Emazing Photography LLC v. AMcCurdy Design Firm LLC

CourtDistrict Court, W.D. Washington
DecidedOctober 26, 2022
Docket2:22-cv-00035
StatusUnknown

This text of Emazing Photography LLC v. AMcCurdy Design Firm LLC (Emazing Photography LLC v. AMcCurdy Design Firm LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emazing Photography LLC v. AMcCurdy Design Firm LLC, (W.D. Wash. 2022).

Opinion

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4 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 EMAZING PHOTOGRAPHY, LLC; and ERICA DANIELS, 8 Plaintiffs, 9 C22-0035 TSZ v. 10 ORDER MCCURDY DESIGN FIRM, LLC, et 11 al., 12 Defendants. 13 THIS MATTER comes before the Court on a motion to dismiss counterclaim and 14 strike certain defenses, docket no. 24, filed by plaintiffs and counter-defendants Emazing 15 Photography, LLC (“Emazing Photography”) and Erica Daniels (collectively 16 “Plaintiffs”). Having reviewed all papers filed in support of, and in opposition to, the 17 motion, the Court enters the following Order. 18 Background 19 Daniels, a photographer, founded Emazing Photography in 2013. Compl. at ¶ 2 20 (docket no. 1). In February 2021, Plaintiffs contracted with defendants and counter- 21 claimants Ashleigh McCurdy, an interior designer, and her business, AMcCurdy Design 22 1 Firm, LLC (“AMDF”) (collectively “Defendants”) in which Defendants agreed to design 2 and stage certain areas in Emazing Photography’s studio. Id. at ¶ 12; Am. Countercl. at 3 ¶¶ 4–11 (docket no. 23). In March 2021, after Defendants completed the project, Daniels

4 took four photographs of one of the newly staged areas. Compl. at ¶ 19; Exs. 1–4 to 5 Compl. (docket nos. 7–7-3). Plaintiffs registered the photographs with the Copyright 6 Office in April 2021. Compl. at ¶ 20; Certificate of Registration No. VA 2-249-533, 7 Ex. 5 to Compl. (docket no. 7-4). 8 On or about March 27, 2021, Daniels allegedly posted the photographs on her

9 private Facebook account to share with her family and friends. Compl. at ¶ 22. Plaintiffs 10 assert that Defendants took the photographs from Daniels’s private Facebook account and 11 posted them on Defendants’ social media accounts to promote Defendants’ interior 12 design business. Id. at ¶¶ 22–31. Plaintiffs contend that Defendants posted the 13 photographs without Plaintiffs’ consent, license, authorization, or agreement. Id. at ¶ 32.

14 Plaintiffs also allege that Defendants performed substandard work during the interior 15 design project and provided broken furniture and other unusable design elements. Id. at 16 ¶ 14. Plaintiffs bring claims against Defendants for copyright infringement and breach of 17 contract. Id. at ¶¶ 37–68. 18 Defendants bring a counterclaim against Plaintiffs for (i) tortious interference with

19 a business expectancy, (ii) breach of contract, and (iii) invalidation of copyright 20 registration no. VA 2-249-533. Am. Countercl. at ¶¶ 24–38. Defendants contend that 21 they provided Plaintiffs with interior design services at a discounted rate in exchange for 22 publicity on Plaintiffs’ social media accounts. Id. at ¶¶ 8, 24, 29. Defendants allege that 1 the contract required Plaintiffs to credit Defendants as the interior designers if Plaintiffs 2 took photographs of the project and released the images publicly. Id. at ¶ 17. According 3 to Defendants’ counterclaim, Plaintiffs breached the contract by posting photographs of

4 the project on Emazing Photography’s public Instagram account without crediting 5 Defendants’ interior design work, which interfered with Defendants’ ability to obtain 6 prospective customers. See id. at ¶¶ 29, 34. Defendants also contend that Plaintiffs failed 7 to disclose to the Copyright Office Defendants’ involvement in the creation of the four 8 photographs referenced above. Id. at ¶ 37.

9 Plaintiffs now move under Federal Rule of Civil Procedure 12(b)(6) to dismiss 10 Defendants’ claims for breach of contract and tortious interference with a business 11 expectancy, and under Rule 12(f) to strike seven of Defendants’ defenses. Plaintiffs also 12 move for “declaratory judgment” on the validity of copyright registration no. VA 2-249- 13 533 and Plaintiffs’ copyright infringement claim, which the Court construes as a motion

14 for partial summary judgment under Rule 56. 15 Discussion 16 1. Motion to Dismiss 17 a. Motion to Dismiss Standard 18 Although a pleading challenged by a Rule 12(b)(6) motion to dismiss need not

19 provide detailed factual allegations, it must offer “more than labels and conclusions” and 20 contain more than a “formulaic recitation of the elements of a cause of action.” Bell Atl. 21 Corp. v. Twombly, 550 U.S. 544, 555 (2007). The pleading must indicate more than mere 22 speculation of a right to relief. See id. When a pleading fails to adequately state a claim, 1 such deficiency should be “exposed at the point of minimum expenditure of time and 2 money by the parties and the court.” Id. at 558. A pleading may be lacking for one of 3 two reasons: (i) absence of a cognizable legal theory, or (ii) insufficient facts under a

4 cognizable legal claim. See Robertson v. Dean Witter Reynolds, Inc., 749 F.2d 530, 534 5 (9th Cir. 1984). In ruling on Plaintiffs’ motion to dismiss the counterclaim, the Court 6 must assume the truth of Defendants’ allegations and draw all reasonable inferences in 7 Defendants’ favor. See Usher v. City of Los Angeles, 828 F.2d 556, 561 (9th Cir. 1987). 8 The question for the Court is whether the facts in the counterclaim sufficiently state a

9 “plausible” ground for relief. See Twombly, 550 U.S. at 570. 10 b. Breach of Contract 11 To prevail on their breach of contract claim, Defendants must establish (i) that the 12 contract at issue imposes a duty, (ii) breach of that duty, and (iii) damages proximately 13 caused by the breach. See Nw. Indep. Forest Mfrs. v. Dep’t of Labor & Indus., 78 Wn.

14 App. 707, 712, 899 P.2d 6 (1995). Defendants contend that the parties entered into a 15 valid and binding contract in which Defendants agreed to design and stage certain areas 16 in Emazing Photography’s studio. Am. Countercl. at ¶¶ 1–11, 31–35. Defendants allege 17 that the contract required Plaintiffs to credit Defendants as the interior designers if 18 Plaintiffs photographed the project and released the images publicly. Id. at ¶ 17.

19 According to Defendants, Plaintiffs breached the contract by publishing photos of the 20 interior design project on Emazing Photography’s public Instagram account without 21 crediting Defendants as the interior designers. Id. at ¶ 34. As a result of Plaintiffs’ 22 alleged conduct, Defendants claim to have suffered damages. Id. at ¶ 35. The Court 1 concludes that Defendants have stated a plausible ground for relief, and Plaintiffs’ motion 2 to dismiss is DENIED as it relates to Defendants’ claim for breach of contract. 3 c. Tortious Interference with a Business Expectancy

4 To prevail on their claim for tortious interference with a business expectancy, 5 Defendants must prove five elements: (i) the existence of a valid business expectancy; 6 (ii) that Plaintiffs had knowledge of the expectancy; (iii) an intentional interference 7 inducing or causing termination of the expectancy; (iv) that Plaintiffs interfered for an 8 improper purpose or used improper means; and (v) resulting damage. See Greensun

9 Grp., LLC v. City of Bellevue, 7 Wn. App. 2d 754, 767–68, 436 P.3d 397 (2019). A valid 10 business expectancy is “something less than an enforceable contract,” id. at 768, and 11 “includes any prospective contractual or business relationship that would be of pecuniary 12 value,” Newton Ins. Agency & Brokerage, Inc. v.

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