Allergy Research Group v. Rez Candles

CourtDistrict Court, D. Utah
DecidedApril 4, 2022
Docket2:21-cv-00073
StatusUnknown

This text of Allergy Research Group v. Rez Candles (Allergy Research Group v. Rez Candles) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allergy Research Group v. Rez Candles, (D. Utah 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH CENTRAL DIVISION

ALLERGY RESEARCH GROUP LLC, a Delaware limited liability company,

Plaintiff, ORDER AND MEMORANDUM DECISION vs.

Case No. 2:21-cv-73-TC-JCB

REZ CANDLES INC., a Delaware corporation,

Defendant.

Allergy Research Group (ARG) brought a complaint against Defendant Rez Candles (RC) asserting claims of trademark infringement, unfair competition, deceptive trade practices, and tortious inference with contractual relations.1 In response, RC filed three counterclaims against ARG: (1) a Sherman Act antitrust claim under 15 U.S.C. § 1 (“Concerted Refusal to Deal — Group Boycott — Authorized Sellers”); (2) “Illegal Anti-Competitive Activities” in violation of the Utah Antitrust Act; and (3) tortious interference with economic relations. ARG now asks the court to dismiss the counterclaims under Rule 12(b)(6).

1 ARG also named RC’s owner, Reza Davachi, as a defendant, but the court dismissed Mr. Davachi for lack of personal jurisdiction. (See Aug. 30, 2021 Order & Mem. Decision, ECF No. 34.) FACTUAL ALLEGATIONS ARG manufactures nutritional and dietary supplements, which it sells through its website and through distributors, resellers, and retailers who are expressly authorized by ARG to sell in their brick-and-mortar locations or on the Internet (“Authorized Sellers”). ARG’s exclusive distribution agreements with those Authorized Sellers (“Distribution Agreements”) require the

sellers to follow ARG’s quality controls and be accountable to ARG for any quality issues. According to ARG, “By distributing products exclusively in this manner, ARG is better able to control the quality and integrity of its products and ensure that customers receive accurate information about them.” (Compl. ¶ 24, ECF No. 2.) Citing the prevalence in the market of fake or compromised products bearing its trademark, and the harm such sales cause, ARG explains that its “distribution controls are intended to minimize the risk and reputational damage caused by the illegal sale of poor-quality products bearing the ARG Registered Trademarks by unauthorized sellers like [RC] who do not abide by ARG’s quality controls.” (Id. ¶ 60.) They are also “designed to protect consumers and prevent them from receiving poor quality and unsafe

products.” (Id. ¶ 73.) The Distribution Agreements require Authorized Sellers to sell ARG products through certain channels and follow ARG’s policies and procedures.2 For instance, the sellers may only purchase ARG products from ARG directly or through authorized distributors, and, apart from selling to end users, they may only sell to ARG-approved resellers. ARG also requires inspections, disclosure of shipment problems, packaging standards, and audits.

2 ARG describes its policies and procedures in more detail in paragraphs 65–70 and 76–90 of the Complaint. ARG imposes additional requirements on authorized online sellers because “ARG products sold online are more susceptible to quality and authenticity problems as consumers cannot see the products before they buy them.” (Id. ¶ 74.) Those rules require the authorized online retailers to sell ARG products through ARG-approved websites (for instance, the retailer’s proprietary website rather than an online marketplace website on Amazon.com) and to use ARG-

approved website interfaces, advertising, product descriptions, sales processes, customer feedback protocols, and the like. ARG polices the sale of its products online. In 2020, during its regular monitoring, “ARG discovered a high volume of products bearing the ARG Registered Trademarks being illegally sold by [RC] on Amazon under the storefront name ‘River of Human Health’” and RC’s “Oasis of Health” website. (Id. ¶¶ 99, 102.) RC and its owner, former Defendant Reza Davachi, were previous ARG customers who were not approved for online sales. Despite that lack of approval, RC says it “sells genuine ARG products that are not materially different from the first sale ARG products. RC has established and abides by legitimate quality

control procedures for the storage and shipment of the ARG products. The products are sold with their original packaging and RC makes clear that it is a reseller of the goods.” (Countercl. ¶ 11, ECF No. 37.) ARG notified RC and Mr. Davachi that they were not authorized to sell ARG products online and demanded that they cease sales of products bearing ARG’s registered trademarks. ARG sent three cease-and-desist letters between July 2020 and January 2021. In its letters, ARG told RC that ARG owned the trademark and that RC was interfering with ARG’s contractual relationships with the Authorized Sellers. ARG said RC would be tortiously interfering with ARG’s Distribution Agreements if it continued to purchase products bearing ARG’s trademarks from Authorized Sellers for resale outside ARG’s distribution channels. ARG also threatened legal action if RC did not stop selling the products. Despite receiving those communications, RC continued to advertise and sell the products. ARG then filed this lawsuit. RC’S COUNTERCLAIM

According to RC’s Counterclaim, ARG’s Distribution Agreements constitute a group boycott (or concerted refusal to deal) in restraint of trade. RC alleges that “ARG has illegally acquired, maintained, and exercised power in the Relevant Market through anticompetitive acts. As a result, ARG has impaired rivals leading to the anticompetitive effects of lower output, higher prices, and fewer options for consumers.” (Id. ¶ 7.) RC defines the “Relevant Market” as “the market for the sale (both first sale and resale) of non-prescription nutritional and dietary supplements within the United States.” (Id. ¶ 6.) RC characterizes the Distribution Agreements as “unlawful vertical restraints of trade” that “have created barriers to entry, limited the supply and variety of products available, inhibited

the growth and development of competitors, and artificially raised and maintained the price paid by consumers in the Relevant Market.” (Id. ¶ 30.) RC elaborates a bit on its general description of antitrust harm, contending that ARG’s anticompetitive behavior has led to at least the following harm in the Relevant Market: (1) reduced supply of non-prescription nutritional and dietary supplements, (2) fewer options for consumers for where and how to purchase non-prescription nutritional and dietary supplements, (3) the limitation of innovation from the entry and growth of competitors, (4) supra-competitive prices for consumers for non-prescription nutritional and dietary supplements, and (5) increased market dominance by ARG. (Id. ¶ 19.) RC also alleges personal harm. The Distribution Agreements constitute “important means of acquiring ARG products” that deprive it of the ability “to re-sell genuine ARG products,” “to sell non-ARG nutritional and dietary supplements on [its] Amazon storefront,” and to sell “the inventory that it had purchased.” (Id. ¶¶ 21, 29.) According to RC, the group boycott has hindered RC’s ability “to build its reputation and brand in some of the most important retail and online marketplaces,” and RC has “obtained lower revenues than it would have obtained in a competitive market.” (Id. ¶¶ 20–21, 29.) RC further alleges that its “market

position is a sliver of what it could and would be in a competitive market, and it has not been able to bring new, efficient, and desirable consumer innovations to its customers because of ARG’s conduct.” (Id. ¶ 22.) As for RC’s tort claim, RC alleges interference with existing as well as potential economic relations in the form of “contracts and business relationships with distributors who sell it ARG products” and “consumers to whom it sells ARG products.” (Id.

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