Associated Professional Educators of Louisiana v. E D U 20/20 L L C

CourtDistrict Court, W.D. Louisiana
DecidedSeptember 30, 2024
Docket1:22-cv-05720
StatusUnknown

This text of Associated Professional Educators of Louisiana v. E D U 20/20 L L C (Associated Professional Educators of Louisiana v. E D U 20/20 L L C) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Associated Professional Educators of Louisiana v. E D U 20/20 L L C, (W.D. La. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA ALEXANDRIA DIVISION

ASSOCIATED PROFESSIONAL CASE NO. 1:22-CV-05720 EDUCATORS OF LOUISIANA

VERSUS JUDGE TERRY A. DOUGHTY

EDU20/20 LLC ET AL MAGISTRATE JUDGE PEREZ-MONTES

MEMORANDUM RULING

Before the Court are five motions for partial summary judgment. The plaintiff, Associated Professional Educators of Louisiana (“A+PEL”) filed the first (R. Doc. 79), second (R. Doc. 82), and third (R. Doc. 84). The defendants, EDU20/20, Courtney Dumas (“Dumas”), and Miranda Britt (“Britt”) (collectively, “Defendants”) filed the fourth (R. Doc. 85) and fifth (R. Doc. 86). Each motion is opposed. After careful consideration of the parties’ memoranda and the applicable law, the first, second, and third Motions, all filed by A+PEL, are DENIED, and the fourth and fifth Motions, both filed by Defendants, are GRANTED. I. BACKGROUND This case stems from a dispute wherein Defendants allegedly misappropriated the property—intellectual or otherwise—of A+PEL, for EDU20/20’s benefit.1 Both A+PEL and EDU20/20 provide training and programming to teachers in Louisiana.2 Britt is a part-owner of EDU20/20, and an ex-employee of A+PEL.3 The alleged acts of Britt—while still employed by A+PEL—give rise to the lion’s share of the claims currently before the Court.4 As it stands today,

1 R. Doc. 41 at 12–28. 2 Id. at 5–6, 14. 3 Id. at 12–15. 4 Id. at 12–28. A+PEL accuses Defendants of misappropriating its trade secrets in violation of the Defend Trade Secrets Act (“DTSA”)5 and the Louisiana Uniform Trade Secrets Act (“LUTSA”)6; impermissibly soliciting A+PEL’s customers in violation of the Louisiana Unfair Trade Practices Act (“LUTPA”)7; “unfair competition” and trademark infringement under the Lanham Act8; and civil conspiracy.9 Further, A+PEL asserts a claim for breach of fiduciary duty against Britt alone.10

A. The First Motion The first motion for partial summary judgment is on “liability only” and seeks our adjudgment that (1) Britt breached her fiduciary duty to A+PEL and (2) that she violated LUTPA.11 Mainly, A+PEL contends that Britt diverted business opportunities to EDU20/20 while still employed by A+PEL.12 Further, A+PEL points to Britt’s alleged use of paid time off (“PTO”) from A+PEL to instead promote EDU20/20, “lying to [the Executive Director of A+PEL],” and

numerous other episodes of alleged unfaithfulness by Britt.13 By A+PEL’s estimation, Britt’s acts were per se violative of a “bright-line rule” that “[a]n employee cannot compete with her employer while she is still employed.”14 Accordingly, A+PEL contends that no genuine issues of material fact exist as to Britt’s liability as an alleged fiduciary, and Defendants’ liability under LUTPA.15 Defendants filed an Opposition, challenging A+PEL’s motion for a flurry of reasons.16 First, Defendants aver that Britt, as a mere employee, owed no fiduciary duty to A+PEL, and thus

5 Id. at 28–31 (citing 18 U.S.C. § 1836). 6 Id. at 31–33 (citing La. R.S. 51:1431, et seq.). 7 Id. at 34–35 (citing La. R.S. 51:1401, et seq.). 8 Id. at 37 (citing 15 U.S.C. § 1125(a)). 9 Id. at 35–36 (citing La. Civ. Code art. 2324(A)). 10 Id. at 33–34. 11 R. Doc. 79 at 1. 12 R. Doc. 79-1 at 12-24. 13 Id. 14 Id. at 19. 15 Id. at 30. 16 R. Doc. 97. was incapable of such a breach.17 Second, Defendants point out that a finding of intent (requisite for breach of fiduciary duty claims) is broadly inappropriate at the summary judgment stage.18 Third, Defendants contend that the corporate opportunities that Britt allegedly usurped for EDU20/20 either were not usurped at all or were not A+PEL’s in the first place.19 Fourth, Defendants aver that A+PEL consented to Britt’s simultaneous employment with EDU20/20.20

Fifth, Defendants assert that A+PEL has failed to show actual damages as required under LUTPA.21 And finally, Defendants allege that “[t]he [b]ulk” of A+PEL’s LUTPA claims are perempted.22 Accordingly, Defendants request that the motion be denied.23 A+PEL filed a Reply.24 A+PEL argues that it need not show actual damages if it is only seeking summary judgment on liability.25 A+PEL additionally challenges Defendants’ characterization of the duties owed to an employer, and asserts that no dispute exists as to whether Britt breached these duties.26 A+PEL closes by denying any dispute with regard to Britt’s alleged intent; denying A+PEL’s knowledge of Britt’s concurrent employment with EDU20/20; and invoking contra non valentum with regard to the timeliness of its LUTPA claims.27

B. The Second Motion The second motion for partial summary judgment seeks our adjudgment that Defendants violated the Lanham Act, both by unfairly competing with A+PEL, and by using A+PEL’s logo.28

17 Id. at 9-11. 18 Id. at 11-12. 19 Id. at 12-20 20 Id. at 21-24. 21 Id. at 24-25. 22 Id. at 25. 23 Id. at 30. 24 R. Doc. 105. 25 Id. at 1–3. 26 Id. at 3–6. 27 Id. at 6–10. 28 R. Doc. 82-1 at 11–28. A+PEL contends that Britt’s unauthorized use of A+PEL’s logo during a presentation (for EDU20/20) constituted trademark infringement by creating a likelihood of confusion, and causing actual confusion.29 In support of this claim, A+PEL namely relies on the declaration of its intended expert—Tobias Wilhelm.30 Furthermore, and specifically in support of its derivative contention that people “actual[ly] confus[ed]” the marks of A+PEL and EDU20/20, A+PEL offers the

declarations of Torrence Williams and Dr. Tia Neal.31 A+PEL concludes its motion by denying that Britt’s use of the A+PEL logo constituted fair use.32 Defendants filed an Opposition.33 Defendants contend that A+PEL hasn’t a trademark in the first place; that even if A+PEL did have an otherwise-protectable trademark, it is fatally absent from interstate commerce; and that even if A+PEL had a protectable mark used in interstate commerce, no requisite likelihood of confusion exists.34 Additionally, Defendants poke holes in both the expertise and analysis of A+PEL’s intended expert, Tobias Wilhelm, and contend that the two other declarants, Torrence Williams and Dr. Tia Neal, are both employed by A+PEL currently and thus incredible.35 Finally, Defendants reassert their “fair use” defense, while pointing out that A+PEL did not address their other affirmative defenses in its Motion.36

A+PEL filed a Reply, challenging Defendants’ conclusions regarding the A+PEL mark and its use in commerce.37 Thereafter, A+PEL runs through the likelihood of confusion once more, makes a pitstop at fair use, and ends with a graze on Defendants’ other affirmative defenses.38

29 Id. at 22. 30 See R. Doc. 82-3. 31 R. Doc. 82-1 at 24–25. 32 Id. at 19–22. 33 R. Doc. 99. 34 Id. at 10–18. 35 Id. at 17–23. 36 Id. at 24–29. 37 Id. at 1–3. 38 Id. at 3–10. C. The Third Motion A+PEL’s third and final39 motion for partial summary judgment seeks our adjudgment that Defendants violated DTSA and LUTSA.40 As the basis of its trade secrets claims, A+PEL asserts that Defendants—namely Britt—stole its “Mentor Teacher” programming material to create their very own “Mentor Teacher” program at EDU20/20.41 Allegedly, Britt accomplished this heist by

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Bluebook (online)
Associated Professional Educators of Louisiana v. E D U 20/20 L L C, Counsel Stack Legal Research, https://law.counselstack.com/opinion/associated-professional-educators-of-louisiana-v-e-d-u-2020-l-l-c-lawd-2024.