Hmm
Without additional details, I'm going to have to side with IBM on this one. Products packed on pallets are not meant for bumpy rides, they are meant for smooth rides. How much higher was this "raised surface at the entry door of the warehouse" than the ground outside the door? How fast was the forklift moving at the time? How tall was the crate? Sounds fishy to me.
On a side note, they say the server cost $1.4 million, so they're suing for that and more. Is that $1.4 million the real cost (what IBM charged them), or is it what they were charging the USPTO? Because you know there's a huge difference.