Battle Foam v. Wade

CourtDistrict Court, D. New Hampshire
DecidedJune 29, 2010
Docket10-CV-116-SM
StatusPublished

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

Bluebook
Battle Foam v. Wade, (D.N.H. 2010).

Opinion

Battle Foam v. Wade 10-CV-116-SM 06/29/10 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Battle Foam, LLC, Plaintiff

v. Civil No. lO-cv-116-SM Opinion No. 2 010 DNH 108 Bryan Wade, d/b/a Outrider Hobbies, Defendant

O R D E R

Plaintiff, Battle Foam, LLC, is an Arizona limited liability

company that "specializes in laser cutting foam for carrying

cases sold in the war gaming market under the mark, BATTLE FOAM,

through [its] website www.battlefoam.com." Complaint (document

no. 1) at 1. It brings this action against Bryan Wade, d/b/a

Outrider Hobbies, seeking preliminary and permanent injunctive

relief, as well as damages for alleged acts of trademark

infringement, unfair competition, false designation of origin,

trademark dilution, deceptive trade practices, injury to business

reputation, and misappropriation of trade secrets. Wade is also

a resident of Arizona.

While the complaint is replete with seeming hyperbole,

including allegations of industrial espionage, unauthorized

access to Battle Foam's manufacturing facility, and theft of

trade secrets, it contains relatively few concrete factual assertions. Nevertheless, it is clear that Battle Foam's claims

rest, largely, on the following proposition:

Outrider Hobbies and Bryan Wade are trying to ride off of the good will of the BATTLE FOAM mark in adopting a similar military oriented FOAM CORPS mark, are passing their products off as Battle Foam products, and have taken other steps to improperly obtain trade secrets from Battle Foam's innovative foam laser cutting technology.

Plaintiff's opposition memorandum (document no. 6) at 1-2. To be

sure. Battle Foam has submitted what it claims is evidence of

consumer confusion between the parties' respective marks. But,

as discussed below, that evidence is of questionable

authenticity.

Wade, proceeding pro se, has filed a motion to dismiss for

lack of personal jurisdiction and improper venue. In the

alternative, he moves the court to transfer venue to the District

of Arizona. Plaintiff objects and asserts that this court may

properly exercise specific personal jurisdiction over Wade.

Standard of Review

When personal jurisdiction is contested, the plaintiff bears

the burden of establishing that the court has such jurisdiction.

See Sawtelle v. Farrell, 70 F.3d 1381, 1387 (1st Cir. 1995);

Kowalski v. Doherty, Wallace, Pillsburv & Murphy, 787 F.2d 7, 8

2 (1st Cir. 1986). Allegations of jurisdictional facts are

construed in the plaintiff's favor, see Buckley v. Bourdon, 682

F. Supp. 95, 98 (D.N.H. 1988), and if, as here, the court

proceeds based upon the written submissions of the parties

without an evidentiary hearing, the plaintiff need only make a

prima facie showing that jurisdiction exists. See Kowalski, 787

F.2d at 8; Bolt v. Gar-Tec Products, Inc., 967 F.2d 671, 674-75

(1st Cir. 1992).

Nevertheless, the plaintiff's demonstration of personal

jurisdiction must be based on specific facts set forth in the

record in order to defeat a defendant's motion to dismiss. See

TicketMaster-New York, Inc. v. Alioto, 26 F.3d 201, 203 (1st Cir.

1994). See also Jet Wine & Spirits, Inc. v. Bacardi & Co., 298

F.3d 1, 8 (1st Cir. 2002) ("Although the burden of proof is

light, [plaintiff] may not rely on the mere allegations of its

complaint, but must point to specific facts in the record that

support those allegations.") . And, "in reviewing the record

before it, a court 'may consider pleadings, affidavits, and other

evidentiary materials without converting the motion to dismiss to

a motion for summary judgment.'" VDI Technologies v. Price, 781

F. Supp. 85, 87 (D.N.H. 1991) (quoting Lex Computer & Management

Corp. v. Eslinqer & Pelton, B.C., 676 F. Supp. 399, 402 (D.N.H.

1987) ) .

3 Because at least some of Battle Foam's claims arise under

federal law, the court's inquiry into whether it may exercise

personal jurisdiction over Wade is necessarily distinct from the

inquiry applicable in diversity cases. See generally United

Elec. Workers v. 163 Pleasant St. Corp., 960 F.2d 1080 (1st Cir.

1992). In a federal question case, "the constitutional limits of

the court's personal jurisdiction are fixed . . . not by the

Fourteenth Amendment but by the Due Process Clause of the Fifth

Amendment." .Id. at 1085. This distinction is significant

"because under the Fifth Amendment, a plaintiff need only show

that the defendant has adequate contacts with the United States

as a whole, rather than with a particular state." United States

v. Swiss Am. Bank, Ltd., 274 F.3d 610, 618 (1st Cir. 2001) .

Importantly, however, "the plaintiff must still ground its

service of process in a federal statute or civil rule." .Id. In

other words. Battle Foam must demonstrate either: (1) that a

federal statute invoked in its complaint authorizes nation-wide

service of process; or (2) that it served Wade with a copy of its

complaint in a way that comports with the requirements of Rule 4

of the Federal Rules of Civil Procedure.

Here, Battle Foam does not claim that any of the federal

statutes under which it is proceeding authorizes national service

of process. Consequently, the Federal Rules of Civil Procedure

4 provide that it must demonstrate that Wade was served in a manner

consistent with New Hampshire's individual long-arm statute. See

Fed. R. Civ. P. 4(e). That long-arm statute, RSA 510:4,

authorizes jurisdiction over foreign defendants to the full

extent permitted by federal law. See Sawtelle, 70 F.3d at 1388.

Stated another way. New Hampshire's long-arm statute is

coextensive with the outer limits of due process protection under

the United States Constitution. Accordingly, the court need only

determine whether the exercise of personal jurisdiction over Wade

would comport with federal constitutional guarantees.

Hence, our analysis comes full circle. When insufficient statutory authorization for extraterritorial service exists. Rule 4 (e) allows such service "only to the extent permitted by the law of the state in which the district court sits." It follows that, absent a federal statute permitting service of process on [defendant] . . . , our threshold inquiry must focus on [state] law concerning personal jurisdiction, notwithstanding that this is a federal question case.

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