GS Holistic, LLC v. A Robinson Recycling Center LLC

CourtDistrict Court, E.D. California
DecidedDecember 2, 2024
Docket2:22-cv-02087
StatusUnknown

This text of GS Holistic, LLC v. A Robinson Recycling Center LLC (GS Holistic, LLC v. A Robinson Recycling Center LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GS Holistic, LLC v. A Robinson Recycling Center LLC, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 GS HOLISTIC, LLC, Case No. 2:22-cv-002087-DJC-JDP 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 A ROBINSON RECYCLING CENTER LLC d/b/a SMOKE N STUFF and ALYA 15 N ROBINSION, 16 Defendants. 17 18 Plaintiff in this trademark infringement action alleges that defendants used its registered 19 marks to sell competing products without plaintiff’s permission. Defendants have neither 20 answered the complaint nor otherwise appeared. Plaintiff now moves for default judgment 21 against both defendants. ECF No. 15. I recommend that plaintiff’s motion be granted in part and 22 denied in part. 23 Background 24 The complaint alleges that, since 2020, plaintiff has marketed and sold glass infusers and 25 related accessories. ECF No. 1 at 3. Plaintiff is the owner of the “Stüdenglass” trademark and 26 two other related trademarks—U.S. Trademark Registration Numbers 6,633,884; 6,174,292; and 27 6,174,291 (“marks”)—which have been used in connection with the manufacturing and sale of 28 plaintiff’s products. Id. at 3-4. Plaintiff has continuously used the marks since 2020, and goods 1 bearing the distinct marks are widely recognized as superior to competing products. Id. at 4. 2 Defendants have, without plaintiff’s consent, sold counterfeit products bearing one or more of 3 plaintiff’s marks. Id. at 6. Based on these allegations, plaintiff alleges two claims under the 4 Lanham Act: (1) counterfeiting and infringement under trademark, 15 U.S.C. § 1114; and 5 (2) false designation of origin and unfair competition, 15 U.S.C. § 1125(a). Id. at 10-13. 6 Plaintiff filed proofs of service showing that defendant Robinson was personally served 7 with a copy of the summons and complaint on February 1, 2023, and service was completed on 8 defendant A Robinson Recycling Center, LLC (“Robinson Recycling”) by substitute service on 9 February 16, 2023. ECF Nos. 4 & 6; see Fed. R. Civ. 4(e)(1), (h); Cal. Civ. P. § 415.20(a). After 10 defendants failed to timely respond to the complaint, plaintiff requested entry of their default. 11 ECF Nos. 8 & 13. Robinson’s default was entered February 28, 2023, ECF No. 9, and Robinson 12 Recycling’s was entered on August 2, 2023, ECF No. 14.1 Plaintiff now moves for default 13 judgment against both defendants. ECF No. 15. 14 Legal Standard 15 Under Federal Rule of Civil Procedure 55, default may be entered against a party who 16 fails to plead or otherwise defend against an action. See Fed. R. Civ. P. 55(a). However, “[a] 17 defendant’s default does not automatically entitle the plaintiff to a court-ordered judgment.” 18 PepsiCo, Inc. v. Cal. Sec. Cans, 238 F. Supp. 2d 1172, 1174 (C.D. Cal. 2002) (citing Draper v. 19 Coombs, 792 F.2d 915, 924-25 (9th Cir. 1986)). Rather, the decision to grant or deny a motion 20 for default judgment is discretionary. Aldabe v. Aldabe, 616 F.2d 1089, 1092 (9th Cir. 1980). In 21 exercising that discretion, the court considers the following factors: 22 (1) the possibility of prejudice to the plaintiff, (2) the merits of plaintiff’s substantive claim, (3) the sufficiency of the complaint, 23 (4) the sum of money at stake in the action, (5) the possibility of a dispute concerning the material facts, (6) whether the default was 24 due to excusable neglect, and (7) the strong policy underlying the Federal Rules of Civil Procedure favoring decisions on the merits. 25 26

27 1 Robinson Recycling’s default was initially entered on February 28, 2023. ECF No. 9. Since service on Robinson Recycling was not completed until February 16, 2023, that entry of 28 default was premature and was therefore set aside. 1 Eitel v. McCool, 782 F.2d 1470, 1471-72 (9th Cir. 1986). “In applying this discretionary 2 standard, default judgments are more often granted than denied.” Philip Morris USA, Inc. v. 3 Castworld Prods., Inc., 219 F.R.D. 494, 498 (C.D. Cal. 2003) (quoting PepsiCo, Inc. v. Triunfo- 4 Mex, Inc., 189 F.R.D. 431, 432 (C.D. Cal. 1999)). 5 Generally, once default is entered, “the factual allegations of the complaint, except those 6 relating to the amount of damages, will be taken as true.” TeleVideo Sys., Inc. v. Heidenthal, 826 7 F.2d 915, 917-18 (9th Cir. 1987) (quoting Geddes v. United Fin. Grp., 559 F.2d 557, 560 (9th 8 Cir. 1977)). However, “necessary facts not contained in the pleadings, and claims which are 9 legally insufficient, are not established by default.” Cripps v. Life Ins. Co. of N. Am., 980 F.2d 10 1261, 1267 (9th Cir. 1992). 11 Discussion 12 A. Appropriateness of the Entry of Default Judgment Under the Eitel Factors 13 The merits of plaintiff’s substantive claims and the sufficiency of the complaint—factors 14 two and three—weigh in favor of granting default judgment. 15 To state a trademark infringement claim under the Lanham Act, a plaintiff must allege 16 “(1) that [the plaintiff] has a protectible ownership interest in the mark; and (2) that the 17 defendant’s use of the mark is likely to cause consumer confusion.”2 Rearden LLC v. Rearden 18 Commerce, Inc., 683 F.3d 1190, 1202 (9th Cir. 2012). “Registration of a mark is prima facie 19 evidence of the validity of the mark, the registrant’s ownership of the mark, and the registrant’s 20 exclusive right to use the mark in connection with the goods specified in the registration.” Pom 21 Wonderful LLC v. Hubbard, 775 F.3d 1118, 1124 (9th Cir. 2014). In assessing the likelihood of 22 consumer confusion, courts consider the following eight factors: “(1) strength of the protected 23 mark; (2) proximity and relatedness of the goods; (3) type of goods and the degree of consumer 24 2 Plaintiff’s two claims are addressed together since demonstrating trademark 25 infringement under the Lanham Act is sufficient to establish a claim for false designation and unfair competition under the Act. See, e.g., Sebastian Intern., Inc. v. Longs Drug Stores Corp., 26 53 F.3d 1073, 1074 (9th Cir. 1995); Grey v. Campbell Soup Co., 650 F. Supp. 1166, 1173 (C.D. 27 Cal. 1986) (“The tests for infringement of a federally registered mark under § 32(1), 15 U.S.C. § 1114(1), infringement of a common law trademark, unfair competition under § 43(a), 15 U.S.C. 28 § 1125(a), and common law unfair competition involving trademarks are the same.”). 1 care; (4) similarity of the protected mark and the allegedly infringing mark; (5) marketing channel 2 convergence; (6) evidence of actual consumer confusion; (7) defendant’s intent in selecting the 3 allegedly infringing mark; and (8) likelihood of product expansion.” Id. at 1125.

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Bluebook (online)
GS Holistic, LLC v. A Robinson Recycling Center LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gs-holistic-llc-v-a-robinson-recycling-center-llc-caed-2024.