City of Leavenworth v. Projekt Bayern Association

District Court, E.D. Washington·Decided December 7, 2022·No. 2:22-cv-00174·Unknown

Opinion

EASTERN DISTRICT OF WASHINGTON

CITY OF LEAVENWORTH, a Washington municipal corporation, NO. 2:22-CV-0174-TOR Plaintiff, ORDER GRANTING PLAINTIFF’S v. DEFENDANT’S AMENDED COUNTERCLAIMS AND THIRD- PROJEKT BAYERN PARTY DEFENDANT’S MOTION ASSOCIATION, a Washington TO DISMISS THIRD-PARTY nonprofit corporation, COMPLAINT Defendant/Third-Party Plaintiff, v. LEAVENWORTH CHAMBER OF COMMERCE, a Washington nonprofit corporation, Third-Party Defendant. BEFORE THE COURT are Plaintiff’s Motion to Dismiss Defendant’s Amended Counterclaims (ECF No. 34) and Third-Party Defendant’s Motion to Dismiss Plaintiff’s Third-Party Complaint (ECF No. 36). These matters were submitted for consideration without oral argument. The Court has reviewed the record and files herein and is fully informed. For the reasons discussed below,

Plaintiff’s Motion to Dismiss Defendant’s Amended Counterclaims (ECF No. 34) is granted and Third-Party Defendant’s Motion to Dismiss Plaintiff’s Third-Party Complaint (ECF No. 36) is granted.

This matter relates to two competing Oktoberfest celebrations, one organized by Plaintiff the City of Leavenworth (“City”) and the other organized by Defendant the Projekt Bayern Association (“Projekt Bayern”). 1 ECF No. 1. On

September 21, 2022, Projekt Bayern filed Amended Counterclaims against the City and a Third-Party Complaint against Third-Party Defendant Leavenworth Chamber of Commerce (“Chamber”). ECF No. 21. The Amended Counterclaims and

Third-Party Complaint raise the following causes of action: (I) false designation of origin, false description, and unfair competition in violation of 15 U.S.C. § 1125(a) (against the City); (II) false designation of origin, false description, and unfair competition in violation of 15 U.S.C. § 1125(a) (against the Chamber); (III)

common law unfair competition (against the City); (IV) common law unfair competition (against the Chamber); (V) violation of Washington’s Consumer

1 The Court refers to the parties by name for clarity. Protection Act (against the City); and (VI) violation of Washington’s Consumer Protection Act (against the Chamber). Id. at 15–28, ¶¶ 61–134. The following

facts are drawn from Projekt Bayern’s Amended Counterclaims and Third-Party Complaint, which are accepted as true for the purposes of the present motion. Chavez v. United States, 683 F.3d 1102, 1108 (9th Cir. 2012).

Since August 1998, Projekt Bayern has rendered, among other things, entertainment services in the nature of organizing and conducting cultural festivals featuring food, beverages, alcohol, live musical performances, and entertainment for children and adults (“Projekt Bayern Services”) in connection with the

trademark LEAVENWORTH OKTOBERFEST. ECF No. 21 at 3, ¶ 8. Since that time, Projekt Bayern has operated its LEAVENWORTH OKTOBERFEST festival in the City of Leavenworth. Id. at 4, ¶ 16.

On September 26, 2012, the City and Projekt Bayern entered into a lease agreement that leased Projekt Bayern space for its LEAVENWORTH OKTOBERFEST event. Id., ¶ 17. Under this agreement, the original term was five years, with the possibility of automatic renewal after this first five-year period.

Id. at 5, ¶ 18. In 2017, the 2012 lease agreement was renewed. Id., ¶ 22. On July 11, 2017, LEAVENWORTH OKTOBERFEST was placed on the Principal Register of the United States Patent and Trademark Office (“USPTO”),

Registration No. 5,239,374. Id. at 3, ¶¶ 9–10. Projekt Bayern invested hundreds of thousands of dollars in advertising, services, and in creating brand and goodwill in connection with LEAVENWORTH OKTOBERFEST. Id. at 3–4, ¶¶ 13–14. As

a result of these activities, the public travels across the country yearly to participate in Projekt Bayern’s LEAVENWORTH OKTOBERFEST event and the public recognizes LEAVENWORTH OKTOBERFEST as representing Projekt Bayern’s

services. Id. at 4, ¶ 15. On March 23, 2021, the City terminated the 2012 lease agreement. Id. at 6, ¶ 24. On June 3, 2022, the City issued a press release stating: “Historically,

October has been reserved for Oktoberfest. The City is seeking a new style of partnership with an entity that will conceptualize, plan, prepare, execute, evaluate and replicate a marquee event to promote the City, showcase local businesses,

respect community character, celebrate inclusion, and balance the needs of visitors and residents in October.” Id. at 6, ¶ 25. The City rejected Projekt Bayern’s proposal to operate a LEAVENWORTH OKTOBERFEST event. Id., ¶ 26. Following the City’s rejection, Projekt Bayern moved its LEAVENWORTH

OKTOBERFEST event to Wenatchee, Washington. Id., ¶ 28. Projekt Bayern continues to operate the LEAVENWORTH OKTOBERFEST event in the same manner as years prior, including hiring the same musicians and vendors, marketing

the event to the same prospective visitors, shuttling bus services between Leavenworth and Wenatchee, and promoting Old-World Bavarian themes in Leavenworth and the surrounding area. Id. at 6–7, ¶ 29.

On July 11, 2022, the City announced that it would operate an “Oktoberfest 2022” (“2022 Festival”) in Leavenworth to compete with Projekt Bayern’s event in Wenatchee. Id. at 7, ¶ 33. The Chamber, in partnership with the City, planned to

provide the 2022 Festival in a geographic area that directly overlaps with the area in which Projekt Bayern provides its’ services. Id. at 7–8, ¶ 34. The City and Chamber marketed the 2022 Festival as an “event identical” to Projekt Bayern’s. Id. at 8, ¶ 35. Despite Projekt Bayern’s event being the only Oktoberfest in the

City for 20 years, the City and Chamber advertised that “Oktoberfest returns to Leavenworth” and included photos of Projekt Bayern events. See id. at 8–11, ¶¶ 36–43. While Projekt Bayern does not allege the City or Chamber used its

trademark, it alleges in one advertisement that the words “Leavenworth” and “Oktoberfest” are “close together to subconsciously bring ‘LEAVENWORTH OKTOBERFEST’ to the consumers’ minds.” Id. at 10, ¶ 39.

I. Motion to Dismiss Standard Federal Rule of Civil Procedure 12(b)(6) provides that a defendant may move to dismiss the complaint for “failure to state a claim upon which relief can be

granted.” A 12(b)(6) motion will be denied if the plaintiff alleges “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v.

Twombly, 550 U.S. 544, 570 (2007)). While the plaintiff’s “allegations of material fact are taken as true and construed in the light most favorable to the plaintiff” the plaintiff cannot rely on “conclusory allegations of law and unwarranted inferences

… to defeat a motion to dismiss for failure to state a claim.” In re Stac Elecs. Sec. Litig., 89 F.3d 1399, 1403 (9th Cir. 1996) (citation and brackets omitted). That is, the plaintiff must provide “more than labels and conclusions, and a formulaic recitation of the elements.” Twombly, 550 U.S. at 555.

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