Athena AG Inc. v. Advanced Nutrients US LLC

CourtDistrict Court, W.D. Washington
DecidedOctober 28, 2024
Docket2:24-cv-01239
StatusUnknown

This text of Athena AG Inc. v. Advanced Nutrients US LLC (Athena AG Inc. v. Advanced Nutrients US LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Athena AG Inc. v. Advanced Nutrients US LLC, (W.D. Wash. 2024).

Opinion

6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8

9 ATHENA AG, INC, a Florida Case No. C24-1239RSM corporation, 10 ORDER GRANTING IN PART MOTION 11 Plaintiff, FOR PRELIMINARY INJUNCTION

12 v. 13 ADVANCED NUTRIENTS US LLC, a 14 domestic limited liability company,

15 Defendant. 16

17 I. INTRODUCTION 18 This matter comes before the Court on Plaintiff Athena Ag, Inc. (“Athena”)’s Motion 19 for Preliminary Injunction. Dkt #12. Defendant Advanced Nutrients US LLC (“Advanced 20 Nutrients”) opposes. Dkt. #21. Neither party has requested oral argument. The Court has 21 22 reviewed the briefing and now rules that Athena’s Motion for Preliminary Injunction is 23 GRANTED IN PART as set forth below. 24 II. BACKGROUND 25 This is a trademark infringement and false advertising case. Plaintiff Athena is a 26 Florida corporation that produces fertilizers specifically for use in growing cannabis. Dkt. #13 27 28 (“Schneider Decl.”), ¶ 3–4. Athena’s customers include large, state-licensed commercial growers. Id. at ¶ 7. Athena’s Chief Product Officer will testify that its “Pro” and “Blended” 1 2 fertilizer lines are “household names in the industry” and that Athena has won industry awards 3 for its fertilizers. Id. at ¶ 13–14. Athena has federally registered trademarks including the 4 word mark ATHENA, the word mark CORE, the word mark FADE, and a design mark. Id. at 5 ¶ 19. Athena has not licensed any of these marks to Defendant Advanced Nutrients. Id. at ¶ 6 21. 7 8 Defendant Advanced Nutrients competes with Athena in the market for cannabis 9 fertilizer. Id. at ¶ 24. Athena recently learned that Advanced Nutrients has displayed, and is 10 continuing to display, advertising materials featuring the Athena Marks without permission. Id. 11 at ¶ 26. For example, Advanced Nutrients’ chief executive, Michael Straumietis, posted a 12 13 video on Instagram in June of 2024 promoting his products by holding up a paper chart with 14 both Advanced Nutrients’ mark and Athena’s word mark and design mark visible at the top. 15 Id. at ¶¶ 27–30. The gist of the Instagram video and a linked website is that growers who are 16 already using competitors’ fertilizers should use Advanced Nutrients’ “Big Bud,” “Bud Factor 17 X,” and “Voodoo Juice Plus Tablets” alongside those competitors’ products. Id. at ¶ 35. 18 19 The video refers to Athena as “one of our competitors” at least twice. See Dkt. #22 20 (“Wang Decl.”), Ex. A (transcript of video). The Instagram post for the video included a 21 written message from Mr. Straumietis: “We’re not here to gatekeep information; we want the 22 best for you. That’s why we created feeding charts to show how to include our products if 23 you’re using Athena, Jacks, Front Row Ag., HGV or General Hydroponics…” Dkt. #21 at 5 24 25 (citing Dkt. # 1 at ¶ 49). 26 Advanced Nutrients’ website has links to download Athena’s feeding charts featuring 27 the Athena word and design marks. Schneider Decl. at ¶¶ 37–39. Above the links it says, 28 “[t]hese charts are designed to help you seamlessly integrate our additives into your current 1 2 feeding regimen…” Id. 3 Athena also presents evidence that Advanced Nutrients has advertised with “Certificates 4 of Analysis” purporting to show testing performed by certain laboratories comparing its 5 products with Athena’s products; these Certificates of Analysis have been altered to add the 6 Athena word mark and design mark at the top, which was originally blank space. Dkt. #12 at 7 8 11–16 (citing Dkt. #13 and exhibits). Although Athena will be claiming false advertising in 9 this case, it seeks a preliminary injunction only as to trademark infringement. Id. at 16. 10

11 III. LEGAL ANALYSIS 12 13 Granting a preliminary injunction is “an extraordinary remedy that may only be 14 awarded upon a clear showing that the plaintiff is entitled to such relief.” Winter v. NRDC, 15 Inc., 555 U.S. 7, 22, 129 S. Ct. 365, 172 L. Ed. 2d 249 (2008). A party can obtain a 16 preliminary injunction by showing that (1) it is likely to succeed on the merits, (2) it is likely to 17 suffer irreparable harm in the absence of preliminary relief, (3) the balance of equities tips in its 18 19 favor, and (4) an injunction is in the public interest. Id. at 555 U.S. 20. A preliminary 20 injunction may also be appropriate if a movant raises “serious questions going to the merits” 21 and the “balance of hardships . . . tips sharply towards” it, as long as the second and third 22 Winter factors are satisfied. All. for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1134-35 (9th 23 Cir. 2011). 24 25 A. Likelihood of Success on the Merits 26 Athena’s registration of its name and design marks gave Athena the exclusive right to 27 use those marks “in commerce on or in connection with the goods or services specified in the 28 certificate,” in this case, the goods “plant nutrients” and/or “fertilizers.” See 15 U.S.C. § 1 2 1057(b). Athena has presented evidence that Advanced Nutrients is using its marks, without 3 permission, in connection with its attempted sale of plant nutrients and/or fertilizers. Advanced 4 Nutrients essentially agrees, but argues it is doing so legally under the “nominative fair use 5 defense.” Dkt. #21 at 2. 6 Nominative use would be using the Athena name and design mark not to describe 7 8 Advanced Nutrients’ products (the classic form of trademark infringement), but rather to 9 describe Athena’s products. “Nominative use becomes nominative fair use when a defendant 10 proves three elements: First, the plaintiff’s product or service in question must be one not 11 readily identifiable without use of the trademark; second, only so much of the mark or marks 12 13 may be used as is reasonably necessary to identify the plaintiff’s product or service; and third, 14 the user must do nothing that would, in conjunction with the mark, suggest sponsorship or 15 endorsement by the trademark holder.” Mattel, Inc. v. Walking Mountain Prods., 353 F.3d 792, 16 810 (9th Cir. 2003) (quoting New Kids on the Block v. News Am. Publ’g Inc., 971 F.2d 302, 17 308 (9th Cir. 1992)). For example, under this New Kids test, “a soft drink competitor would be 18 19 entitled to compare its product to Coca–Cola or Coke, but would not be entitled to use Coca– 20 Cola’s distinctive lettering.” New Kids, 971 F.2d 308 at n.7. 21 Athena argues that the use of its marks here goes beyond what is reasonably necessary 22 to compare products and is enough to suggest an endorsement. Dkt. #12 at 18. Athena 23 presents considerable evidence of the number of marks used, arguing that this is more than 24 25 reasonably necessary to identify its products. Id. Athena contends that the intent of Advanced 26 Nutrients’ ad campaign must be to “convince consumers that Defendant’s products, and 27 28 Defendant’s instructions for using them with Athena’s, are somehow endorsed or sponsored by 1 2 Athena.” Id. at 19. 3 In response, Advanced Nutrients argues they have taken down the links to Athena’s 4 feeding charts and that the Instagram videos are protected by the First Amendment as 5 nominative use. Dkt. #21. Defendant argues that, in the Ninth Circuit, “if the test for finding 6 nominative use is not met, ‘the district court may order defendants to modify their use of the 7 8 mark so that [the test for nominative use] is satisfied; it may not enjoin nominative use of the 9 mark altogether.’” Id. at 9 (citing Toyota Motor Sales, U.S.A., Inc., v. Tabari, 610 F. 3d 1171, 10 1176 (9th Cir. 2010)).

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Athena AG Inc. v. Advanced Nutrients US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/athena-ag-inc-v-advanced-nutrients-us-llc-wawd-2024.