Hammer Brand, LLC v. Voro Inc.

CourtDistrict Court, M.D. Florida
DecidedFebruary 24, 2025
Docket8:23-cv-01272
StatusUnknown

This text of Hammer Brand, LLC v. Voro Inc. (Hammer Brand, LLC v. Voro Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hammer Brand, LLC v. Voro Inc., (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

HAMMER BRAND, LLC, d/b/a WOLF BRAND SCOOTERS, Plaintiff, v. Case No. 8:23-cv-1272-KKM-NHA VORO, INC., et al., Defendants. ___________________________________

ORDER Defendants Ningbo Kaabo Technology Co., Ltd., Voro, Inc., and Leitmotif Services, LLC d/b/a Fluidfreeride LLC1 move for a stay pending appeal of a permanent injunction

and an order cancelling Kaabo’s “Wolf Warrior” mark’s registration. Mot. to Stay (MTS) (Doc. 229). For the reasons below, that motion is denied. I. BACKGROUND

e heart of this trademark case is a dispute between Hammer Brand, LLC, and Kaabo over the use of the word “Wolf” in connection with the sale of scooters. Hammer

1 e defendants explain that Fluidfreeride, which is bankrupt, joins this motion “[o]ut of an abundance of caution” but believes that “the limited relief from the bankruptcy stay does not include enforcement of the injunction” as to it. Mot. to Stay (MTS) (Doc. 229) at 5 n.1 (citing (Doc. 209-1)). Because no party seeks enforcement of the injunction as to Fluidfreeride, I have no cause to decide whether the automatic stay, 11 U.S.C. § 362(a), would prohibit that relief. has sold gas-powered, Vespa-like scooters under the brand “Wolf” since 2013. (Doc.

174-1) ¶ 10; (Doc. 176-4) at 11; (Doc. 176-5) at 11. In early 2016, Hammer registered the “Wolf” mark in connection with the sale of motor scooters. (Doc. 173-1) at 1–2. Kaabo, a Chinese scooter company, entered the American market in 2022 and, until recently, sold

electric scooters under the brands “Wolf Warrior” and “Wolf King.” (Doc. 173) ¶¶ 12, 14; (Doc. 173-2) at 1. After learning in early 2023 that someone was selling electric scooters using the

word “Wolf,” (Doc. 174-5) ¶¶ 5–6, Hammer investigated and eventually sued Voro, which distributed the scooters, Compl. (Doc. 1); Am. Compl. (Doc. 9). Hammer learned through this action that Kaabo was the source of the infringing scooters, and Hammer amended its

complaint to target Kaabo. ird Am. Compl. (Doc. 59). After discovery, the parties cross- moved for summary judgment. (Docs. 174, 175, 182, 184.) As relevant here, I granted summary judgment in favor of Hammer on its

infringement claim and entered a permanent injunction prohibiting Kaabo, Voro, and Fluidfreeride from selling electric scooters using the word “Wolf.”2 Summ. J. Order (Doc.

2 e Summary Judgment Order also denies Hammer’s motion in part, grants Voro’s motion in part and denies it in part, and denies Kaabo’s and Fluidfreeride’s motions. Summary Judgment Order at 40–42. Only the portion of the order granting Hammer’s motion in part is relevant here. 2 214) at 40–42. I also cancelled Kaabo’s registration of the “Wolf Warrior” mark. at 42;

15 U.S.C. 1119.3 Kaabo, Voro, and Fluidfreeride appealed the injunction. Notice of Appeal (Doc. 216); 28 U.S.C. § 1292(a)(1). ey now move for a stay of the injunction and the

cancellation of the “Wolf Warrior” mark pending resolution of that appeal. MTS. Hammer opposes their motion. Resp. (Doc. 232). II. LEGAL STANDARD

When a party appeals an order granting an injunction, a district court may stay that injunction “for bond or other terms that secure the opposing party’s rights.” FED. R. CIV. P. 62(d). “A party must ordinarily move first in the district court” before seeking a stay from

a court of appeals. FED. R. APP. P. 8(a)(1)(C). A stay of an injunction pending appeal is “a disfavored and extraordinary remedy.” , 805 F. Supp. 2d 1321, 1327 (M.D. Fla. 2011).

In exercising its discretion to stay a permanent injunction, a district court must consider “(1) whether the stay applicant has made a strong showing that he is likely to succeed on the merits; (2) whether the applicant will be irreparably injured absent a stay;

(3) whether issuance of the stay will substantially injure the other parties interested in the

3 Hammer has twice moved for an order directing the defendants to show cause why they are not in contempt of the injunction, (Docs. 217, 226), which I have twice denied, (Docs. 223, 231). 3 proceeding; and (4) where the public interest lies.” , 556 U.S. 418, 434 (2009)

(quoting , 481 U.S. 770, 776 (1987)); , 888 F.3d 1206, 1207 (11th Cir. 2018). “e first two factors of the traditional standard are the most critical.” , 556 U.S. at 434. “It is not enough that the chance of success on the merits

be better than negligible. By the same token, simply showing some possibility of irreparable injury fails to satisfy the second factor.” , 957 F.3d 1171, 1177 (11th Cir. 2020) (cleaned up) (quoting , 556 U.S. at 434–35). III. ANALYSIS

e defendants fail to show that any of the traditional factors weigh in their favor. I therefore decline to exercise my discretion to grant them a stay as to the permanent

injunction. I also decline to stay the cancellation order because the defendants have not appealed it—their Notice of Appeal says that they seek only “reversal of the issuance of the permanent injunction.” Notice of Appeal at 1.

I address each of the traditional factors as they apply to the permanent injunction. A. e Defendants Have Not Made a Strong Showing at ey Are Likely to Succeed on the Merits Trying to make a strong showing that they are likely to succeed on the merits, the defendants largely repeat arguments that I already rejected in adjudicating the parties’ summary judgment papers. Summ. J. Order at 7–27, MTS at 8–24. I

therefore conclude that the defendants have not made a strong showing that they are likely 4 to succeed largely for the reasons that I already expressed. Summ. J. Order. Yet a couple

of their arguments bear addressing. e first is the defendants’ repeated assertion that Hammer needed to “present incontrovertible evidence to win” at summary judgment. MTS at 21 (emphasis in the

original). at statement misstates the standard, or at least obfuscates it. In the case that the defendants principally cite on this point, the Eleventh Circuit explained that “all material facts have been ‘incontrovertibly proved’ ” when “there are no

genuine issues of material fact.” , 57 F.4th 939, 959 (11th Cir.) (quoting , 572 F.2d 1119, 1123–24 (5th Cir. 1978)), , 144 S. Ct. 103 (2023). e defendants seem to suggest

“incontrovertibility” is something more than another way to phrase the ordinary summary judgment standard. For example, they say that the testimony of one of Hammer’s dealers as to the sophistication of scooter purchasers is not “incontrovertible evidence” of their lack

of sophistication. MTS at 23–24. Yet the question is not whether the evidence is “incontrovertible” in the abstract, but whether the record evidence permits multiple conclusions on the factual question of whether scooter purchasers are sophisticated.

, 477 U.S. 242, 251 (1986). On the question of consumer sophistication, only one conclusion was reasonable because all the record evidence pointed one way and the defendants presented no evidence as to credibility or legal arguments as

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Hammer Brand, LLC v. Voro Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hammer-brand-llc-v-voro-inc-flmd-2025.