserted under Illinois law

pursuant to 28 U.S.C. § 1367.

14. Venue is appropriate in the Northern District of Illinois because a substantial part

of the events or omissions giving rise to the claim occurred, and the real property involved in this

suit is located, in this judicial district. 28 U.S.C. § 1391(b)(2).

FACTUAL ALLEGATIONS

15. Plaintiff King Sykes is the owner of an approximately 6.5-acre panel located at

2545-55 South King Drive in Chicago (the “KS Site”). This is the northeast corner of 26th Street

and King Drive. Plaintiff has owned the KS Site since 2007.

16. Since approximately 2009, the City has owned the property immediately across

26th Street from the KS Site, at the southeast corner of 26th Street and King Drive. The City’s

property, which runs south to 31st Street, is known as the Michael Reese Site.

Prior Michael Reese Site History/RFP

17. On October 12, 2016, the City of Chicago released a request for proposals for the

purchase and redevelopment of the Michael Reese Site (the “RFP”).

18. The Michael Reese Site RPF stated that:

“In cooperation with the Metropolitan Pier and Exposition Authority (”MPEA”),
DPD will also consider proposals that will redevelop, (1) the Michael Reese Site
together with the property commonly referred to as the McCormick Place
marshalling yards (the “Marshalling Yards Site”), or (2) the Michael Reese Site
together with the Marshalling Yards Site and the property bounded by E. 25th
Street to the north, E. 26th Street to the south, Dr. Martin King Luther Drive to

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the west, and the Metra right-of-way to the east (“the “Advocate/McDonald’s
Site”).”

19. The RFP further noted that the “Advocate/McDonald’s Site currently has four

owners and is not controlled by the City or MPEA.” The KS Site is one of the four sites that

comprise what the RFP called the “Advocate/McDonald’s Site.” Plaintiff is one of the “four

owners” referred to in the RFP.

20. The Michael Reese Site, Marshalling Yards Site, and the Advocate/McDonald’s

Site (which includes the KS Site) are all located in Chicago’s 4th Ward. At all relevant times,

the Alderperson of the 4th Ward was Sophia King.

21. The RFP invited developers to work with the City in developing the KS Site as

part of the Michael Reese development. For example, the RFP stated:

“If the Selected Developer has included the Advocate/McDonald’s Site in their
Development Proposal, the Selected Developer must commit to acquire the
Advocate/McDonald’s Site through private negotiations with the current owners.
However, if private negotiations fail and the City elects, in its own discretion, to
acquire the property through eminent domain, then the developer must commit to
pay the fair market value of the land as determined by a court, plus the City’s
acquisition costs.”

22. In sum, the City solicited redevelopment proposals for the City-owned Michael

Reese Site. But the City was also inviting developers to consider including two adjacent

properties in their proposals. These adjacent parcels were (a) the Marshalling Yards (owned by

MPEA) and (b) the “Advocate/McDonald’s Site” (owned by Plaintiff and others).

23. In June 2017, the City selected GRIT Chicago as the developer for the Michael

Reese RFP. Farpoint is a principal member of the GRIT Chicago development team, and Scott

Goodman is a manager of Farpoint. Upon information and belief, Goodman directed the actions

of GRIT Chicago and Farpoint at all relevant times.

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24. After GRIT Chicago’s selection as developer of the Michael Reese site, Goodman

acted in conjunction with the City and as the City’s agent and co-joint venturer in developing the

Michael Reese Site. In that role, Goodman and the City sought to control and acquire the KS

Site.

25. On or about August 28, 2017, Brett Walrod, a representative of King Sykes, met

with Scott Goodman and another representative of the GRIT Chicago development team.

Goodman told Walrod that David Riefman (then the DPD Commissioner) had encouraged him to

use the KS Site in his plans and marketing materials. Goodman further stated that he “needed”

the KS Site, but not for another 5 to 10 years. Goodman further stated that he and “his friends”

would oppose any use Plaintiff might propose for the site, and that Plaintiff would never get

zoning for any use of the KS Site, purportedly because it was “not in the public’s best interest”.

26. What Goodman meant was that he and the City would prevent Plaintiff from

selling or developing the KS Site because they wanted to buy it at an artificially low price in the

distant future as part of their plans for all three sites.

27. Since GRIT Chicago was selected as developer of the Michael Reese site,

Goodman has worked with the City on long-term plans for a “Bronzeville Lakefront”

development, which would include the Michael Reese Site and—in Goodman’s vision— the

Marshalling Yards Site and the Advocate/McDonald’s Site, which included the KS Site.

Plaintiff’s Deal With Equinix

28. In April 2020, Plaintiff and Equinix, LLC, an international digital infrastructure

company, began discussing a potential sale of the KS Site to Equinix, and Equinix began due

diligence. Equinix proposed to develop a new, state-of-the-art, multi-user data center on the KS

Site.

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29. On or about September 8, 2020, Plaintiff and Equinix executed an Agreement to

Purchase Real Estate, under which Equinix would purchase the KS Site for $30 million. Equinix’s

obligation to purchase the Property was conditioned upon it obtaining the required “Governmental

Approvals” (as defined in that agreement) during the Inspection Period (i.e., August 4 to November

2, 2020), including “all licenses, planned development approvals, zoning changes, [and] site plan

approvals…”

City/Goodman Frustrate The Plaintiff’s Contract With Equinix

30. Equinix began work on obtaining Governmental Approvals for its proposed data

center, and began engaging with the City and King. On September 10, 2020, the Equinix team

participated in a video conference meeting with King’s team to begin a dialogue about the

proposed data center. At that meeting, King said that “we have plans for that site” – in other words,

that King would oppose Equinix getting the necessary approvals for its data center, because the

City wanted to purchase the KS Site.

31. On September 24, 2020, Equinix submitted a pre-application submission depicting

the proposed data center which included a data center, a parking structure, and additional surface

parking for the data center to the City (DPD) and King.

32. Over the next few months, Equinix had extensive discussions with various City

officials, including King, her chief of staff, Mayekar, and Cox, about obtaining the required

governmental approvals for the data center. Goodman was involved in many of those discussions.

33. On or about November 16, 2020, there was a call among King, Goodman, DPD and

Equinix. At this meeting, Goodman pitched to Equinix the idea of buildings its data center on the

Michael Reese Site rather than the KS Site. And on or about December 10, 2020, in a meeting

with Equinix and the City, Goodman again told Equinix that it should move its planned data center

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to the Michael Reese Site. By this time, the City was siding with King and Goodman about

building the data center on the Michael Reese Site.

34. On December 22, 2020, Equinix and Plaintiff executed a First Amendment to

Agreement to Purchase Real Estate. That First Amendment extended the inspection period for

the Purchase Contract, in which Equinix was to obtain the necessary Governmental Approvals,

to April 30, 2021.

35. Upon information and belief, on January 8, 2021, Equinix representative(s) had a

call with King and Goodman. On that call, King told Equinix that the City would not grant

Equinix the required approvals because the City wanted to purchase the KS Site, and to purchase

it “cheap.” King wanted only one data center in the area—the one she and Goodman had

suggested for the Michael Reese Site.

36. Equinix, however, preferred the KS Site to the proposed Michael Reese location

due to, among other things, the economics of a data center; connectivity and distance to existing

fiber optic cable and power; better infrastructure; and the cost to go vertical vs. horizontal

expansion over time.

37. On February 11, 2021, King arranged a call with Equinix and Goodman. That

call took place on February 19, 2021. During that call, Goodman told Equinix that Goodman

and the City were trying to obtain Plaintiff’s property for “cheap.”

38. On February 22, 2021, Equinix requested that Plaintiff delay the closing of the

Equinix purchase of the KS Site for 6 to 12 months.

39. On March 16, 2021, King, Mayekar, Goodman and representative(s) of Equinix

met. King told Equinix that: (a) Equinix would never get the required approvals to build the data

center on the KS Site; (b) Plaintiff would never get the required approvals to build on the KS

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Site; and (c) the reason for (a) and (b) was that “we [King, the City, and Goodman] have plans

for the King Sykes Site.”

Equinix Terminates the Plaintiff/Equinix Contract and Goodman/City Swoop In

40. At this point, Equinix had been told definitively that it would never obtain the

governmental approvals necessary under its agreement with Plaintiff to build the data center on

the KS Site. And at the same time, Equinix was told by King and Goodman that it could build its

proposed data center just across the street from the KS Site.

41. On April 30, 2021, Equinix provided Plaintiff a “Notice of Termination of

Purchase Agreement.”

42. Thereafter, Equinix entered into negotiations with Goodman to purchase the land

across the street from the KS Site.

43. With Equinix’s $30 million purchase contract terminated, Goodman set about

executing their plan to buy the KS Site for “cheap.”

44. Goodman then met with Plaintiff to discuss buying the KS Site. On July 1, 2021,

Plaintiff met with Goodman, who said he would make an offer for the KS Site but it “won’t be

data center money,” i.e., it would be less than what Equinix had contracted to pay Plaintiff.

45. On July 20, 2021, the DPD gave a presentation to the Chicago City Council

Committee on Housing and Real Estate, which included contemplation of a data center at the

Michael Reese Site.

46. The next day, on July 21, 2021, the City Council amended the Chicago Zoning

Ordinance to adopt the Michael Reese Planned Development (“PD 1509”), and approved the

Bronzeville Lakefront Agreement for the Sale and Redevelopment of Land (the “Redevelopment

Agreement”). The amendment listed as a permitted use in PD 1509: “Electronic Data Storage

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Center (provided, however that not more than one Electronic Data Storage Center shall be

located within this Planned Development).”

47. Under the Redevelopment Agreement, the City agreed to engage in a series of

sales to GRIT Chicago of several parcels of land comprising the Michael Reese Site for a total

purchase price that depends in part on the success of the project.

48. The City and Goodman manifested their intent to become joint venturers in the

redevelopment and completion of PD 1509 by entering into the Redevelopment Agreement and

by the City’s approval of PD 1509. Among other things, the City agreed it would contribute to

infrastructure development within the site while GRIT Chicago would construct commercial,

institutional, and housing structures, and completion of the redevelopment would require

continued, close collaboration between the City and GRIT Chicago. The joint venture was

expected to generate significant profits for GRIT Chicago, which would be shared with the City.

49. Subsequently, on or about May 5, 2022, Plaintiff’s representatives met with King

and her chief of staff. King said she would support development of the KS Site, but then stated

that Plaintiff wanted “too much” for the KS Site and suggested $15 million as a fair price, which

was half of what Equinix had agreed to pay Plaintiff, until the City and Goodman made closing

that deal impossible.

50. The next month, on or about June 24, 2022, Equinix had a phone call with King’s

chief of staff. He reiterated that the City/King would not support development of the KS Site,

which would remain “amorphic” until the City decided what its plans were for the site. Of

course, no potential purchaser would want to buy the KS Site when—just like with Equinix—the

City was not going to approve any use for the Site.

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51. Later, on or about November 28, 2022, Goodman, through a company he controls

called Decennial DX Management LLC, sent an offer to Plaintiff for the purchase and sale of the

KS Site for $15,000,000. That offer was to expire on December 7, 2022. Plaintiff refused this

low-ball offer.

COUNT I
Against City of Chicago
(5th Amendment Takings Clause; Section 1983)

52. Plaintiff restates and incorporates by reference Paragraphs 1 - 51 of this Complaint

as Paragraph 52, as if fully set forth herein.

53. The City engaged in a regulatory taking of Plaintiff’s private property without just

compensation when, on March 16, 2021, King and Mayekar, speaking for the City itself, stated

that Equinix would not get the required approvals to build its data center on the KS Site, and that

Plaintiff would never get the required approvals to build on the KS Site, because “we [King, the

City, and Goodman] have plans for King Sykes.”

54. The City confirmed its regulatory taking of Plaintiff’s private property when King’s

chief of staff, speaking for King and the City, stated in June 2022 that the City would not support

development of the KS Site, which would remain “amorphic” until the City decided what its plans

were for the site.

55. Prior to the City’s taking in March 2021, Plaintiff and Equinix had an agreement

under which Equinix would purchase the KS Site for $30 million, conditioned on Equinix’s ability

to obtain appropriate governmental approvals.

56. Equinix subsequently terminated its contract with Plaintiff, while the KS Site was

relegated to an “amorphic” status until the City decided on its plans for the KS Site.

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57. The City proposed that the value of the KS Site was $15 million, which is the same

amount that Goodman, through Decennial DX Management LLC, offered Plaintiff for the

purchase and sale of the KS Site.

58. The City’s refusal to allow Equinix to pursue its plans to develop the KS Site

effected a severe diminution of the value—from $30 million down to $15 million—of Plaintiff’s

property.

59. Further, the City’s arbitrary and capricious decision to block redevelopment of the

KS Site for any purpose while it decides how the KS Site will fit into the overall redevelopment

of the Michael Reese Site has rendered the KS Site unsaleable to any other buyer.

60. The City’s refusal to permit development of the KS Site was not designed to

promote the public good in any manner.

COUNT II
Against Individual City Defendants
(Section 1983 – Equal Protection – Class of One)

61. Plaintiff restates and incorporates by reference Paragraphs 1 - 60 of this Complaint

as Paragraph 61, as if fully set forth herein.

62. The Individual City Defendants intentionally treated Plaintiff differently than

others similarly situated. Plaintiff, a property owner in the immediate vicinity of a planned

redevelopment, was intentionally treated differently by the Individual City Defendants with

respect to obtaining necessary governmental approvals for development of the KS Site.

63. The Individual City Defendants unequivocally stated that Plaintiff’s property

would not obtain necessary governmental approvals for Equinix to build its proposed data center

on the KS Site. Likewise, the Individual City Defendants unequivocally stated that Plaintiff would

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not obtain necessary governmental approvals to build on the KS Site and that the KS Site would

remain “amorphic” until the City decided what its plans were for the site.

64. Goodman and the Individual City Defendants engaged Equinix to locate its data

center on a Michael Reese parcel of land immediately across 26th Street from the KS Site. On

information and belief, that parcel, which is comparable to the KS Site, did not face similar threats

from the Individual City Defendants regarding appropriate government approvals.

65. There was no rational basis for the difference in treatment between Plaintiff and

Goodman, as the parcels of property were comparable in all material respects and suitable for

Equinix’s data center.

66. The Individual City Defendants were motivated by illegitimate animus against the

Plaintiff.

67. By making it known to the marketplace that neither Plaintiff nor anyone else

(including Equinix) would be able to obtain necessary governmental approvals for any

development of the KS Site, the Individual City Defendants’ treatment of Plaintiff was manifestly

unreasonable and improper, was motivated by an intent to inhibit and punish the exercise of

constitutional rights, constitutes selective and discriminatory treatment, and constitutes a denial of

Plaintiff’s equal protection rights pursuant to the United States Constitution, and constitutes a

violation of 42 U.S.C. § 1983.

68. The Individual City Defendants acted with deliberate indifference or reckless

disregard of Plaintiff’s constitutional rights to equal protection under the law.

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COUNT III
Against the Individual City Defendants & Goodman
(Conspiracy - Section 1983 – Equal Protection)

69. Plaintiff restates and incorporates by reference Paragraphs 1 - 68 of this Complaint

as Paragraph 69, as if fully set forth herein.

70. The Individual City Defendants acted in concert with Goodman pursuant to an

agreement to deprive Plaintiff of its constitutional right to equal protection under the law by

thwarting Equinix’s ability to obtain necessary governmental approvals for its proposed data center

on the KS Site, by making it known that no one would be able to obtain necessary governmental

approvals for any proposed development of the KS Site, and by subsequently steering Equinix

toward a deal with Goodman.

71. The Individual City Defendants and Goodman repeatedly participated in joint

efforts to undermine Plaintiff’s contract with Equinix and Equinix’s proposed data center on the

KS Site. King, on a call that included Goodman, communicated to Equinix that the City wanted

the KS Site for cheap. King, Mayekar, and Goodman later informed Equinix that the KS Site

would never be approved and that the City had plans for the KS Site. Equinix then terminated its

agreement with Plaintiff. At the same time, Goodman and the Individual City Defendants were

telling Equinix to locate its data center on a Michael Reese parcel of land immediately across the

street from the KS Site.

72. Goodman subsequently made an offer to purchase the KS Site for half the amount

of Plaintiff’s contract with Equinix.

73. Goodman willingly participated in the Individual City Defendants’ efforts to deny

Plaintiff its constitutionally protected right to equal protection under the law.

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74. The Individual City Defendants and Goodman acted with a calculated, deliberate,

and intentional disregard for Plaintiff’s constitutional right to equal protection under the law.

COUNT IV
Against Goodman
(Tortious Interference With Prospective Economic Opportunity)

75. Plaintiff restates and incorporates by reference Paragraphs 1 - 74 of this Complaint

as Paragraph 76 as if fully set forth herein.

76. Plaintiff had an expectancy that it would close on its contract with Equinix for the

sale of the KS Site for $30 million.

77. Goodman knew of Plaintiff’s business expectancy.

78. Goodman intentionally interfered with the Plaintiff’s expectancy by:

A. Wrongfully acting in concert with the Individual City Defendants—and abusing

Goodman’s influence pursuant to their joint venture with the City—to thwart

Equinix’s ability to obtain necessary governmental approvals for its proposed data

center on the KS Site, and thus causing Equinix to terminate its contract with

Plaintiff;

B. Luring Equinix to locate the proposed data center on the other side of the street;

and

C. Trying to muscle Plaintiff into selling the KS Site for half of the Equinix purchase

price.

79. Goodman’s intentional interference with Plaintiff’s relationship and expectancy

with Equinix resulted in Equinix’s decision to terminate the purchase contract with King Sykes;

80. Plaintiff suffered damages because of the loss of business expectancy.

81. Goodman acted with the purpose of injuring Plaintiff’s business expectancy and

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employed wrongful means in doing so by conspiring with the City to: (a) thwart Equinix’s ability

to obtain necessary governmental approvals for its proposed data center on the KS Site, and (b)

make it known to the marketplace that no one would be able to obtain necessary governmental

approvals for any proposed development of the KS Site in order to drive the price down for the

City to take the KS Site through eminent domain.

82. Goodman’s conduct was willful and done in complete disregard of Plaintiff’s

rights.

PRAYER FOR RELIEF

Wherefore, Plaintiff requests that the Court:

(a) Enter judgment in favor of Plaintiff on Count I, finding that the City violated

plaintiff’s constitutional rights by taking the KS Site for public use without just compensation;

(b) Enter an order on Count I for damages and compensation for the value of the

property taken by the City;

(c) Award compensatory and punitive damages on Count II against all Individual City

Defendants in and amount to be proven at trial, currently estimated to be an amount in excess of

$15,000,000.00;

(d) Award compensatory and punitive damages on Count III against all Individual City

Defendants and Goodman in an amount to proven at trial, currently estimated to be an amount in

excess of $15,000,000.00;

(e) Award compensatory and punitive damages on Count IV against Goodman in an

amount to be proven at trial, currently estimated to be an amount in excess of $15,000,000.00;

(f) Award Plaintiff its reasonable attorney fees, costs, and expenses pursuant to 42

U.S.C. §§ 1983 and 1988, and any other applicable law; and

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(g) For such other and further relief as is deemed appropriate in the circumstances.

JURY DEMAND

Plaintiff demands a trial by Jury on any issues triable by a Jury.

Dated: March 15, 2023 Respectfully submitted,

KING SYKES LLC

By: /s/ Michael K. Forde_______

One of Plaintiff’s Attorneys
Michael K. Forde
Kevin R. Malloy
Ellen M. Carey
Forde & O’Meara LLP
191 N. Wacker Drive, 31st Floor
Chicago, IL 60606
(312) 641-1441

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