Arizona Board of Regents v. Doe

CourtDistrict Court, D. Arizona
DecidedAugust 17, 2021
Docket2:20-cv-01638
StatusUnknown

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

Bluebook
Arizona Board of Regents v. Doe, (D. Ariz. 2021).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Arizona Board of Regents, No. CV-20-01638-PHX-DWL

10 Plaintiff, ORDER

11 v.

12 John Doe,

13 Defendant. 14 15 This is an unusual case. On one side is a major public university that seeks to use 16 our nation’s trademark laws in novel ways in an effort to combat the COVID-19 pandemic. 17 On the other side is a deeply unsympathetic John Doe defendant (“Doe”) who posted a 18 series of vulgarity-filled messages on Instagram in an attempt to persuade college students 19 to attend maskless COVID-19 parties during the peak of the first wave of the pandemic, 20 whose answer was stricken for litigation misconduct, who stopped participating in this 21 action after his answer was stricken, and whose identify was never discovered during 22 subsequent proceedings. All of this has culminated in the plaintiff, the Arizona Board of 23 Regents (“ABOR”), filing a motion for default judgment that seeks the entry of a 24 permanent injunction against Doe. (Doc. 33.) As discussed below, although ABOR’s 25 motivations for bringing this lawsuit are understandable, ABOR has not established that 26 Doe’s challenged conduct (however odious it may be) implicates the trademark doctrines 27 identified in ABOR’s complaint. Accordingly, ABOR’s motion is denied and this action 28 is dismissed. 1 BACKGROUND 2 I. Underlying Factual Allegations 3 The facts set forth below are derived from ABOR’s complaint. (Doc. 1.) Because 4 Doe has defaulted, ABOR’s alleged facts are assumed true, except facts as to damages. 5 Geddes v. United Fin. Grp., 559 F.2d 557, 560 (9th Cir. 1977). 6 A. ASU’s Marks, Trade Dress, And Instagram Account 7 Arizona State University (“ASU”), which was founded under a different name in 8 1885, has continuously operated under the “ASU” and “ARIZONA STATE 9 UNIVERSITY” trademarks since 1958. (Doc. 1 ¶ 9.) ASU owns “numerous ASU, 10 ARIZONA STATE UNIVERSITY, and ARIZONA STATE federal trademark 11 registrations for a variety of different goods and services.” (Id. ¶ 10.) 12 ASU also owns “the ASU school colors trade dress, consisting of maroon and gold, 13 which it has been using since at least as early as 1898.” (Id. ¶ 11.) “ASU’s maroon and 14 gold color scheme has been used extensively on merchandise, in advertising and 15 promotional materials, and on ASU’s website and social media accounts to designate ASU 16 and its goods and services, such that consumers—especially Arizona consumers—readily 17 recognize maroon and gold as representing ASU.” (Id.) ASU “invests substantial sums 18 annually” to achieve “wide and extensive exposure of the ASU Marks and maroon and 19 gold trade dress to the public in direct association with the University.” (Id. ¶ 12.) 20 ASU also operates an official Instagram account with the username 21 “arizonastateuniversity.” (Id.) The account “prominently features the ASU Marks and 22 school colors trade dress.” (Id.) 23 B. Doe’s Instagram Posts 24 On or about July 19, 2020, Doe (whose true identity and location are unknown) 25 created an Instagram account under the username “asu_covid.parties.” (Id. ¶ 23.) Directly 26 below the username, Doe identified his location as “Arizona State University.” (Id.) In 27 the profile associated with this account, Doe identified his full name as “ASU Coronavirus 28 Parties,” identified his title as “Event Planner,” and then provided the following blurb: 1|| “‘COVID-19 Parties because they’re during this pandemic era’ Not a contest to catch 2|| COVID. THROWING HUGE PARTIES AT ASU. Follow before we go private.” (/d. 24.) 4 Also on July 19, 2020, Doe posted the first message on the “asu_covid.parties” 5|| account. Ud. § 23.) It provided as follows: 6 =

9 ‘

10 11 12 13 14

15 16 17 18 || Ud.) As the complaint notes, this post included “the ASU logo within the body of the 19 || message” and was formatted “in ASU’s maroon and gold color trade dress.” (/d.) 20 At some unspecified time after he created this post, Doe wrote a comment in the || public comment bar that appears next to the post. Ud.) The comment provided as follows: || “Those of you coming back to Phoenix. We about to get fucking lit.” (/d.) 23 On July 20, 2020, Doe posted his second message on the “‘asu_covid.parties” account. (/d. ¥ 25.) Unlike the first message, this message was not formatted in maroon 25 || and gold (it was set against a black background, with neon pink and yellow text) and did 26 || □□□ include the ASU logo. (/d.) Its text provided as follows: “OUR FIRST PARTY WILL 27|| BE CALLED HOAX-19 BECAUSE THE IDEA THAT COVID IS ONLY RAMPANT 28 || IN AMERICA COMPARED TO OTHER COUNTRIES IS A HOAX! COME TO

-3-

1 HOAX-19. POSTING ADDY SOON!” (Id.) 2 Doe proceeded to post a series of additional messages on the “asu_covid.parties” 3 account. (Doc. 1-4 at 2-21.) Although the complaint only discusses some of those 4 messages, more are provided in an attachment to the complaint. (Id.) Notably, none of the 5 later messages prominently featured the colors of maroon and gold and only one displayed 6 the ASU logo. (Id.) The text of each subsequent message1 is as follows: 7 ▪ Message Three: “I just spoke to the Vice-Consul of the Consulate of the Republic 8 of Belarus. The consul couldn’t make it so I only spoke with the Vice Consul in person. 9 They are both excited to host us. They are both awesome accomplished guys. We would 10 like to thank them for letting us throw a party on consulate grounds so the party can’t get 11 shut down by the police. The party will take place on the first Saturday of the semester.” 12 (Doc. 1-4 at 2, 5.) 13 ▪ Message Four: “For security purposes, the consulate has asked us to prohibit 14 masks so we can identify people. Also the drinking age in Belarus is 18 [emoji of 15 Belorussian flag] since we will be on Belarus soil while in the consulate.” (Doc. 1-4 at 2, 16 6.) 17 ▪ Message Five: “We will party. We do not care what you snowflakes say. 18 COVID-19 is a fat hoax.” (Doc. 1 ¶ 26; Doc. 1-4 at 2, 7.) 19 ▪ Message Six: In the sixth message, in lieu of drafting his own text, Doe provided 20 what appears to be a picture of an article from a newspaper entitled The State Press. (Doc. 21 1-4 at 2, 8.) The headline of the article is “University plans to punish partying on and off 22 campus.” (Id.) The text of the article begins (before being cut off): “In response to 23 questions about an Instagram page promoting ‘COVID parties,’ the University said it will 24 not tolerate behavior that disregards health protocols.” (Id.) In a lengthy comment 25 appearing next to this post, Doe wrote the following: 26

27 1 The Court has used ellipses in place of some of the more offensive language appearing in certain posts. The quoted language is sufficient for purposes of the likelihood- 28 of-confusion analysis appearing later in this order and there is no need to place undue emphasis on the bile being spewed by an anonymous internet provocateur such as Doe. 1 They are trying to slander this account. They don’t report the threats people have made to purposely come to the party with COVID . . . . I gave a fake 2 consulate so there is no political backlash for said country. Our company 3 will not name the consulate our party will be at. Just the address when the time comes. CDC Guidelines, Arizona jurisdiction and ASU on campus 4 rules do not apply to foreign soil. We will be violating nothing. ASU will 5 not be able to punish you. There will be security at the party. EXPRESS YOUR FREEDOM. LET’S PARTY. FIRST SATURDAY OF 2020 FALL 6 SEMESTER. (These parties are hosted for students to have fun like how a 7 normal frat party would work. These parties are not designed to disregard public health protocols because they will not be public. These parties will be 8 like parties if COVID never existed.

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Arizona Board of Regents v. Doe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arizona-board-of-regents-v-doe-azd-2021.