Cricut v. Enough For Everyone

CourtDistrict Court, D. Utah
DecidedFebruary 24, 2025
Docket2:21-cv-00601
StatusUnknown

This text of Cricut v. Enough For Everyone (Cricut v. Enough For Everyone) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cricut v. Enough For Everyone, (D. Utah 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

CRICUT, INC., a Delaware corporation, MEMORANDUM DECISION AND ORDER GRANTING IN PART Plaintiff, PLAINTIFF’S MOTION TO CLARIFY OR RECONSIDER v.

ENOUGH FOR EVERYONE, INC., a Case No. 2:21-cv-00601-TS-DAO Nevada corporation, and DESIRÉE TANNER, an individual, District Judge Ted Stewart

Defendants. Magistrate Judge Daphne A. Oberg

This matter is before the Court on Plaintiff Cricut, Inc’s Motion to Clarify or Reconsider the Court’s Order excluding certain opinions of Plaintiff’s expert, Charles L. Mauro. For the reasons discussed herein, the Court will grant the Motion in part. I. BACKGROUND On September 26, 2024, following a motion to exclude brought by Defendants Enough for Everyone (”EFE”) and Desiree Tanner, the Court entered an Order excluding Opinion 2 and Opinion 3 of Cricut’s expert, Charles L. Mauro, among other things.1 The Court found Mauro’s Opinions 2 and 3 were no longer relevant based on the Court granting partial summary judgement to Cricut on related issues. The Court did not make any findings as to either opinion’s admissibility under Fed. R. Evid. 702. Circuit now seeks clarification or reconsideration from the Court finding that Opinion 2 was excluded as moot, and Opinion 3 is relevant and therefore admissible.

1 Docket No. 274. II. DISCUSSION “Grounds warranting a motion to reconsider include (1) an intervening change in the controlling law, (2) new evidence previously unavailable, and (3) the need to correct clear error or prevent manifest injustice.”2 “[A] motion for reconsideration is appropriate where the court has misapprehended the facts, a party’s position, or the controlling law. It is not appropriate to

revisit issues already addressed or advance arguments that could have been raised in prior briefing.”3 Cricut argues that Opinion 2 would be better excluded as “moot” than as irrelevant because the Court did not find any of Mauro’s opinions to be deficient under Rule 702. Cricut seeks clarification on this point to avoid any negative consequences for Mauro. This does not present an issue warranting reconsideration. However, to the extent it is necessary, the Court clarifies that the Court did not analyze the sufficiency of Mauro’s Opinion 2 under Rule 702, and the irrelevance finding was based on a change in the relevant facts, not an evaluation of Mauro’s expertise or testimony on this point. Cricut next argues that Opinion 3 should not be excluded because it is relevant to some of

the remaining issues between the parties. Cricut states that, “[t]he Court’s exclusion of Opinion 3 was predicated on the Court’s understanding of Cricut’s own briefing, that Mauro’s Opinion 3 would be relevant only if the Brulotte rule did not apply.”4 However, Cricut now states that it should have more clearly explained that Opinion 3 is relevant to all of Cricut’s remaining claims for declaratory judgment.

2 F.D.I.C. v. Heaton, No. 2:13-CV-219 TS, 2014 WL 4415377, at *1 (D. Utah Sept. 8, 2014) (quoting Servants of Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000)). 3 Id. (quoting Servants of Paraclete, 204 F.3d at 1012). 4 Docket No. 275, at 2 (citing Docket No. 274, at 13). Section 3.3 of the 2007 Agreement requires Cricut to pay royalties on Cricut-branded cartridges and cartridges that have “the same fit, form, or function.” At some point, Cricut began using digital downloads instead of physical cartridges. The parties dispute whether Cricut owed royalties for the digital downloads under the terms of the 2007 Agreement. In his Opinion 3, Mauro opines that digital downloads do not having the same “fit, form, or function” as

“cartridges.” The Court agrees with Cricut that this opinion is relevant to Cricut’s remaining claims, which seek return of alleged overpaid royalties. Whether the royalties were owed is dependent in part upon whether digital downloads used by Cricut are the same “fit, form, or function” as “cartridges” for which Defendants were owed royalties. In the Court’s Summary Judgment Order, it concluded that royalties were not owed past the expiration of the patents. However, Cricut contends that some royalties were overpaid before the expiration of the patent. The testimony is, therefore, relevant, and the Court finds that reconsideration is appropriate here to correct a clear error. Notably, Defendants do not dispute the relevance of Opinion 3, but instead argue the Motion was brought too late and that Cricut should have argued its relevance previously in response to Defendants’ motion to exclude. The Court is not persuaded such deficiencies prevent the Court from correcting an order well before trial.5

Having found Opinion 3 to be relevant, the Court must then determine if it is otherwise admissible. Federal Rule of Evidence 702 allows an expert to testify if the Court finds by a preponderance of the evidence that: (a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue;

5 See Fed. R. Civ. P. 54(b) (“[A]ny order or other decision, however designated, that adjudicates fewer than all the claims or the rights and liabilities of fewer than all the parties does not end the action as to any of the claims or parties and may be revised at any time before the entry of a judgment adjudicating all the claims and all the parties’ rights and liabilities.”). (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and (d) the expert’s opinion reflects a reliable application of the principles and methods to the facts of the case.6 Rule 702 “‘imposes upon the trial judge an important gate-keeping function with regard to the admissibility of expert opinions.’”7 This involves a two-step analysis.8 The district court “must first determine whether the expert is qualified ‘by knowledge, skill, experience, training, or education’ to render an opinion.”9 Second, “the court must determine whether the expert’s opinion is reliable by assessing the underlying reasoning and methodology.”10 “‘To be reliable, expert testimony must be based on actual knowledge, and not mere subjective belief or unsupported speculation.’”11 The standard under Rule 702 is “liberal . . . regarding expert qualifications,”12 and “rejection of expert testimony is the exception rather than the rule.”13 However, “[t]he proponent of expert testimony bears the burden of showing that the testimony is admissible.”14

6 Fed. R. Evid. 702. 7 Mathis v. Huff & Puff Trucking, Inc., 787 F.3d 1297, 1307 (10th Cir. 2015) (quoting Ralston v. Smith & Nephew Richards, Inc., 275 F.3d 965, 969 (10th Cir. 2001)); see generally Daubert v. Merrell Dow Pharms. Inc., 509 U.S. 579 (1993). 8 See United States v. Nacchio, 555 F.3d 1234, 1241 (10th Cir. 2009) (en banc). 9 Id. (quoting Fed. R. Evid. 702). 10 Id. (citing United States v. Rodriguez–Felix, 450 F.

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Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Mitchell v. Gencorp Inc.
165 F.3d 778 (Tenth Circuit, 1999)
Servants of the Paraclete v. Does
204 F.3d 1005 (Tenth Circuit, 2000)
Ralston v. Smith & Nephew Richards, Inc.
275 F.3d 965 (Tenth Circuit, 2001)
United States v. Rodriguez-Felix
450 F.3d 1117 (Tenth Circuit, 2006)
United States v. Lupe Gomez
67 F.3d 1515 (Tenth Circuit, 1995)
Conroy v. Vilsack
707 F.3d 1163 (Tenth Circuit, 2013)
United States v. Nacchio
555 F.3d 1234 (Tenth Circuit, 2009)
Heer v. Costco Wholesale Corporation
589 F. App'x 854 (Tenth Circuit, 2014)
Mathis v. Huff & Puff Trucking, Inc.
787 F.3d 1297 (Tenth Circuit, 2015)

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