Angry Chickz, Inc. v. Bosphorus Trade, Inc.

CourtDistrict Court, N.D. California
DecidedJune 10, 2024
Docket3:23-cv-03569
StatusUnknown

This text of Angry Chickz, Inc. v. Bosphorus Trade, Inc. (Angry Chickz, Inc. v. Bosphorus Trade, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Angry Chickz, Inc. v. Bosphorus Trade, Inc., (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 SAN JOSE DIVISION 7 8 ANGRY CHICKZ, INC., Case No. 23-cv-03569-VKD

Plaintiff, 9 INTERIM ORDER RE PLAINTIFF’S v. MOTION FOR DEFAULT JUDGMENT 10

11 BOSPHORUS TRADE, INC., et al., Re: Dkt. No. 20 Defendants. 12

13 14 Plaintiff Angry Chickz, Inc. (“Angry Chickz”) moves for entry of default judgment against 15 defendants Bosphorus Trade, Inc. (“Bosphorus”) and Salih Inci. Dkt. No. 20. Neither defendant 16 has appeared and the Clerk has entered default against them. Dkt. No. 18. The Court previously 17 found this matter suitable for determination without oral argument. See Civil L.R. 7-1(b); Dkt. 18 Nos. 24, 27. 19 Having reviewed Angry Chickz’s complaint, motion for default judgment, and supporting 20 documents, it appears that Angry Chickz is entitled to judgment in its favor on liability. However, 21 Angry Chickz seeks injunctive relief that does not comply with Rules 65(d) and 54(c) of the 22 Federal Rules of Civil Procedure. Accordingly, the Court issues this interim order regarding the 23 merits of Angry Chickz’s motion and requests a further submission regarding the proposed 24 injunction. 25 I. BACKGROUND 26 According to the complaint, Angry Chickz owns, operates, and franchises a chain of 27 “Angry Chickz” restaurants serving Nashville hot chicken. Dkt. No. 1 ¶¶ 10-11. Two of these 1 Defendant Bosphorus operates “The Angry Hot Chicken,” a restaurant which also serves 2 Nashville hot chicken. Id. ¶ 24. Bosphorus’s restaurant is also located in San Jose. Id. 3 Defendant Inci is Bosphorus’s chief executive officer and a resident of Milpitas. Id. ¶ 4. 4 Angry Chickz alleges that defendants have copied many distinctive features of its business 5 and asserts claims against defendants for trademark and trade dress infringement under section 6 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), and under California common law. Id. ¶¶ 39-58. 7 Specifically, Angry Chickz alleges that its restaurants are characterized by a distinctive menu, 8 décor, and design, and that its restaurants are strongly associated with certain design and word 9 marks. See id. ¶¶ 10-23. Angry Chickz also alleges that defendants’ restaurant includes many 10 elements that are confusingly similar to the distinctive features of Angry Chickz’s restaurants. See 11 id. ¶¶ 24-38. 12 Angry Chickz says that, since 2018, it has spent “considerable time, effort and money” 13 promoting its “Angry Chickz” brand on restaurant signage, packaging and promotional materials, 14 on its website (www.angrychickz.com), and on social media platforms like Facebook, Instagram, 15 and Yelp. Id. ¶ 22. According to Angry Chickz, its trademarks and trade dress have “gained 16 substantial fame among consumers of Nashville hot chicken-style food” and that “[a]s a result, the 17 ANGRY CHICKZ marks are easily recognized, well-known, and famous in California, Nevada, 18 [and] Arizona.” Id. ¶ 23. 19 Angry Chickz claims the name of defendants’ restaurant, “The Angry Hot Chicken,” is 20 confusingly similar to the “Angry Chickz” name for its own restaurants. Id. ¶ 32. It also alleges 21 that defendants display the “Angry Hot Chicken” name and branding in their restaurant, on 22 publicity and promotional materials, on their website (www.theangryhotchicken.com), and on 23 social media platforms like Facebook, Instagram, and Yelp. Id. ¶ 25. 24 In addition, Angry Chickz alleges that defendants copied distinctive features of its menu. 25 First, like Angry Chickz, defendants sell a chicken with French fries combination as “Angry 26 Fries” and a chicken with macaroni and cheese combination as “Angry Mac.” Id. ¶¶ 18-19, 29-30, 27 33. Second, like Angry Chickz, defendants’ menu includes the same four combinations of chicken 1 and French fries; (2) two hot chicken tenders over white bread with pickles and French fries; (3) 2 one hot chicken slider and one chicken tender over white bread, coleslaw, pickles, and French 3 fries; and (4) two hot chicken tenders over rice topped with coleslaw and pickles.”), ¶ 26 (The 4 Angry Hot Chicken combos: “(1) two chicken tenders served on white bread with French fries and 5 pickles; (2) two chicken sliders served with coleslaw, pickles, and French fries; (3) one chicken 6 tender and one chicken slider served with French fries; and (4) two chicken tenders served with 7 mac and cheese and French fries.”). Third, Angry Chickz’s menu allows customers to select from 8 one of six playfully named levels of “heat” or spiciness, represented by a stylized image of a 9 thermometer and the words “(1) Country (No Heat); (2) Mild (Light Spice); (3) Medium (Perfect 10 Heat); (4) Hot (Feel The Burn); (5) X-Hot (Call 911); and (6) Angry (Sign A Waiver).” Id. ¶ 15. 11 Similarly, the Angry Hot Chicken’s menu also includes a stylized image of a thermometer with 12 five levels of “heat” accompanied by the words “(1) Country (No Heat), (2) Medium (Light 13 Spice), (3) Hot Shot (Perfect Heat), (4) Extra Hot (Feel The Burn), and (5) Reaper (Sign Waiver).” 14 Id. ¶ 28. Angry Chickz’s complaint includes photographs of its menus and defendants’ menus. 15 Id. ¶ 14 (Angry Chickz menu); ¶¶ 26, 28 (The Angry Hot Chicken menu). 16 Angry Chickz also claims that defendants’ restaurant shares many of the same physical 17 design elements that characterize its own restaurants. It alleges that all Angry Chickz restaurants 18 feature a white, black and red color scheme, with murals of cartoon chickens, wood-grained tables 19 with red metal chairs, and a partially open kitchen, and that The Angry Hot Chicken’s décor 20 features these same design elements. Id. ¶¶ 17, 31. Additionally, Angry Chickz alleges that 21 employees at both restaurants wear black shirts with the restaurant’s logo, black pants, and a red or 22 black apron. Id. ¶¶ 17, 21, 31. 23 Angry Chickz alleges that it has used the names, marks, menu, décor, and other design 24 elements described above in commerce since 2018. Id. ¶¶ 10-23. 25 In November of 2022, Angry Chickz’s counsel sent a letter to defendants, asking that they 26 “alter their trade name and branding” to avoid infringing on Angry Chickz’s trademarks. Dkt. No. 27 1 ¶ 36; Dkt. No. 20-1 ¶¶ 5-6, Ex. 2. However, Angry Chickz’s attempts to resolve this dispute 1 Bosphorus and Mr. Inci were served on September 16 and 18, 2023, respectively. Dkt. Nos. 9, 10. 2 Angry Chickz later stipulated to an extension of defendants’ deadline to respond to the complaint 3 to October 24, 2023. Dkt. No. 13. Neither defendant filed a timely response to the complaint, and 4 on November 2, 2023, at Angry Chickz’s request, the Clerk entered default against both 5 defendants. Dkt. Nos. 16, 18. 6 On January 2, 2024, Angry Chickz filed a motion for entry of default judgment. Dkt. No. 7 20. Defendants did not file a response. Thereafter, the Court deemed the matter suitable for 8 resolution without oral argument. Dkt. No. 24. On February 8, 2024, Mr. Inci filed a motion to 9 reschedule the hearing to give him time to “find an attorney/legal support.” Dkt. No. 25. The 10 Court denied the motion to reschedule the hearing, having already concluded that the matter could 11 be resolved without oral argument. Dkt. No. 27. The Court has received no further 12 communication from either defendant. 13 II. LEGAL STANDARD 14 The Clerk must enter default against a party who fails to plead or otherwise defend an 15 action. Fed. R. Civ. P. 55(a). After entry of default, a court may, in its discretion, enter default 16 judgment. Fed. R. Civ. P. 55(b)(2);1 Aldabe v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Qualitex Co. v. Jacobson Products Co.
514 U.S. 159 (Supreme Court, 1995)
Wal-Mart Stores, Inc. v. Samara Brothers, Inc.
529 U.S. 205 (Supreme Court, 2000)
Dastar Corp. v. Twentieth Century Fox Film Corp.
539 U.S. 23 (Supreme Court, 2003)
Bogosian v. Woloohojian
158 F.3d 1 (First Circuit, 1998)
Alvera M. Aldabe v. Charles D. Aldabe
616 F.2d 1089 (Ninth Circuit, 1980)
Gary R. Eitel v. William D. McCool
782 F.2d 1470 (Ninth Circuit, 1986)
Skydive Arizona, Inc. v. Quattrocchi
673 F.3d 1105 (Ninth Circuit, 2012)
Reno Air Racing Association, Inc. v. Jerry McCord
452 F.3d 1126 (Ninth Circuit, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
Angry Chickz, Inc. v. Bosphorus Trade, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/angry-chickz-inc-v-bosphorus-trade-inc-cand-2024.