Aram Logistics v. United States Liability Insurance Company

CourtDistrict Court, S.D. California
DecidedJanuary 31, 2024
Docket3:23-cv-01869
StatusUnknown

This text of Aram Logistics v. United States Liability Insurance Company (Aram Logistics v. United States Liability Insurance Company) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aram Logistics v. United States Liability Insurance Company, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 ARAM LOGISTICS, a California Case No.: 3:23-cv-01869-H-DEB corporation, 12 ORDER: Plaintiff, 13 v. (1) DENYING PLAINTIFF’S 14 MOTION FOR PARTIAL UNITED STATES LIABILITY 15 SUMMARY JUDGMENT; AND INSURANCE COMPANY, a

16 Pennsylvania corporation, (2) GRANTING DEFENDANT’S 17 Defendant. MOTION FOR SUMMARY JUDGMENT 18

19 [Doc. Nos. 9, 15.]

20 21 This action involves an insurance coverage dispute. On November 28, 2023, 22 Plaintiff Aram Logistics (“Aram” or “Plaintiff”) filed a motion for partial summary 23 judgment that Defendant United States Liability Insurance Company (“USLI” or 24 “Defendant”) breached its duty to defend Aram in an underlying lawsuit. (Doc. No. 9.) 25 On December 22, 2023, USLI filed a cross-motion for summary judgment that it owes no 26 duty to defend and that it did not deny Aram’s claim in bad faith. (Doc. No. 15.) On 27 January 8, 2024, Plaintiff and Defendant each filed an opposition to the other party’s 28 motion for summary judgment. (Doc. Nos. 16, 18.) On January 12, 2024, USLI filed its 1 reply in support of its motion for summary judgment. (Doc. No. 20.) On January 15, 2024, 2 Aram filed its reply in support of its motion for partial summary judgment. (Doc. No. 21.) 3 The Court held a hearing on the parties’ cross-motions for summary judgment on January 4 29, 2024. (Doc. No. 30.) David A. Gauntlett appeared for Aram and Richard D. Bremer 5 appeared for USLI. (Id.) For the reasons discussed below, the Court denies Aram’s motion 6 for partial summary judgment that USLI breached its duty to defend and grants USLI’s 7 motion for summary judgment on the duty to defend and bad faith claims. 8 BACKGROUND 9 Plaintiff Aram Logistics is in the business of delivering furniture from retail stores 10 to customers. (Doc. No. 9-1 at 7.) Aram obtained from USLI a Commercial General 11 Liability Policy (Policy Number GL 1059811) (the “Policy”) for the policy period of July 12 15, 2020 to July 15, 2021. (Doc. No. 9-3, Declaration of Samuel Rubio (“Rubio Decl.”) ¶ 13 2.) The Policy provides that USLI “will pay those sums that the insured becomes legally 14 obligated to pay as damages because of ‘personal and advertising injury.’” (Doc. No. 1-2 15 (“USLI Policy”) at 16.) Pertinent here, the Policy’s definition of “personal and advertising 16 injury” includes “injury . . . arising out of . . . [t]he use of another’s advertising idea in your 17 ‘advertisement’” or “[i]nfringing upon another’s copyright, trade dress or slogan in your 18 ‘advertisement.’” (Id. at 24.) The Policy defines “advertisement” as “a notice that is 19 broadcast or published to the general public or specific market segments about your goods, 20 products or services for the purpose of attracting customers or supporters.” (Id. at 22.) The 21 Policy’s coverage includes the “the right and duty to defend [Aram] against any ‘suit’ 22 seeking [personal and advertising injury] damages.” (Id. at 16.) 23 A. The Underlying Diakon Action 24 On July 2, 2021, Diakon Logistics, Inc. (“Diakon”), a competitor of Aram, filed a 25 lawsuit against Aram and its executives, Samuel Rubio (“Rubio”) and Alvardo Hernandez 26 (“Hernandez”), in the Superior Court of California, San Diego County (the “Diakon 27 28 1 Action”). (Doc. No. 9-2, Declaration of James A. Lowe (“Lowe Decl.”) ¶¶ 2, 3; see also 2 Doc. No. 1-3 (“Diakon Compl.”).) In the lawsuit, Diakon alleges that Rubio and 3 Hernandez, while employed by Diakon, established Aram, a competing furniture delivery 4 company, using Diakon’s trade secrets and confidential information, and funneling 5 resources and business to Aram. (See Diakon Compl.) The Diakon Complaint asserts 6 three causes of action against Aram: (1) the first cause of action for misappropriation of 7 trade secrets; (2) the second cause of action for violation of California’s Unfair 8 Competition Law (“UCL”), Cal. Bus. & Prof. Code § 17200 et seq.; and (3) the fourth 9 cause of action for intentional interference with prospective economic advantage. (Id. ¶¶ 10 34–44, 50–55.) 11 B. Aram Tenders the Claim for Defense 12 On July 8, 2021, Aram tendered the Diakon Action to USLI and sought coverage 13 under the Policy. (Lowe Decl. ¶ 29.) On July 26, 2021, USLI denied coverage. (Id.; Doc. 14 No. 1-4.) USLI disclaimed coverage under the USLI Policy’s “personal and advertising 15 injury” on the grounds that Diakon’s causes of action were rooted in intentional conduct 16 and the Policy’s infringement exclusion excluded Diakon’s claims for intentional 17 misappropriation of trade secrets. (Doc. No. 1-4 at 5.) USLI further explained that none 18 of the remaining allegations in the Diakon Action qualified as “personal or advertising 19 injury.” (Id.) 20 On July 31, 2023, Aram sought reconsideration of USLI’s coverage position. (Lowe 21 Decl. ¶ 31.) In its request for reconsideration, Aram presented additional information 22 obtained through discovery in the Diakon Action. (Doc. No. 1-5 at 1; Lowe Decl. ¶ 31.) 23 Specifically, Aram provided the deposition testimony of Robert Davis (“Davis”), Diakon’s 24 president, dated June 1, 2023, which Aram claimed, “clarified that a major factual 25 26 27 1 The San Diego Superior Court action is Diakon Logistics (Delaware) Inc. v. Aram Logistics, Inc., Samuel Rubio, Alvaro Hernandez, and Does 1 to 50, Case No. 32-2021- 28 1 allegation of Diakon is that Aram and its officers have taken Diakon’s advertising ideas 2 and styles and have used them in Aram’s own advertising, including in its Internet 3 websites.” (Doc. No. 1-5 at 4; Lowe Decl. ¶ 8; see also Doc. No. 1-6.) As such, Aram 4 argued that the Davis deposition testimony triggered the Policy’s “personal and advertising 5 injury” coverage, giving rise to USLI’s duty to defend Aram in the Diakon Action. (Doc. 6 No. 1-5 at 13.) On September 8, 2023, USLI reaffirmed that there remained no coverage 7 under the Policy for the Diakon Action, notwithstanding the Davis deposition testimony. 8 (Doc. No. 1-9 at 7; Lowe Decl. ¶ 32.) USLI explained that because the injury alleged in 9 the underlying action “arose out of access to or disclosure of [Diakon’s] confidential or 10 personal information, including . . . trade secrets” the Policy’s confidential information 11 exception applied. (Doc. No. 1-9 at 7.) USLI further clarified that other exclusions to the 12 Policy bar coverage as well. (Id.) 13 On October 12, 2023, Aram brought the present action against USLI, alleging causes 14 of action for (1) declaratory relief – duty to defend, (2) breach of contract, and (3) breach 15 of the covenant of good faith and fair dealing. (Doc. No. 1, “Compl.”) On November 27, 16 2023, USLI filed its answer to Aram’s complaint. (Doc. No. 6.) 17 Aram moves for partial summary judgment that USLI owes a duty to defend it in the 18 Diakon Action. (Doc. No. 9-1 at 7.) USLI cross-moves for summary judgment that it owes 19 no duty to defend Aram in the Diakon Action, and that it did not act in bad faith because 20 no potential for coverage exists. (Doc. No. 15 at 15–16, 26.) 21 DISCUSSION 22 I. Legal Standards for Summary Judgment 23 Summary judgment is appropriate under Federal Rule of Civil Procedure 56 if the 24 moving party demonstrates that there is no genuine issue of material fact and that it is 25 entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a); Celotex Corp. v. Catrett, 477 26 U.S. 317, 322 (1986). A fact is material when, under the governing substantive law, it 27 could affect the outcome of a case. Anderson v.

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Aram Logistics v. United States Liability Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aram-logistics-v-united-states-liability-insurance-company-casd-2024.