Amazon.com Inc., et al. v. Michael Bartley, et al.

District Court, W.D. Washington·Decided June 30, 2026·No. 2:24-cv-01188·Unknown

Opinion

UNITED STATES DISTRICT COURT AT SEATTLE AMAZON.COM INC., et al., CASE NO. C24-1188-KKE

Plaintiff(s), ORDER GRANTING MOTION FOR v. DEFAULT JUDGMENT

MICHAEL BARTLEY, et al.,

Defendant(s).

Plaintiff The Ergo Baby Carrier, Inc. (“Ergo”) created and designed babywearing carriers that are sold by more than 700 retailers in the United States and more than 50 other countries. Dkt. No. 49 ¶ 3. Together with Plaintiffs Amazon.com, Inc. and Amazon.com Services LLC (collectively “Amazon”), Ergo filed this action alleging that Defendants—“a collection of individuals and entities who conspired and operated in concert with each other to engage in the counterfeiting scheme alleged in this [action]”—sold counterfeit Ergo products in Amazon’s store. Id. ¶¶ 5, 9. Plaintiffs have dismissed their claims against some of the Defendants. Dkt. Nos. 55, 56, 57, 59, 77, 78, 79, 88. Defendants Sebastian Gonzales Rojas and Seymour Watson (doing business as Ethanmour Holdings LLC) have not appeared or otherwise defended this action, and the Court entered orders of default against them. Dkt. Nos. 70, 74. Plaintiffs now seek a default judgment and permanent injunction against those two Defendants (hereinafter “Defaulted Defendants”). Dkt. No. 82. 1 Because Plaintiffs have shown that they are entitled to default judgment on their claims against the Defaulted Defendants, and the Court will grant Plaintiffs’ motion and award the damages and injunctive relief Plaintiffs request. Plaintiffs’ operative complaint alleges that between May 5, 2021, and February 7, 2024, Defendants advertised, marketed, offered, distributed, and/or sold counterfeit Ergo-branded products via multiple Amazon Selling Accounts, using marks owned by Ergo (“Ergobaby Trademarks”) without authorization to deceive customers about the authenticity and origin of the products and the products’ affiliation with Ergo. Dkt. No. 49 ¶¶ 41–62. In this action, Ergo asserts claims for trademark counterfeiting and infringement against all Defendants. Id. ¶¶ 63–69. All Plaintiffs also bring claims against all Defendants for false designation of origin and for violation of Washington’s Consumer Protection Act (“CPA”). Id. ¶¶ 70–85, 112–16. Plaintiffs also bring

contributory trademark infringement and contributory false designation of origin claims against Watson. Id. ¶¶ 86–111. Amazon.com Services LLC (“Amazon Services”) separately brings a breach of contract claim against Rojas. Id. ¶¶ 117–22. For the following reasons, the Court will grant Plaintiffs’ motion for default judgment against the Defaulted Defendants. Dkt. No. 82. A. The Court Has Jurisdiction over the Subject Matter and the Parties. Before entering default judgment, the Court must confirm that it has both subject matter and personal jurisdiction. See In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999) (“When entry of judgment is sought against a party who has failed to plead or otherwise defend, a district court has

1 The Court refers to the parties’ briefing by CM/ECF page number. an affirmative duty to look into its jurisdiction over both the subject matter and the parties.”). The Court has federal question jurisdiction over Plaintiffs’ claims for trademark infringement, false designation of origin, and false advertising. Dkt. No. 49 ¶ 22. The Court also

has personal jurisdiction over Defendants. A forum selection clause alone can confer personal jurisdiction. Chan v. Soc’y Expeditions, Inc., 39 F.3d 1398, 1406–07 (9th Cir. 1994). The Business Solutions Agreement (“BSA”) between Amazon and Rojas provides that Amazon may bring claims related to counterfeit products in the “Governing Courts,” and the BSA defines “Governing Courts” as any state or federal court in King County, Washington, which includes this Court. Dkt. No. 49 ¶ 24. The Court also has personal jurisdiction over both Rojas and Watson because they purposefully directed their unlawful activities toward, and consummated transactions in, Washington. Id. ¶¶ 23, 25–26. Accepting Plaintiffs’ factual allegations as true, the Court has jurisdiction over the claims

presented in this lawsuit as well as the Defaulted Defendants. B. Legal Standards on a Motion for Default Judgment The Court’s decision to enter a default judgment is discretionary. Aldabe v. Aldabe, 616 F.2d 1089, 1092 (9th Cir. 1980). The Court “ordinarily disfavor[s]” default judgment because “[c]ases should be decided upon their merits whenever reasonably possible.” Eitel v. McCool, 782 F.2d 1470, 1472 (9th Cir. 1986). In considering a motion for default judgment, the Court accepts “the well-pleaded factual allegations” as true, but “necessary facts not contained in the pleadings, and claims which are legally insufficient, are not established by default.” Cripps v. Life Ins. Co. of N. Am., 980 F.2d 1261, 1267 (9th Cir. 1992) (citation modified). When considering whether to exercise its discretion to enter a default judgment, the Court

may consider the following Eitel factors: (1) the possibility of prejudice to the plaintiff, (2) the merits of plaintiff’s substantive claim, (3) the sufficiency of the complaint, (4) the sum of money at stake in the action; (5) the possibility of a dispute concerning material facts; (6) whether the default was due to excusable neglect, and (7) the strong policy underlying the Federal Rules of Civil Procedure favoring decisions on the merits.

Eitel, 782 F.2d at 1471–72. The Western District of Washington also requires a party seeking default judgment to provide “a declaration and other evidence establishing plaintiff’s entitlement to a sum certain and to any nonmonetary relief sought.” Local Civil Rules W.D. Wash. LCR 55(b)(2). “A default judgment must not differ in kind from, or exceed in amount, what is demanded in the pleadings.” Fed. R. Civ. P. 54(c). C. Plaintiffs are Entitled to Default Judgment Against the Defaulted Defendants. The Court applies the Eitel factors to this case and finds that they favor a default judgment as requested by Plaintiffs. 1. Possibility of Prejudice to Plaintiffs For the first Eitel factor, the Court analyzes the possibility of prejudice to Plaintiffs. Prejudice exists when “the plaintiff has no recourse for recovery other than default judgment.” Curtis v. Illumination Arts, Inc., 33 F. Supp. 3d 1200, 1211 (W.D. Wash. 2014) (cleaned up). In this case, the Defaulted Defendants have failed to respond to or otherwise defend against Plaintiffs’ complaint. Without a default judgment, Plaintiffs would have no recourse. Therefore, the Court finds the first Eitel factor favors a default judgment. 2. Sufficiency and Merits of Plaintiffs’ Complaint The Court analyzes the second and third Eitel factors—the merits of Plaintiffs’ substantive claim and the sufficiency of the complaint—together. See, e.g., Curtis, 33 F. Supp. 3d at 1211. For the following reasons, the Court finds that Plaintiffs have alleged facts in their complaint showing that the Defaulted Defendants are liable on the claims upon which default judgment is requested. a. Ergo’s Trademark Counterfeiting and Infringement Claim

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Amazon.com Inc., et al. v. Michael Bartley, et al., (W.D. Wash. 2026).

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