American Social IP, LLC v. Powell

CourtDistrict Court, S.D. Florida
DecidedJuly 10, 2025
Docket1:23-cv-24875
StatusUnknown

This text of American Social IP, LLC v. Powell (American Social IP, LLC v. Powell) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Social IP, LLC v. Powell, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:23-cv-24875-LEIBOWITZ

AMERICAN SOCIAL IP, LLC and 721 LAS OLAS BLVD., INC.,

Plaintiffs, v.

JERRY POWELL,

Defendant. ______________________________________________/

ORDER THIS CAUSE comes before the Court on Plaintiffs American Social IP, LLC and 721 Las Olas Blvd, Inc.’s, (collectively, “Plaintiffs”) Motion for Summary Final Judgment (“the Motion”), filed on June 16, 2025. [Mot., ECF No. 73]. Plaintiffs’ Motion was filed in response to this Court’s prior order requiring all parties to submit briefing, pursuant to Rule 56(f) of the Federal Rules of Civil Procedure, regarding whether Plaintiffs are entitled to final judgment on both of Plaintiffs’ claims. [ECF No. 72]. Defendant Jerry Powell (“Powell”) filed a brief pursuant to Rule 56(f) arguing that summary judgment should be granted in his favor. [ECF No. 75].1 After a review of the Motion, the record, and the applicable case law, the Motion is denied and summary judgment is granted in favor of Powell. PROCEDURAL HISTORY Plaintiffs filed this case on December 22, 2023, against Powell and a John Doe Corporation. [Compl., ECF No. 1]. Plaintiffs then moved twice for ex parte Temporary Restraining Orders, which

1 Plaintiffs requested that this Court strike Powell’s filing. [ECF No. 77]. This Court takes no position on whether the filing should be stricken because the Court comes to the same conclusion with or without considering Powell’s filing. the Court denied for Plaintiffs’ failure to establish that the Court should issue temporary restraining orders without notice to Defendants. [ECF Nos. 10, 11, 14, 16]. Powell first appeared in this case on March 14, 2024, and filed an Answer. [ECF No. 19]. Plaintiffs later learned the identity of the previously asserted John Doe Corporation and filed their First Amended Complaint on August 14, 2024, naming both Powell and First Street Hilmar, LLC (“First Street Hilmar”) as Defendants. [First Am. Compl., ECF No. 41]. Plaintiffs sufficiently served First Street Hilmar with a copy of the First

Amended Complaint and Summons to Michael Warda, the registered agent for service, but never appeared in the case. [Aff. of Deputy Sheriff Jared Silva, ECF No. 67-5]. After Powell failed to follow United States Magistrate Judge Jonathan Goodman’s order requiring Powell to file an electronic notice listing an email address and telephone number for Plaintiffs’ counsel for purposes of conferral regarding this case, Judge Goodman recommended that this Court enter a default against Powell. [ECF No. 56]. The Court agreed, and the Clerk of Court entered a default against Powell. [ECF Nos. 58, 59]. Plaintiffs then filed their Motion for Default Final Judgment on December 18, 2024. [ECF No. 61]. The Court denied the Motion without prejudice for three reasons. [ECF No. 66]. First, the Court questioned whether Plaintiffs provided the Court with adequate service of process on First Street Hilmar.2 [Id. at 4–5]. Second, the Court did not believe that Plaintiffs established personal jurisdiction over First Street Hilmar because they failed to allege First Street Hilmar had sufficient

“minimum contacts” in the state of Florida and that Section 48.193, Florida Statutes, did not apply to First Street Hilmar. [Id. at 5–6]. Lastly, the Court concluded that Plaintiff failed to show that Defendants violated the Lanham Act, and failed to show there was a likelihood of confusion between the marks. [Id. at 6–8]. Plaintiffs then filed an Amended Motion for Default Final Judgment. [ECF

2 Plaintiffs later provided sufficient proof of service on First Street Hilmar in the Amended Motion. [Aff. of Deputy Sheriff Jared Silva, ECF No. 67-5]. No. 67]. The Court found that it had no personal jurisdiction over First Street Hilmar, and dismissed it. [ECF No. 70 at 5–8]. Next, the Court found that Plaintiffs, even on default, failed to show that Powell’s use of “American Social” was likely to cause confusion between Plaintiffs’ “American Social” mark, and thus Plaintiffs were not entitled to default judgment on their trademark infringement claim. [Id. at 8–14]. Finally, the Court found that Plaintiffs did not establish that they were entitled to default judgment on their claim under the Florida Deceptive and Unfair Trade Practices Act (“FDUTPA”),

because Plaintiffs failed to establish their first claim of trademark infringement. [Id. at 14–15]. Plaintiffs then filed a Motion to Alter or Amend Judgment or Motion for Relief from a Judgment or Order on May 20, 2025. [ECF No. 71]. Plaintiffs requested that this Court reconsider its prior order and grant the motion for default. [Id.]. On May 26, 2025, this Court denied that motion and ordered the parties to submit briefing on whether the Plaintiffs were entitled to final judgment on both of their counts, pursuant to Rule 56(f) of the Federal Rules of Civil Procedure. [ECF No. 72]. Plaintiffs then filed this Motion on June 16, 2025. [Mot.]. BACKGROUND Plaintiff American Social IP, LLC (“American Social IP”) is a Florida limited liability company that “at all relevant times has been the owner of two of the federal trademarks to be enforced in this action[]” which have been used in commerce “since at least 2011.” [Plaintiffs’ Statement of Material Facts (“SMF”), ECF No. 74 ¶ 1]. American Social IP owns the marks “AMSO AMERICAN SOCIAL

BAR AND KITCHEN” (U.S. Registration No. 6016227) and “AMSO” (U.S. Registration 5749498). [Id.]. Plaintiff 721 Las Olas Blvd., Inc., is a Florida profit corporation that “at all relevant times has been the owner/holder of the registered mark ‘AMERICAN SOCIAL’ (Word mark, U.S. Registration No. 7402201)[.]” [Id. ¶ 2].3 Plaintiffs have operated a chain of restaurants named “American Social”

3 The registration for this mark “inadvertently lapsed on December 8, 2023. The mark was, however, reinstated on May 28, 2024.” [SMF ¶ 2]. This, however, does not preclude relief in favor since 2011 and currently operate restaurants in five Florida cities. [Id. ¶ 5]. Plaintiffs claim they have “enormous internet presence and invest substantial resources in their marketing campaigns” which has helped them “establish[] a national presence through collaboration with global brands and other vendors.” [Id.]. Powell is a resident of California and the owner of the restaurant at issue in this case. [Id. ¶ 4]. Powell, “without authorization or license from the Plaintiffs, opened a restaurant called ‘American

Social’ in Ripon, California” on or about August 2023. [Id. ¶ 9]. Plaintiffs sent Powell two separate cease and desist letters “on or about November 21, 2023, and subsequently on December 6, 2023,” demanding that he “completely cease use of Plaintiffs’ marks.” [Id. ¶ 11]. Powell utilized Plaintiffs’ marks on social media between December 2023 until May 2024. [Id. ¶¶ 12–13]. Defendant “change[d] the restaurant’s name from American Social to Ripon Social, but all or most of the older posts still utilize the American Social name and hashtag, which have remained available for the public to see and engage with.” [Id. ¶ 13]. Defendant’s social media and website “continue to contain Plaintiffs’ American Social word mark[,]” and Defendant has not provided proof to Plaintiffs that they are no longer using the American Social name at their restaurant. [Id. ¶ 14–15]. LEGAL STANDARD ¶ A court “shall grant summary judgment if the movant shows that there is no genuine dispute

as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a).

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