AAA Alarm & Security Incorporated v. A3 Smart Home LP

CourtDistrict Court, D. Arizona
DecidedAugust 30, 2021
Docket2:21-cv-00321
StatusUnknown

This text of AAA Alarm & Security Incorporated v. A3 Smart Home LP (AAA Alarm & Security Incorporated v. A3 Smart Home LP) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AAA Alarm & Security Incorporated v. A3 Smart Home LP, (D. Ariz. 2021).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 AAA Alarm & Security Incorporated, No. CV-21-00321-PHX-GMS

10 Plaintiff, ORDER

11 v.

12 A3 Smart Home LP,

13 Defendant. 14 15 16 Before the Court is Plaintiff AAA Alarm & Security Incorporated’s (“Plaintiff”) 17 Application for Preliminary Injunction. (Doc. 18.) Also pending is Defendant A3 Smart 18 Home LP’s Motion to Strike the Declaration of John Konchak. (Doc. 29.) The Court held 19 an evidentiary hearing on the Motion for Preliminary Injunction on August 17 and August 20 18, 2021. For the following reasons, Plaintiff’s Motion is granted, and Defendant’s Motion 21 is denied. 22 BACKGROUND 23 Plaintiff AAA Alarm & Security, Inc. and Defendant A3 Smart Home LP provide 24 home and business security services in Arizona. Plaintiff first used the AAA mark in 1985 25 when it began operating under the name “AAA Alarm & Security.” (Doc. 18-1 at 1.) Since 26 then, Plaintiff’s business has served over 8,000 customers across Arizona. Id. at 3. Its 27 business includes use of the AAA mark on several promotional mediums, including 28 branded stickers, yard signs, magnets, vehicles, and employee T-shirts. Plaintiff also 1 advertises on its website and via print ads and promotional brochures. Id. at 2. These 2 advertising expenditures amount to nearly $200,000 since 2014. (Doc. 28-1 at 1.) 3 In Fall 2019, Plaintiff began receiving communications from people who believed 4 they were AAA Alarm & Security customers, but who were actually customers of 5 Defendant. See (Doc. 18-1 at 3–4.) A chart maintained by Plaintiff’s employees 6 documenting erroneous calls from Defendant’s customers contains over 200 entries. 7 (Doc. 18-4 at 6–19.) Plaintiff also received several mailed documents and emails directed 8 to Defendant. These included three unemployment insurance notices from the Arizona 9 Department of Economic Security, a request from a fiduciary to modify the terms of her 10 ward’s service, checks and cancellation notices addressed to Defendant from its customers, 11 and alarm permits from the City of Phoenix. (Doc. 18-1 at 4–6.) Plaintiff also received 12 false alarm notices from governmental entities. Plaintiff did not experience this confusion 13 before Defendant entered the Arizona market as AAA Smart Home. Id. at 6. 14 The American Automobile Association of Northern California, Nevada, and Utah 15 acquired an Arizona security business, SAFE Security, in November 2018. (Doc. 27-1 at 16 3.) After the acquisition, the name of the business was changed to A3 Smart Home LP and 17 it began operating under the brands “AAA Smart Home” and “AAA Smart Business.” Id. 18 A3 Smart Home has approximately 20,000 customers in Arizona. Id. A3 Smart Home’s 19 Manager of the Member Experience Monitoring Center, Jessica Winter, avows that she is 20 aware of no instance where an individual contacting Defendant was experiencing any sort 21 of confusion between it and Plaintiff’s business. (Doc. 27-2 at 3.) Although the hearing 22 testimony highlighted that she may not have been in a position to be aware of such 23 confusion. 24 DISCUSSION 25 I. Standard of Review 26 “A preliminary injunction is ‘an extraordinary and drastic remedy, one that should 27 not be granted unless the movant, by a clear showing, carries the burden of persuasion.’” 28 Lopez v. Brewer, 680 F.3d at 1068, 1072 (9th Cir. 2012) (quoting Mazurek v. Armstrong, 1 520 U.S. 968, 972 (1997)). A plaintiff seeking a preliminary injunction must show that 2 (1) it is likely to succeed on the merits; (2) it is likely to suffer irreparable harm without an 3 injunction; (3) the balance of equities tips in its favor; and (4) an injunction is in the public 4 interest. Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). 5 II. Analysis 6 A. Likelihood of success on the merits 7 AAA Alarm pleads claims for Lanham Act unfair competition, state statutory 8 trademark infringement, common law trademark infringement and unfair competition. 9 Plaintiff asserts that its common law trademark claim and state statutory trademark 10 infringement claims warrant the preliminary injunction. 11 Common law trademark claims are substantially congruent to claims made under 12 the Lanham Act. See Health Indus. Bus. Commc’ns Council Inc. v. Animal Health Inst., 13 481 F. Supp. 3d 941, 956 (D. Ariz. 2020) (collecting cases); Walker & Zanger, Inc. v. 14 Paragon Indus., Inc., 549 F. Supp. 2d 1168, 1182 (N.D. Cal. 2007) (“[I]n the Ninth Circuit, 15 claims of unfair competition and false advertising under state statutory and common law 16 are ‘substantially congruent’ to claims made under the Lanham Act”) (quoting Cleary v. 17 News Corp., 30 F.3d 1255 (9th Cir. 1994)). “The Arizona Court of Appeals has held that 18 the common law doctrine of unfair competition ‘encompasses several tort theories, such as 19 trademark infringement, false advertising, palming off, and misappropriation.’” Joshua 20 David Mellberg LLC v. Will, 96 F. Supp. 3d 953, 983 (D. Ariz. 2015) (quoting Fairway 21 Constructors, Inc. v. Ahern, 193 Ariz. 122, 124, 970 P.2d 954, 956 (Ct. App. 1998)). Courts 22 thus address Arizona common law trademark claims under the framework of federal law. 23 See 3 Ratones Ciegos v. Mucha Lucha Libre Taco Shop 1 LLC, No. CV-16-04538-PHX- 24 DGC, 2017 WL 4284570, at *2 (D. Ariz. Sept. 27, 2017) (considering plaintiff’s trademark 25 infringement and unfair competition claims together). 26 To prevail on a trademark infringement claim, a plaintiff “must prove (1) that it has 27 a protectible ownership interest in the mark; and (2) that defendant’s use of the mark is 28 likely to cause consumer confusion, thereby infringing upon [plaintiff’s] rights to the 1 mark.” Dep’t of Parks & Recreation for State of Cal. v. Bazaar Del Mundo Inc., 448 F.3d 2 1118, 1124 (9th Cir. 2006). The touchstone for trademark infringement is likelihood of 3 confusion, which asks whether a reasonably prudent consumer is “likely to be confused as 4 to the origin of the good or service bearing one of the marks.” Rearden LLC v. Rearden 5 Com., Inc., 683 F.3d 1190, 1214 (9th Cir. 2012). This determination is made by applying 6 the well-established Sleekcraft factors: (1) strength of the mark, (2) proximity of the goods, 7 (3) similarity of the marks, (4) evidence of actual confusion, (5) marketing channels used, 8 (6) types of goods and degree of care exercised by consumers, (7) defendant’s intent in 9 selecting the mark, and (8) likelihood of expansion of the product lines. AMF Inc. v. 10 Sleekcraft Boats, 599 F.2d 341, 348–49 (9th Cir. 1979). This eight-factor test is “pliant”; 11 “the relative importance of each individual factor will be case-specific.” Brookfield 12 Commc’ns, Inc. v. W. Coast Entm’t Corp., 174 F.3d 1036, 1054 (9th Cir. 1999). 13 “Utilizing the eight-factor test, plaintiffs may establish a likelihood of consumer 14 confusion as a result of either (1) forward confusion, or (2) reverse confusion.” JL 15 Beverage Co., LLC v. Jim Beam Brands Co., 828 F.3d 1098, 1106 (9th Cir. 2016) (citing 16 Surfvivor Media, Inc. v.

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AAA Alarm & Security Incorporated v. A3 Smart Home LP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aaa-alarm-security-incorporated-v-a3-smart-home-lp-azd-2021.