Fitz v. Nunez

CourtDistrict Court, N.D. Texas
DecidedOctober 8, 2025
Docket3:23-cv-02298
StatusUnknown

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

Bluebook
Fitz v. Nunez, (N.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

ZEFERINO OCAMPO FITZ, § § Plaintiff, § § v. § § § ELIZABETH VENEGAS NUÑEZ, § EXECUTOR AND HEIR OF THE ESTATE § OF DAVID VENEGAS FRIAS, ALEJANDRO § Civil Action No. 3:23-CV-2298-B AGUILERA ROMAN, ALEXIS VENEGAS, § GAEL ORDAZ, EDGAR MELENDEZ, § ASCENSION QUIROZ, AND PETER § ANGEL, § § Defendants. §

MEMORANDUM OPINION AND ORDER

Before the Court are Defendants Elizabeth Venegas Nuñez, Executor and Heir of the Estate of David Venegas Frias (“Nuñez”), Alejandro Aguilera Roman, Alexis Venegas, Edgar Melendez, Armando Carlos Ascencion Quiroz, and Peter Angel (collectively, “Defendants”1)’s Motion for Summary Judgment (Doc. 54) and Plaintiff Zeferino Ocampo Fitz’s Motion for Summary Judgment (Doc. 57).2 Having reviewed the evidence, briefing, and applicable law, the Court DENIES Fitz’s Motion and GRANTS IN PART and DENIES IN PART Defendants’ Motion.

1 “Defendants,” as referenced in this Memorandum Opinion, does not include Defendant Gael Ordaz, against whom the Clerk previously issued an entry of default that was then vacated by the Court. See Doc. 45, Order. Fitz has not requested re-issuance of the entry of default against Ordaz. 2 With their Opposition to Fitz’s Motion for Summary Judgement, Defendants included a Motion to strike some of the evidence relied upon by Fitz. See Doc. 64, Br. Opp’n Pl.’s Mot., 1–7. Because the evidence to which Defendants object would not change the outcome of the Court’s ruling on the cross-motions for summary judgment, the issuance of this opinion moots Defendants’ Motion to Strike. I. BACKGROUND This lawsuit is a battle over U.S. rights to use of the trademark for the band “Los Yaguaru de Angel Venegas.” The two brothers who originally performed together under the Los Yaguaru

name—Angel Venegas Frias (“Angel”) and David Venegas (“David”)—are now deceased. Fitz, who claims that Angel’s original rights to the U.S. trademark passed to him, sued Defendants for their use of the Los Yaguaru name in the United States. Nuñez, who is David’s daughter and the current owner of David’s U.S. trademark registration for the Los Yaguaru name, claims that Defendants rightfully use the name with her permission. Fitz asserts that David obtained the U.S. trademark registration through fraud. These competing narratives of ownership extend from the band’s inception to the present.

A. Early History of the Los Yaguaru Band Around 1996, the Los Yaguaru band was formed in Mexico and shortly thereafter began to perform in the United States. See Doc. 55, Br. Supp. Defs.’ Mot., 8; Doc. 58, Br. Supp. Pl.’s Mot., 3–4. Fitz contends that the band was formed and originally owned solely by Angel and that David’s role in the band was “minor.” Doc. 58, Br. Supp. Pl.’s Mot., 3, 11; Doc. 59-1, App. Pl.’s Mot., 507. Defendants assert that David co-created the band with Angel. Doc. 55, Br. Supp. Defs.’ Mot., 8.

The parties agree that David left the band in the early years and then came back. Plaintiff says David left Los Yaguaru around 1998, formed his own separate musical group called “Grupo Carabo,” then came back to Los Yaguaru in 2012. See Doc. 58, Br. Supp. Pl.’s Mot., 11. Defendants respond that David left Los Yaguaru in 2000 and primarily performed with Grupo Carabo but continued to perform with Los Yaguaru on occasion until officially rejoining in 2012. Doc. 64, Br. Opp’n Pl.’s Mot., 19. Fitz’s connection to Los Yaguaru extends back to the 1990s, when Fitz’s father and Angel entered into an “agreement for exclusive professional artistic representation.” Doc. 59-1, App. Pl.’s Mot., 500. The agreement indicated that Angel was the sole “director and owner” of Los Yaguaru

and that he held a registered Mexican trademark and copyright for the Los Yaguaru name. Id. at 500–01. Fitz’s father was placed in charge of promoting Los Yaguaru and was licensed to use the Los Yaguaru name—which Angel promised “[t]o not assign to any third party”—in promotion efforts. Id. at 502–03. Despite the restriction on assigning the trademark rights, Angel could “remove . . . at his own discretion” then-current members of the band, including David, without frustrating the purposes of the agreement. Id. at 500. David and Fitz both signed the agreement as witnesses. Id. at

505. Fitz claims that he oversaw promotion of the band in the United States. See id. at 331. In that capacity, Fitz secured visas for Angel to perform in the United States and managed the group’s social media platforms, which remain under Fitz’s control today. See Doc. 58, Br. Supp. Pl.’s Mot., 6. B. The 2009 Assignment Fitz’s purported ownership of U.S. rights to the “Los Yaguaru” trademark comes not through

his history as manager but through two sequential written assignments, the first of which was in 2009. In that year, Angel—who was concerned for his health leading up to a major surgery, see Doc. 55, Br. Supp. Defs.’ Mot., 8—assigned at least the registered Mexican trademark to his stepdaughter Viridiana Venegas Fabian (“Fabian”). See Doc. 59-1, App. Pl.’s Mot., 482–83. The parties dispute whether the 2009 assignment also assigned Angel’s U.S. common law rights over the trademark to Fabian. See Doc. 58, Br. Supp. Pl.’s Mot., 6–7; Doc. 64, Br. Opp’n Pl.’s Mot., 10. The translated 2009 assignment states in Recital I(b) that Angel “wishes to assign the rights he holds over the exclusive use, trademark and design of ‘LOS YAGUARU DE ANGEL VENEGAS’ as granted in registrations number 552594 of the Mexican Institute of Industrial Property and

number 04 1996-000000000338-401 of the National Institute of Copyrights.” Doc. 59-1, App. Pl.’s Mot., 482. In Clause One of the 2009 assignment, Angel assigned to Fabian “the rights he holds over the exclusive use, trademark and design of ‘LOS YAGUARU DE ANGEL VENEGAS’ as listed in Recital I., paragraph b) above with all that corresponds to them in fact and law.” Id. Clause Six of the 2009 assignment states: “The conventions and clauses contained in this agreement nullify any prior verbal or written agreement. Thus this agreement reflects the conditions and terms under

which the parties to this agreement wish to obligate themselves.” Id. at 483. Although the 2009 assignment says nothing explicitly about rights to the trademark in the United States, Fitz proffers Fabian’s Declaration as proof that the transfer of rights included “any and all rights in Mexico and throughout the world.” Id. at 969. Defendants argue that the 2009 assignment, by its written terms, transferred only the rights in the registered Mexican trademark. Doc. 64, Br. Opp’n Pl.’s Mot., 10–11, 11 n.34. C. David’s 2012 Trademark Application and Fabian’s Opposition

In 2012, after the 2009 assignment from Angel to Fabian, two important events were set in motion. First, when David “rejoined” the band, he and Angel entered into a joint business venture called “Los Yaguaru de Angel Venegas, S.A. de C.V.” (the “Corporation”). See Doc. 56, App. Defs.’ Mot., 7–56. The Corporation’s purposes included the “realization, production, presentation, direction, organization, representation, interpretations and commercialization . . . of all manner of artistic, cultural, social and commercial activities[.]” Id. at 34. To that end, the Corporation’s purpose also included to “[o]btain licenses, patents, commercial names, trademarks, copyrights and in general, all real rights over industrial or intellectual property related to the business purpose.” Id. at 36. The only two shareholders at formation were Angel and David, each holding an equal number

of shares. Id. at 45. David was also initially designated “Sole Administrator,” which gave him authority over “[g]eneral power for acts of administration” and “[g]eneral power for acts of ownership.” Id. at 42–43, 46.

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