Bratt v. Lovestories TV Inc.

CourtDistrict Court, S.D. California
DecidedJanuary 26, 2024
Docket3:23-cv-00100
StatusUnknown

This text of Bratt v. Lovestories TV Inc. (Bratt v. Lovestories TV Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bratt v. Lovestories TV Inc., (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 BRYAN MARSHALL BRATT, Case No. 23-cv-0100-BAS-JLB

12 Plaintiff, ORDER GRANTING IN PART AND 13 v. DENYING IN PART DEFENDANT’S MOTION TO DISMISS 14 LOVE STORIES TV, INC.,

15 Defendant. (ECF No. 19)

16 17

18 Plaintiff Bryan Marshall Bratt, self-represented, filed a First Amended Complaint 19 against Defendant Love Stories TV, Inc. alleging various claims, including violations of 20 the Lanham Act and common law trademark infringement. (First Am. Compl. (“FAC”) 21 ¶¶ 28, 38, ECF No 18.) Plaintiff alleges Defendant uses his business name, which is 22 protected by trademark and copyright, while offering an “essentially identical” service. 23 (Id. ¶ 6.) Plaintiff alleges that this infringement has caused “significant damage” to his 24 business. (Id. ¶ 19.) 25 Defendant moves to dismiss, claiming the Court has no personal jurisdiction over it, 26 and Plaintiff fails to state a claim upon which relief can be granted. (Mot. 2:10–3:9, ECF 27 No 19.) The Court finds this motion suitable for determination on the papers submitted 28 1 and without oral argument. See Civ. L.R. 7.1(d)(1). For the reasons stated below, the 2 Court GRANTS IN PART and DENIES IN PART Defendant’s Motion to Dismiss. 3 I. BACKGROUND 4 The Court underscores that Plaintiff is self-represented. Generally, the Court must 5 broadly construe his pleadings, affording him any benefit of the doubt. See Erickson v. 6 Pardus, 551 U.S. 89, 94 (2007); Thompson v. Davis, 295 F.3d 890, 895 (9th Cir. 2002). 7 Plaintiff is allegedly the original creator, first user, and owner of the term “Wedding Video 8 Awards.” (FAC ¶ 17.) Plaintiff alleges that he began using this term in commerce in 2014. 9 (Id.) Plaintiff applied to register and obtain copyright and trademark protection for 10 “Wedding Video Awards,” but the application was abandoned due to “lack of legal 11 knowledge.” (Id. ¶ 18.) Nevertheless, Plaintiff asserts that his business name and model 12 are still protected under federal and state law. (See id. ¶¶ 18, 22.) 13 Defendant Love Stories TV, Inc. has its principal place of business in Brooklyn, 14 New York, and is a Delaware corporation. (FAC ¶ 13.) Defendant hosts the “Wedding 15 Film Awards.” (Id. ¶ 19.) Plaintiff alleges that Defendant’s competing “Wedding Film 16 Awards” service bears a near-identical resemblance to his own business name and model. 17 (Id.) Plaintiff avers Defendant “purposefully availed [itself] of this judicial district” by 18 offering infringing content through its website aimed at this forum and by attempting to 19 partner with California businesses and promote sales in California. (Id. ¶ 7.) 20 More specifically, Plaintiff alleges the winners of Defendant’s Wedding Film 21 Awards receive cash prizes, and Defendant features California residents and weddings on 22 its platform. (FAC ¶ 14.) Plaintiff alleges Defendant’s Wedding Film Awards are part of 23 a concerted effort to cultivate “deep [business-to-business] relations in California” with 24 wedding vendors, “more than [in] any other forum.” (Id.) Indeed, as part of its wedding- 25 focused business, Defendant features vendors on its website. (Id.) These vendors allegedly 26 pay $2,500 for six months of advertising on the site. (Id.) Defendant lists 6,637 California 27 wedding vendors on its website, which is more than any other state. (Id.) This same 28 website promotes the Wedding Film Awards, and Plaintiff contends Defendant’s activities 1 and the Wedding Film Awards should go “hand in hand.” (ECF No. 22.) “They are sharing 2 the same website, audience, [and] general business goals” as part of Defendant’s effort to 3 solicit wedding-related business, particularly in California. (Id.; FAC ¶ 14.) Moreover, 4 Plaintiff alleges Defendant knew its conduct “would directly impact the Wedding Video 5 Awards” operated by Plaintiff. (FAC ¶ 14.) Defendant “took action to crush [the Wedding 6 Video Awards] in California.” (Id.) Plaintiff has consequently been forced to “reconsider 7 the entire business as it [has] lost its value and strength.” (Id.) 8 Defendant moves to dismiss, arguing this Court may not exercise personal 9 jurisdiction over it for the following reasons: (1) Defendant’s website has a national 10 viewership, but the website does not target the forum state either expressly or indirectly; 11 and (2) Plaintiff fails to plead any facts demonstrating Defendant’s website is “expressly 12 aimed” at California residents. (Mot. 12:13–19.) Defendant further asserts that Plaintiff 13 does not bear a mark, nor does he have a copyright, for the term “Wedding Video Awards,” 14 as is required to bring forth copyright and certain trademark claims. (Id. 11:10–17.) 15 Defendant also contends that Plaintiff fails to allege sufficient facts for his remaining 16 claims under federal and state law. (Id. 2:14–15.) 17 II. LEGAL STANDARDS 18 A. Personal Jurisdiction 19 Rule 12(b)(2) authorizes the dismissal of an action for lack of personal jurisdiction. 20 Fed. R. Civ. P. 12(b)(2). When a defendant moves to dismiss on this ground, “the plaintiff 21 bears the burden of demonstrating that jurisdiction is appropriate.” Will Co. v. Lee, 47 22 F.4th 917, 921 (9th Cir. 2022). If the defendant’s motion is based on written materials, and 23 no evidentiary hearing is held, then the court will evaluate only whether the plaintiff makes 24 a prima facie showing of personal jurisdiction based on the plaintiff’s pleadings and 25 affidavits. Id. The court must take unchallenged allegations in the complaint as true, and 26 conflicts between the parties over statements within any affidavits must be resolved in 27 favor of the plaintiff. Id. 28 1 The general rule provides that personal jurisdiction over a defendant is proper if it is 2 permitted by a long-arm statute and if the exercise of that jurisdiction does not violate 3 federal due process. Pebble Beach Co. v. Caddy, 453 F.3d 1151, 1154 (9th Cir. 2006). For 4 due process to be satisfied, a defendant must have “minimum contacts” within the forum 5 state such that asserting jurisdiction over the defendant would not “offend traditional 6 notions of fair play and substantial justice.” Id. at 1155 (citing Int’l Shoe Co. v. 7 Washington, 326 U.S. 310, 315 (1945)). Both California and federal long-arm statutes 8 require compliance with due process requirements. Daimler AG v. Bauman, 571 U.S. 117, 9 125 (2014). 10 There are two types of personal jurisdiction: general and specific. Daimler, 571 U.S. 11 at 118. General jurisdiction allows a court to hear cases unrelated to the defendant’s forum 12 activities and exists if the defendant has “substantial” or “continuous and systematic” 13 contacts with the forum state. Fields v. Sedgewick Assoc. Risk, Ltd., 769 F.2d 299, 301 14 (9th Cir. 1986) (citing Haisten v. Grass Valley Med. Reimbursement Fund, Ltd., 784 F.2d 15 1392, 1396 (9th Cir. 1986)). Specific jurisdiction permits the court to exercise jurisdiction 16 over a defendant who has availed itself through forum-related activities that gave rise to 17 the action before the court. Bancroft & Masters, Inc. v. August Nat’l Inc., 223 F.3d 1082, 18 1086 (9th Cir. 2000), overruled on other grounds in part by Yahoo! Inc. v. La Ligue Contre 19 Le Racisme Et L’Antisemitisme, 433 F.3d 1199 (9th Cir. 2006). 20 B. Failure to State a Claim 21 A complaint must plead sufficient factual allegations to “state a claim to relief that 22 is plausible on its face.” Ashcroft v.

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Bratt v. Lovestories TV Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/bratt-v-lovestories-tv-inc-casd-2024.