Grubhub Inc. v. The Kroger Co.

CourtDistrict Court, N.D. Illinois
DecidedApril 24, 2025
Docket1:21-cv-05312
StatusUnknown

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

Bluebook
Grubhub Inc. v. The Kroger Co., (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

GRUBHUB INC., et al., ) ) Plaintiffs, ) Case No. 21-cv-5312 v. ) ) District Judge Franklin U. Valderrama THE KROGER CO., et al., ) ) Magistrate Judge Jeannice W. Appenteng Defendants. ) )

MEMORANDUM OPINION AND ORDER Before the Court is defendants’ motion to compel plaintiffs’ responses to interrogatories and requests to admit, Dkt. 146, and defendants’ motion to compel third-party document production, Dkt. 148. For the reasons set forth below, the motion to compel plaintiffs is granted in part and denied in part, and the motion to compel a third party is denied. I. Background Plaintiffs Grubhub Inc. (“Grubhub”) and Takeaway.com Central Core B.V. (“Takeaway”) are “online food-ordering and delivery marketplace[s].” Dkt. 1 at 3-5. Grubhub was founded in 2004 in the United States. Takeaway was founded in 2000 and is based in the Netherlands. Id. In 2013, Grubhub merged with Seamless, a company that provides similar services. Grubhub maintains a Seamless brand to date. In June 2021, Takeaway acquired Grubhub. Shortly thereafter, Grubhub modified its logos to comply with Takeaway’s branding guidelines. The new logos feature Takeaway’s house-and-cutlery logo (referred to as the “Takeaway Home Mark”) with the name “Grubhub” or “Seamless” below or next to the house. In September 2021, Grubhub received a cease-and-desist letter from

defendants Relish Labs LLC and The Kroger Company (collectively, “Home Chef”). Id. at 15. Home Chef is a United States company that creates and delivers meal kits and provides other grocery delivery services. Dkt. 16 at 41-42. Home Chef owns several federal registrations for its logo “comprised of a fork and knife inside an outline of a house.” Id. at 43. After receiving the cease-and-desist letter, plaintiffs filed their complaint seeking declaratory judgment that their logos did not infringe

on defendants’ trademark rights. Discovery began in July 2024, after the District Judge denied defendants’ motion for preliminary injunction and the Seventh Circuit affirmed. Dkts. 76, 93. The parties began to raise disputes early in the discovery process. On January 24, 2025, the Court held a status hearing concerning disputed requests for production, interrogatories, and requests for admission. The Court instructed the parties to “engage in a meaningful meet and confer” before filing a motion to compel

interrogatory and RFA responses. Dkt. 140. The Court did not grant leave to file a motion to compel document production, instead directing the parties to meet and confer again and list outstanding disputes in a joint status report. Dkts. 140, 149. The parties evidently remain at an impasse. Defendants filed their motion to compel interrogatory and RFA responses, Dkt. 146, and the parties identified approximately 40 disputed RFPs in their March 14, 2025 joint status report, Dkt. 160. Defendants also filed a motion to compel document production from non-

party Michael Maloney. Dkt. 148. Mr. Maloney is the founder and former chief executive officer of Grubhub. Dkt. 161-1. He resigned in 2021. After Takeaway acquired Grubhub, Mr. Maloney offered to buy Grubhub twice, once in 2022 and once in 2024. Takeaway did not accept his bids. Mr. Maloney attests that he has “not been involved in Grubhub’s or Takeaway’s business or operations since [his] departure” three years ago. Id. Nevertheless, defendants issued a Rule 45 subpoena,

requesting Mr. Maloney produce all documents about his analysis of Grubhub, his offers to buy Grubhub, the trademarks at issue, Takeaway’s acquisition of Grubhub, and other trademark allegations or cases against Grubhub. Mr. Maloney, represented by plaintiffs’ counsel, objected to the requests and maintained he had no responsive documents in his possession, custody, or control. II. Legal Standard Federal Rule of Civil Procedure 26 allows parties to “obtain discovery

regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1); see also Motorola Sols., Inc. v. Hytera Commc’ns Corp., 365 F.Supp.3d 916, 924 (N.D. Ill. 2019) (“Relevance focuses on the claims and defenses in the case, not its general subject matter.”). A party may compel discovery under Rule 37 whenever another party fails to respond to a discovery request, or when its response is insufficient. Fed. R. Civ. P. 37(a). In the context of requests for admission, a party may move the Court for a ruling on the sufficiency of an answer or objection, and the Court may deem the matter admitted or order the responding party to amend its answer. Fed R. Civ.

P. 36(a)(6); Buchanan v. Chicago Transit Auth., No. 16-CV-4577, 2016 WL 7116591, at *3 (N.D. Ill. Dec. 7, 2016). Rule 45 allows a party to subpoena documents and tangible things in a non- party’s possession. Fed. R. Civ. P. 45(a)(1)(A). The scope of information discoverable under Rule 45 is the same as the scope available under Rule 26(b)(1), but the requesting party “must take reasonable steps to avoid imposing undue burden or

expense on a person subject to the subpoena.” Fed. R. Civ. P. 45(d)(1); Sabuco v. Pecelunas, No. 17-CV-9372, 2019 WL 13215194, at *1 (N.D. Ill. Sept. 17, 2019). To determine whether a subpoena imposes an undue burden, the Court considers whether (1) the request is relevant; (2) the requesting party has substantial need for the documents; (3) the request is overly broad; (4) the time period requested is reasonable; (5) the request is sufficiently particular; and (6) the non-party’s compliance would, in fact, be burdensome. Little v. JB Pritzker for Governor, No. 18

C 6954, 2020 WL 1939358, at *2 (N.D. Ill. Apr. 22, 2020). Courts have “extremely broad discretion” in controlling discovery, Jones v. City of Elkhart, 737 F.3d 1107, 1115 (7th Cir. 2013), and resolving discovery disputes, Scott v. Chuhak & Tecson, P.C., 725 F.3d 772, 785 (7th Cir. 2013). The party moving to compel discovery bears the initial burden to establish a request’s relevance, then the burden shifts to the objecting party to show why the request is improper. See Mendez v. City of Chicago, No. 18-cv-6313, 2020 WL 4736399, at *5, *8 (N.D. Ill. Aug. 14, 2020). III. Analysis

A. Defendants’ Motion to Compel Plaintiffs’ Discovery Responses i. Scope of Relevancy Prior to evaluating defendants’ various discovery requests, the Court must establish the bounds of relevancy. To prove trademark infringement under the Lanham Act, defendants must establish that (1) it owns a valid, protectable trademark, and (2) there is a likelihood of confusion as to the origin of defendants’

products. Ty, Inc. v. Jones Grp. Inc., 237 F.3d 891, 897 (7th Cir. 2001). There is no dispute that defendants own a valid, protectable trademark; thus, the case turns on whether consumers in the relevant market confuse plaintiffs’ and defendants’ marks.

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