Gilmore v. Shanghai Xiaoxu International Trade Co., LTD

CourtDistrict Court, E.D. Texas
DecidedOctober 7, 2025
Docket4:24-cv-00275
StatusUnknown

This text of Gilmore v. Shanghai Xiaoxu International Trade Co., LTD (Gilmore v. Shanghai Xiaoxu International Trade Co., LTD) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gilmore v. Shanghai Xiaoxu International Trade Co., LTD, (E.D. Tex. 2025).

Opinion

United States District Court EASTERN DISTRICT OF TEXAS SHERMAN DIVISION

ERIC GILMORE and REBECCA § MAHONEY, Individually and as Next § Friends of K.G., a Minor, § § Plaintiffs, § v. § Civil Action No. 4:24-cv-275 § Judge Mazzant SHANGHAI XIAOXU INTERNATIONAL § TRADE CO., LTD., BLTPRESS, and EBAY § INC., § § Defendants. § MEMORANDUM OPINION AND ORDER Pending before the Court is Defendant eBay Inc.’s Motion to Dismiss Plaintiffs’ First Amended Complaint under Rule 12(b)(6) and Brief in Support (Dkt. #20). Having considered the Motion and the relevant pleadings, the Court finds that the Motion should be GRANTED. BACKGROUND Plaintiffs Eric Gilmore and Rebecca Mahoney, individually and as Next Friends of K.G., a Minor (collectively, “Plaintiffs”), brought this product liability action against Defendants Shanghai Xiaoxu International Trade Co., Ltd. (“SXIT”), BLTpress (“BLT”), and eBay Inc. (“eBay” or “Defendant”) (collectively, “Defendants”) under Texas law, invoking the Court’s diversity jurisdiction (Dkt. #14).1 On July 3, 2018, Plaintiffs purchased an inflatable gymnastics mat (the “Product”) from a friend who originally bought the Product on eBay (Dkt. #14 at ¶ 3.1). On May 14, 2022, one of the

1 On February 5, 2025, Plaintiffs filed their First Amended Complaint (the “Complaint”) (Dkt. #14). Plaintiffs allegedly suffered an injury caused by the Product (Dkt. #14 at ¶ 3.3). Plaintiffs allege Defendants failed to take reasonable care in developing, designing, manufacturing, testing, selling, and/or marketing a product free from defects and safe for consumer use (Dkt. #14 at ¶ 3.6). As a

result, Plaintiffs assert causes of action against Defendants for strict liability, negligence, breach of express warranty, and breach of implied warranty of merchantability (Dkt. #14 at ¶¶ 4.1–4.24). On March 31, 2025, eBay, an online marketplace, filed its Motion to Dismiss arguing Texas law bars Plaintiffs’ claims against it (Dkt. #20). On April 28, 2025, Plaintiffs filed their Response (Dkt. #29). On May 12, 2025, eBay filed its Reply (Dkt. #32). The Motion is now ripe for adjudication.

LEGAL STANDARD The Federal Rules of Civil Procedure require that each claim in a complaint include a “short and plain statement . . . showing that the pleader is entitled to relief.” FED. R. CIV. P. 8(a)(2). Each claim must include enough factual allegations “to raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). A Rule 12(b)(6) motion allows a party to move for dismissal of an action when the complaint fails to state a claim upon which relief can be granted. FED. R. CIV. P. 12(b)(6). When considering a

motion to dismiss under Rule 12(b)(6), the Court must accept as true all well-pleaded facts in the plaintiff’s complaint and view those facts in the light most favorable to the plaintiff. Bowlby v. City of Aberdeen, 681 F.3d 215, 219 (5th Cir. 2012). The Court may consider “the complaint, any documents attached to the complaint, and any documents attached to the motion to dismiss that are central to the claim and referenced by the complaint.” Lone Star Fund V (U.S.), L.P. v. Barclays Bank PLC, 594 F.3d 383, 387 (5th Cir. 2010). The Court must then determine whether the complaint states a claim for relief that is plausible on its face. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Gonzalez v. Kay, 577 F.3d 600, 603 (5th Cir. 2009)

(quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). “But where the well-pleaded facts do not permit the [C]ourt to infer more than the mere possibility of misconduct, the complaint has alleged—but it has not ‘show[n]’—‘that the pleader is entitled to relief.’” Iqbal, 556 U.S. at 679 (quoting FED. R. CIV. P. 8(a)(2)). In Iqbal, the Supreme Court established a two-step approach for assessing the sufficiency of a complaint in the context of a Rule 12(b)(6) motion. First, the Court should identify and

disregard conclusory allegations, for they are “not entitled to the assumption of truth.” Iqbal, 556 U.S. at 664. Second, the Court “consider[s] the factual allegations in [the complaint] to determine if they plausibly suggest an entitlement to relief.” Id. “This standard ‘simply calls for enough facts to raise a reasonable expectation that discovery will reveal evidence of the necessary claims or elements.’” Morgan v. Hubert, 335 F. App’x 466, 470 (5th Cir. 2009) (citation omitted). This evaluation will “be a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 679. Thus, “[t]o survive a motion to dismiss, a

complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Id. at 678 (quoting Twombly, 550 U.S. at 570). ANALYSIS The Texas Product Liability Act (“TPLA”) governs all products liability claims, whether the claim is based on strict liability, negligence, misrepresentation, or some other theory. See TEX. CIV. PRAC. & REM. CODE § 82.001, et seq.; see id. at § 82.001(2) (defining a “products liability action” as “any action against a manufacturer or seller for recovery of damages arising out of personal injury, death, or property damage allegedly caused by a defective product whether the action is based in strict tort liability, strict products liability, negligence, misrepresentation, breach

of express or implied warranty, or any other theory or combination of theories”). Under Section 82.003 of the TPLA, a seller that did not manufacture a product that is alleged to have caused damage is generally not liable for the harm caused by that product. See id. § 82.003. Rather, to recover against a non-manufacturing seller of a product, a plaintiff must plead and prove one of seven specified exceptions to this blanket protection. See id. at § 82.003(a). In its Motion, eBay urges the Court to dismiss Plaintiffs’ strict liability, negligence, breach

of express warranty, and breach of implied warranty of merchantability claims, arguing each is barred under the TPLA (Dkt. # 20). Specifically, eBay argues under existing Fifth Circuit and Texas Supreme Court case law, eBay is not a “seller” under the TPLA (Dkt. #20 at pp. 9–13). Plaintiffs concede that under the current interpretation of the TPLA, the definition of “seller” excludes digital online marketplaces like Amazon, Etsy, or eBay (Dkt. #29 at pp. 4, 7). However, Plaintiffs argue Texas law should be changed: Given that consumers are using online marketplaces like eBay and Amazon at ever increasing rates and many foreign manufacturers of products sold on these platforms no longer exist or are unreachable, Texas courts should change the current interpretation of what constitutes a “seller” under Chapter 82 to include online marketplaces such as eBay.

(Dkt. #29 at pp. 3–4).

“Where, as here, the proper resolution of the case turns on the interpretation of Texas law, we are bound to apply [Texas] law as interpreted by the state’s highest court.” Am. Int’l Specialty Lines Ins. Co. v. Rentech Steel LLC, 620 F.3d 558, 564 (5th Cir. 2010) (citation modified).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Morgan v. Gusman
335 F. App'x 466 (Fifth Circuit, 2009)
Gonzalez v. Kay
577 F.3d 600 (Fifth Circuit, 2009)
Lone Star Fund v (U.S.), L.P. v. Barclays Bank PLC
594 F.3d 383 (Fifth Circuit, 2010)
Estate of Cowart v. Nicklos Drilling Co.
505 U.S. 469 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Bowlby v. City of Aberdeen, Miss.
681 F.3d 215 (Fifth Circuit, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Gilmore v. Shanghai Xiaoxu International Trade Co., LTD, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gilmore-v-shanghai-xiaoxu-international-trade-co-ltd-txed-2025.