Recovery Express and Interstate Demolition (IDEC) are two separate corporations located at the same business address in Boston. On August 22, Albert Arillotta, a partner at IDEC, sent an e-mail to Len Whitehead, Jr., of CSX Transportation expressing an interest in buying rail cars as scrap. Arillotta represented himself to be from interstate demolition and recovery express in the e-mail. The e-mail address from which he sent his inquiry was albert@ recoveryexpress.com. Arillotta went to the CSX rail yard, disassembled the cars and transported them away. Thereafter, CSX sent invoices for the scrap railcars totaling $115,757.36 addressed to IDEC at its Boston office shared with Recovery Express. Whitehead believed Arillotta was authorized to act for Recovery Express, based on the e-mails domain namerecoveryexpress.com. Recovery claims that Arillotta never worked for it. Recoverys president Thomas Trafton allowed the fledgling company to use telephone, fax, and e-mail services at its offices, but never shared anything with IDECassets, funds, books of business, or financials with IDEC. CSX sued Recovery for the invoice amount on the doctrine of apparent authority. IDEC is now defunct. Recovery claims that Arillotta never worked for it, and it is not liable. [CSX Transportation, Inc. v. Recovery Express, Inc. 415 F.Supp.2d 6 (D. Mass.)]

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