Benefit Cosmetics LLC v. E.L.F. Cosmetics, Inc.

CourtDistrict Court, N.D. California
DecidedJuly 25, 2024
Docket3:23-cv-00861
StatusUnknown

This text of Benefit Cosmetics LLC v. E.L.F. Cosmetics, Inc. (Benefit Cosmetics LLC v. E.L.F. Cosmetics, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benefit Cosmetics LLC v. E.L.F. Cosmetics, Inc., (N.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 BENEFIT COSMETICS LLC, 10 Case No. 23-cv-00861-RS Plaintiff, 11 v. ORDER ON MOTIONS TO EXCLUDE, 12 BENEFIT’S MOTION TO STRIKE, E.L.F. COSMETICS, INC., AND SEALING MOTIONS 13 Defendant. 14

15 I. INTRODUCTION 16 In this trademark and trade dress infringement case, Plaintiff Benefit Cosmetics LLC 17 (“Benefit”) avers Defendant e.l.f. Cosmetics, Inc. (“e.l.f.”) infringed on intellectual property 18 associated with Benefit’s Roller Lash mascara. Benefit and e.l.f. have filed cross-motions to 19 exclude various expert witness opinions. Benefit has also filed a motion to strike allegedly 20 improper deposition testimony from e.l.f.’s experts, documents not produced in fact discovery and 21 related opinions, and theories of functionality not disclosed in fact discovery and corresponding 22 opinions. Finally, the parties have filed several sealing motions. For the reasons below, e.l.f.’s 23 motion to exclude is granted in part and denied in part, Benefit’s motion to exclude is granted in 24 part and denied in part, and Benefit’s motion to strike is granted in part and denied in part. The 25 sealing motions are addressed in further detail below. 26 II. BACKGROUND 27 Benefit and e.l.f. are globally known cosmetics companies that sell competing mascaras: 1 e.l.f.’s “Lash ‘N Roll”-branded mascara. Benefit avers it has been using these marks since at least 2 2015. In January 2023, Benefit became aware e.l.f. was selling mascara under e.l.f.’s Lash ‘N Roll 3 mark using, Benefit claims, Benefit’s Roller Lash trade dress. Benefit notified e.l.f. of its 4 registered trademark and common law trade dress rights and requested e.l.f. cease and desist from 5 its alleged acts of infringement. Benefit filed suit when e.l.f. continued selling its Lash ‘N Roll 6 mascara. The case proceeded through a motion to dismiss and fact and expert discovery. A bench 7 trial is scheduled to begin on August 26, 2024. 8 On June 13, 2024, the parties filed cross-motions to exclude various expert witness 9 opinions. E.l.f. moved to exclude rebuttal opinions offered by Benefit expert Tim P. Fletcher, 10 while Benefit moved to exclude opinions offered by e.l.f. experts Victoria Colby, Glenn May, and 11 Sarah Butler. Benefit also moved to strike expert opinions and evidence it argues were disclosed 12 after the close of fact discovery or otherwise constituted improper rebuttal. Oral argument was 13 heard on these motions on July 18, 2024. 14 III. MOTIONS TO EXCLUDE 15 A. Legal Standard 16 Rule 702 of the Federal Rules of Evidence requires that a witness proffered as an expert by 17 a party be qualified by “knowledge, skill, experience, training, or education.” Fed. R. Evid. 702. 18 Under the test laid out in Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993), expert 19 opinion testimony is reliable if it has a “basis in the knowledge and experience of [the relevant] 20 discipline.” Id. at 592. The following factors, among others, are to be considered when evaluating 21 whether an expert’s proposed testimony is reliable: (1) “whether a theory or technique . . . can be 22 (and has been) tested,” (2) “whether the theory or technique has been subjected to peer review and 23 publication,” (3) the known or potential error rate of the particular scientific theory or technique, 24 and (4) the degree to which the scientific technique or theory is accepted in a relevant scientific 25 community. Id. at 593–94; see Kumho Tire Co. v. Carmichael, 526 U.S. 137, 151 (1999) (Daubert 26 factors are not exhaustive). “[T]he Daubert gatekeeping obligation is less pressing in connection 27 with a bench trial.” Volk v. United States, 57 F. Supp. 2d 888, 896 n.5 (N.D. Cal. 1999). 1 The proponent of an expert’s opinions bears the burden of establishing their admissibility. 2 Lust ex rel. Lust v. Merrell Dow Pharmaceuticals, Inc., 89 F.3d 594, 598 (9th Cir. 1996). Where a 3 witness relies solely on experience as the basis for expertise, they must explain how their 4 experience supports their conclusions. See Fed. R. Evid. 702 advisory committee’s note to the 5 2000 amendments. Courts reviewing Daubert motions focus on the principles and methodology 6 employed by the expert, not the conclusions the expert ultimately reaches. See Daubert, 509 U.S. 7 at 595. As such, expert testimony may not be excluded simply because it is impeachable. Alaska 8 Rent-A-Car, Inc. v. Avis Budget Grp., Inc., 738 F.3d 960, 969 (9th Cir. 2013). Instead, “[v]igorous 9 cross-examination, presentation of contrary evidence, and careful instruction on the burden of 10 proof are the traditional and appropriate means of attacking shaky but admissible evidence.” 11 Daubert, 509 U.S. at 596. 12 B. E.l.f.’s Motion to Exclude 13 E.l.f. moves to exclude the opinions and testimony of Benefit’s rebuttal expert, Tim P. 14 Fletcher, on the grounds he has insufficient experience in the beauty industry, did not support his 15 opinions with testing or data, spent little time on this case, and relied on discredited theories. First, 16 E.l.f. claims Fletcher lacks sufficient experience to be “qualified to testify about beauty products 17 or on consumer perception in the beauty industry.” Dkt. 84-2, at 6. In e.l.f.’s telling, Fletcher is an 18 industrial designer familiar with the design of consumer products for infants, exercise equipment, 19 and other categories of goods unrelated to the beauty industry such that there is no basis for him to 20 opine about “the beauty industry or cosmetic products.” Id. at 8. E.l.f. contends Fletcher spent, by 21 his own estimation, only a few hours perusing the parties’ (and third-parties’) websites to learn 22 about consumers’ online shopping experience. 23 Fletcher has more than 30 years of experience and two degrees in the design field and is 24 the named inventor on a number of design and utility patents. He has served as an expert witness 25 in cases involving a wide array of consumer products, including nail polish bottles.1 To support 26

27 1 Fletcher’s experience with nail polish bottle design is particularly relevant given e.l.f.’s claim he has no experience in the beauty sector. Even if Fletcher did not have this experience, e.l.f. does not 1 the expert opinions he offers in this case, Fletcher performed both online research on a number of 2 websites and in-person research at “two separate retailers that carry both Roller Lash and Lash ‘N 3 Roll, in which he observed how the products were sold from a consumer’s perspective.” Dkt. 95, 4 at 9. Fletcher’s in-person research in this case accords with his general practice of engaging in 5 retail environment research to understand product design. All told, Fletcher has extensive 6 experience in “product and packaging design for consumer products,” and he is sufficiently 7 qualified to apply that experience to the beauty industry. Id. at 11; see Sumotext Corp. v. Zoove, 8 Inc., No. 16-cv-1370, 2020 WL 533006, at *10 (N.D. Cal. Feb. 3, 2020) (permitting witness to 9 apply broad expertise to products at issue). E.l.f.

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Bluebook (online)
Benefit Cosmetics LLC v. E.L.F. Cosmetics, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/benefit-cosmetics-llc-v-elf-cosmetics-inc-cand-2024.