Cross v. Walmart Inc

CourtDistrict Court, N.D. Indiana
DecidedJanuary 14, 2022
Docket2:21-cv-00198
StatusUnknown

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

Bluebook
Cross v. Walmart Inc, (N.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA HAMMOND DIVISION JAMES E. CROSS, ) ) Plaintiff, ) ) v. ) NO. 2:21CV198-PPS/JPK ) DICK’S SPORTING GOODS, INC, ) KOHL’S INC, WALMART INC, and ) AMAZON INC, ) ) Defendants. ) OPINION AND ORDER Plaintiff James E. Cross brings this action without the assistance of an attorney, alleging that each of the giant retailer defendants – Dick’s Sporting Goods, Kohl’s, Walmart, and Amazon – is liable to him for patent infringement and trade dress infringement. The claims are based on Cross’s ownership of three United States Design Patents. The first, U.S. Patent No. Des. D341,471 dated November 23, 1993, is for an “ornamental design for a T-shirt.” [DE 1-1 at 3.] Both the second and third patents, U.S. Patent No. D580,633S, dated November 18, 2008, and No. D581,136S dated November 25, 2008, also claim an “ornamental design for a convertible t-shirt.” [DE 1-1 at 4, 5.] Aside from identifying Cross as the owner of the three patents, the substantive content of the complaint is entirely threadbare. Cross merely claims that each defendant has: for a long-times past and still is infringing actively inducing the infringement of and contributorily infringing in this judicial district, the patents ‘633, 136, and 417..., and Trade Dress Under section 432(a) of the Lanham Act by, among other things, importing, e-commerce, making, using, offering for sale, and/or selling T-shirts with the ornamental design as defined by the claim of the ‘633, 136, [and] 471 [patents] and without permission from Cross. [DE 1 at ¶21.] On that basis, Cross seeks declaratory relief, an injunction, and an accounting for damages. [Id. at 5-6.] Motions to dismiss (or for more definite statement) have been filed by each defendant, are fully briefed, and ripe for ruling. Walmart was the first to file, moving to dismiss on the ground that Cross’s

“single conclusory allegation” is insufficient to meet federal pleading standards and lacks the specificity required to state a claim for trade dress infringement. [DE 32 at 2- 3.] If the motion to dismiss is denied, Walmart requests that the court order plaintiff to amend the complaint to provide a more definite statement, pursuant to Fed.R.Civ.P. 12(e). [Id. at 3.] All the defendants offer a version of this same contention about the

inadequacy of Cross’s pleading. This argument reaches the heart of what is fundamentally deficient about Cross’s complaint. A motion under Fed.R.Civ.P. 12(b)(6) challenges the sufficiency of the complaint “to state a claim upon which relief can be granted.” As the Supreme Court decided in 2007, Rule 12(b)(6) requires “a claim to relief that is plausible on its face,” which in turn

requires factual allegations sufficient to permit a reasonable inference that a defendant is liable for the misconduct alleged. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 556 (2007). Cross relies on older decisions to erroneously suggest he has little or no obligation to plead facts at all. To the contrary, even though a pro se litigant like Cross is entitled to more leeway than a trained attorney in pleading his case, the complaint

2 must still “allege facts ‘plausibly suggesting (not merely consistent with)’ a showing of entitlement to relief” if it is going to avoid dismissal for failure to state a claim. Filler v. United States, 602 Fed.Appx. 518, 520 (Fed.Cir. 2015) (quoting Acceptance Ins. Cos. v.

United States, 583 F.3d 849, 853 (Fed.Cir. 2009) and Twombly, 550 U.S. at 557). See also Shelton v. United States, 539 Fed.Appx. 1011, 1013 (Fed. Cir. 2013). The court is “not bound to accept as true a legal conclusion couched as a factual allegation.” Filler, 602 Fed.Appx. at 520, quoting Twombly, 550 U.S. at 555. Cross says he has claims for patent infringement and trade dress infringement.

The Federal Circuit recently “address[ed] the stringency of pleading requirements in cases alleging patent infringement” in a case involving patents relating to video games. Bot M8 LLC v. Sony Corporation of America, 4 F.4th 1342, 1346 (Fed. Cir. 2021). The court held that “a plaintiff cannot assert a plausible claim for infringement under the Iqbal/Twombly standard by reciting the claim elements and merely concluding that the

accused product has those elements. There must be some factual allegations that, when taken as true, articulate why it is plausible that the accused product infringes the patent claim.” Bot M8 LLC, 4 F.4th at 1353. At the very least, this language indicates that an infringement claim must specifically identify the products accused of infringing. The text of Cross’s complaint contains no effort at all to do this.

Attached to the complaint are Exhibits 5 through 8, one for each defendant, containing one or more screenshots of zip-up jerseys as advertised for sale on the defendant’s website. Exhibit 5 consists of a single screenshot of one jersey on the Dick’s 3 Sporting Goods website. [DE 1-1 at 19.] Exhibit 6 for Walmart shows three jerseys on Walmart.com. [DE 1-1 at 21-22.] Exhibit 7 includes the image of one jersey advertised on Kohls.com. [DE 1-1 at 25.] Exhibit 8 for Amazon.com consists of 6 pages depicting

more than 3 dozen cycling jerseys. [DE 1-1 at 29-34.] The complaint makes no reference to these exhibits and offers no allegations about the products depicted. Cross fails to allege what the particular accused products offered by each retailer are. Even if, without any language indicating so, Walmart assumes that all three jerseys depicted in Exhibit 6 are alleged to infringe, the conclusory nature of the complaint means Cross

does not “articulate why it is plausible that the accused product infringes the patent claim.” Bot M8 LLC, 4 F.4th at 1353. Cross’s complaint does not “describe the claim in sufficient detail to give the defendant fair notice of the claim and the basis for it.” Tamayo v. Blagojevich, 526 F.3d 1074, 1084 (7th Cir. 2008). As Walmart puts it: “the pictures of the alleged infringing products failed to

bring any clarity to Plaintiff’s claims, inasmuch as they depict the entire product without reference to any particular features.” [DE 52 at 4.] To the extent Cross speaks in his opposition of his invention as a design “with relatively light material featuring the patented separating zipper down the front” [DE 44 at 10], this minimal explanation comes too late. What is argued in briefing cannot be considered to amend a pleading,

and cannot attempt to rectify deficiencies of a complaint. Bissessur v. Indiana University Bd. of Trustees, 581 F.3d 599, 603 (7th Cir. 2009) (a complaint may not be amended by the plaintiff’s opposition to a motion to dismiss). What’s worse, Walmart complains that 4 with Cross’s two filings in opposition to the motion to dismiss, he has included images of still other jerseys. [DE 52 at 4; DE 53 at 2.] Cross’s claim of patent infringement is deficient under Twombly and does not meet the minimum standards required by Rule

12(b)(6). The trade dress claim is similarly inadequate. To state a claim for trade dress infringement, a party must set forth a precise expression of the characteristics and scope of the claimed trade dress. High Point Design LLC v.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Acceptance Ins. Companies, Inc. v. United States
583 F.3d 849 (Federal Circuit, 2009)
Korsinsky v. Microsoft Corp.
198 F. App'x 931 (Federal Circuit, 2006)
Potter v. United States
424 F. App'x 941 (Federal Circuit, 2011)
John C. Boyle, Paintiff-Appellant v. United States
200 F.3d 1369 (Federal Circuit, 2000)
Shelton v. United States
539 F. App'x 1011 (Federal Circuit, 2013)
High Point Design LLC v. Buyer's Direct, Inc.
730 F.3d 1301 (Federal Circuit, 2013)
Tamayo v. Blagojevich
526 F.3d 1074 (Seventh Circuit, 2008)
Bissessur v. Indiana University Board of Trustees
581 F.3d 599 (Seventh Circuit, 2009)
Chicago Building Design, P.C. v. Mongolian House, Inc.
770 F.3d 610 (Seventh Circuit, 2014)
Filler v. United States
602 F. App'x 518 (Federal Circuit, 2015)
Daniel Loughran v. Wells Fargo Bank, N.A.
2 F.4th 640 (Seventh Circuit, 2021)
Bot M8 LLC v. Sony Corporation of America
4 F.4th 1342 (Federal Circuit, 2021)
Michael White v. Illinois State Police
15 F.4th 801 (Seventh Circuit, 2021)
Celgene Corporation v. Mylan Pharmaceuticals Inc.
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Cross v. Walmart Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cross-v-walmart-inc-innd-2022.