Artoss Inc v. Artoss GmbH

CourtCourt of Appeals for the Third Circuit
DecidedJune 4, 2024
Docket23-1185
StatusUnpublished

This text of Artoss Inc v. Artoss GmbH (Artoss Inc v. Artoss GmbH) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Artoss Inc v. Artoss GmbH, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 23-1185 ___________

ARTOSS, INC.

v.

ARTOSS GMBH; THOMAS GERBER; WALTER GERIKE,

ARTOSS GMBH, Appellant ____________

On Appeal from the United States District Court for the District of Delaware (D.C. No. 1-20-cv-00741) District Judge: Honorable Robert T. Dawson ____________

Submitted Under Third Circuit LAR 34.1(a) June 3, 2024

Before: HARDIMAN, PORTER, and AMBRO, Circuit Judges.

(Filed: June 4, 2024)

____________

OPINION* ____________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. HARDIMAN, Circuit Judge.

Artoss GmbH (GmbH) appeals a post-trial judgment on a claim for breach of

contract and counterclaims for breach of contract and trademark infringement. GmbH

challenges the sufficiency of the evidence for a specific jury finding and also claims the

District Court made procedural and evidentiary errors. We will affirm.

I

This appeal arises out of a dispute between GmbH, a German medical device

company, and Artoss, Inc. (Artoss), its North American distributor of an implantable

synthetic bone-grafting product called NanoBone. Under the parties’ Distribution

Agreement, all “trademarks,” “trade names,” and other “proprietary rights . . . associated”

with NanoBone products belonged exclusively to GmbH, which was allowed to terminate

the agreement if it “reasonably determine[d] that [Artoss] . . . negligently or intentionally

acted in a manner which adversely affect[ed]” GmbH’s “trademark rights.” App. 645,

647. Meanwhile, the Distribution Agreement specified that GmbH was not permitted to

increase its prices except “upon mutual agreement,” and it was entitled to payment for

products it supplied to Artoss only after those products were sold. App. 644.

In June 2020, Artoss sued GmbH for breaching the Distribution Agreement after

GmbH refused to ship new NanoBone products to Artoss without advance payment.

Nevertheless, Artoss conditionally pre-paid for inventory pending resolution of its

lawsuit. A few months later, GmbH unilaterally raised prices on all NanoBone products.

Finally, GmbH purported to terminate the Distribution Agreement in April 2021, alleging

that Artoss had “registered certain trademarks on material associated with” NanoBone

2 products and “commenced an attempt to rebrand . . . GmbH’s products as products . . . of

Artoss.” App. 770. Artoss filed an amended complaint based on GmbH’s price increases

and its termination of the Distribution Agreement.

In pre-trial motions, Artoss sought to exclude evidence intended to show it had

failed to sell NanoBone products on a first-in-first-out basis, a standard industry practice

in which older inventory is sold before newer inventory to minimize waste for medical

products with a limited shelf life. GmbH asserted that this evidence was necessary to

rebut Artoss’s claim that GmbH’s demand for advance payment breached the

Distribution Agreement. The District Court ruled in favor of Artoss, concluding that

“[w]hy [Artoss] may have allegedly built up excess inventory or allowed product to

expire [wa]s not at issue.” App. 17. Also prior to trial, GmbH objected to instructing the

jury on nominative fair use, arguing that even if Artoss had timely pleaded this

affirmative defense to GmbH’s trademark infringement counterclaims, it was “legally

inapplicable” to the facts of the case. App. 527. The Court overruled this objection and

instructed the jury accordingly.

The jury found that: (1) GmbH breached the Distribution Agreement and acted

wrongfully when it terminated the Agreement; and (2) Artoss did not breach the

Agreement or violate any of GmbH’s trademark rights. Following the damages phase of

the trial, the jury awarded $1,260,821 to Artoss. The District Court then denied GmbH’s

renewed motion for judgment as a matter of law as well as its motion to amend the

judgment and transfer ownership of NanoBone-related trademark registrations and

3 applications from Artoss to GmbH. After the District Court entered final judgment,

GmbH timely appealed.1

II

GmbH urges us to reverse the District Court’s order denying its renewed motion

for judgment as a matter of law “because the undisputed evidence at trial [provided] a

sound contractual basis for termination.” GmbH Br. 18. Exercising plenary review, we

may grant such a motion “only if, viewing the evidence in the light most favorable to the

nonmovant and giving it the advantage of every fair and reasonable inference, there is

insufficient evidence from which a jury reasonably could find liability.” Ambrose v.

Township of Robinson, 303 F.3d 488, 492 (3d Cir. 2002) (cleaned up). GmbH claims it

was permitted to terminate the Distribution Agreement because Artoss “engaged in a

deliberate campaign to misuse . . . GmbH’s marks and misappropriate them as its own.”

GmbH Br. 25. We disagree.

GmbH’s sole trademark at issue here is the word “NanoBone,” “consist[ing] of

standard characters without claim to any particular font, style, size, or color.” App. 725

(capitalization omitted). There was substantial evidence at trial demonstrating that Artoss

never attempted to register “NanoBone,” never challenged the ownership or validity of

the trademark, nor deprived GmbH of its right to use or exercise control over it.2 Rather,

1 The District Court had jurisdiction under 28 U.S.C. § 1332. We have jurisdiction under 28 U.S.C. § 1291. 2 S & R Corp. v. Jiffy Lube Int’l, Inc. is inapposite because, unlike in this case, the franchisee was using “the same legally protectable trademark[] owned by Jiffy Lube.” 968 F.2d 371, 375 (3d Cir. 1992). 4 Artoss used the word only to promote and sell NanoBone products. So it was reasonable

for the jury to conclude that Artoss never “adversely affected” GmbH’s “trademark

rights.”3 App. 647. And because this was the only applicable basis for GmbH to terminate

the Distribution Agreement, its arguments on appeal that Artoss violated other provisions

of the Distribution Agreement are unavailing.

GmbH also emphasizes that Artoss “created and released an unauthorized

stylization of the NanoBone[] mark and sought to obtain protection in its own name for

elements of that stylization.” GmbH Br. 27 (emphasis added). But this argument fails

because GmbH’s trademark encompasses only the word itself. The logos that Artoss

created incorporating the original stylized NanoBone mark or generic scientific terms like

“nanobiology,” “ossification,” and “osteogenesis” are thus distinct from the NanoBone

trademark.

Because it was not unreasonable for the jury to conclude that GmbH wrongfully

terminated the Distribution Agreement, we cannot disturb its finding.

III

GmbH also argues that the District Court erred when it instructed the jury on

nominative fair use, a purportedly “inapplicable [affirmative] defense that [Artoss] did

not plead and did not mention until the eve of trial.” GmbH Br. 20. Because the Court did

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Artoss Inc v. Artoss GmbH, Counsel Stack Legal Research, https://law.counselstack.com/opinion/artoss-inc-v-artoss-gmbh-ca3-2024.