Happy CP Company Limited v. LB Accessories LLC

CourtDistrict Court, E.D. California
DecidedMay 19, 2025
Docket2:24-cv-02274
StatusUnknown

This text of Happy CP Company Limited v. LB Accessories LLC (Happy CP Company Limited v. LB Accessories 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
Happy CP Company Limited v. LB Accessories LLC, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 HAPPY CP COMPANY LIMITED, Case No. 2:24-cv-2274-TLN-JDP 12 Petitioner, 13 v. FINDINGS AND RECOMMENDATIONS 14 LB ACCESSORIES LLC, et al., 15 Respondents. 16 17 Petitioner Happy CP Company Limited (“Happy CP”) filed this action seeking to confirm 18 a foreign arbitration award that it obtained against respondents LB Accessories LLC and Megan 19 Castillo. Respondents have not appeared, and petitioner now moves for default judgment. ECF 20 No. 14. I recommend that the motion be granted. 21 Background 22 In September 2022, petitioner, a Hong Kong company, entered into a contract with LB 23 Accessories LLC under which petitioner agreed to purchase a portion of LB Accessories’ future 24 receivables in exchange for a percentage of its monthly deposits, with payments secured by 25 irrevocable letters of instructions to banks and payment processors. ECF No. 1 at 3. Castillo 26 guaranteed LB Accessories’ performance under the contract, including payment of any 27 outstanding amounts, and agreed to indemnify petitioner against liabilities arising from the 28 contract. Id. 1 Petitioner alleges that LB Accessories defaulted on its obligations, including by failing to 2 provide the necessary authorizations to banks and processors, leading to petitioner’s termination 3 of the parties’ contract. Id. at 3-4. In July 2023, petitioner initiated arbitration, which was 4 administered by the Hong Kong International Arbitration Centre, to recover the balance of the 5 purchased amount and late fees. Id. at 4. On April 3, 2024, an arbitrator found that petitioner 6 lawfully terminated the contract and that respondents were liable for the purchase amount and late 7 fees—totaling $150,384.64—plus petitioner’s tribunal fees, legal expenses, and administrative 8 costs.1 Id. 9 Petitioner subsequently filed this action to confirm the arbitration award. After several 10 unsuccessful attempts to personally serve respondents, petitioner moved to complete service 11 pursuant to California Code of Civil Procedure section 415.30. ECF No. 6. The court granted 12 that motion and ordered service to be completed by affixing a copy of the complaint of summons 13 at respondents’ address and by delivering the same via both mail and email. ECF No. 8. In early 14 2025, petitioner notified the court that it had completed service on December 30, 2024. ECF No. 15 10. After respondents failed to appear or to respond to the petition to confirm the arbitration 16 award, petitioner requested entry of their default, ECF No. 12, which the Clerk of Court entered 17 on February 3, 2025, ECF No. 13. The instant motion followed. ECF No. 14. 18 Legal Standard 19 Under Federal Rule of Civil Procedure 55, default may be entered against a party who 20 fails to plead or otherwise defend against an action. See Fed. R. Civ. P. 55(a). However, “[a] 21 defendant’s default does not automatically entitle the plaintiff to a court-ordered judgment.” 22 PepsiCo, Inc. v. Cal. Sec. Cans, 238 F. Supp. 2d 1172, 1174 (C.D. Cal. 2002) (citing Draper v. 23 Coombs, 792 F.2d 915, 924-25 (9th Cir. 1986)). Rather, the decision to grant or deny a motion 24 for default judgment is discretionary. Aldabe v. Aldabe, 616 F.2d 1089, 1092 (9th Cir. 1980). In 25 exercising that discretion, the court considers the following factors: 26 27

28 1 Respondents did not participate in arbitration. 1 (1) the possibility of prejudice to the plaintiff, (2) the merits of plaintiff’s substantive claim, (3) the sufficiency of the complaint, 2 (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 3 due to excusable neglect, and (7) the strong policy underlying the Federal Rules of Civil Procedure favoring decisions on the merits. 4 5 Eitel v. McCool, 782 F.2d 1470, 1471-72 (9th Cir. 1986). “In applying this discretionary 6 standard, default judgments are more often granted than denied.” Philip Morris USA, Inc. v. 7 Castworld Prods., Inc., 219 F.R.D. 494, 498 (C.D. Cal. 2003) (quoting PepsiCo, Inc. v. Triunfo- 8 Mex, Inc., 189 F.R.D. 431, 432 (C.D. Cal. 1999)). 9 Generally, once default is entered “the factual allegations of the complaint, except those 10 relating to the amount of damages, will be taken as true.” TeleVideo Sys., Inc. v. Heidenthal, 826 11 F.2d 915, 917-18 (9th Cir. 1987) (quoting Geddes v. United Fin. Grp., 559 F.2d 557, 560 (9th 12 Cir. 1977)). However, “necessary facts not contained in the pleadings, and claims which are 13 legally insufficient, are not established by default.” Cripps v. Life Ins. Co. of N. Am., 980 F.2d 14 1261, 1267 (9th Cir. 1992). 15 Discussion 16 I. Appropriateness of the Entry of Default Judgment Under the Eitel Factors 17 The first two Eitel factors weigh in favor granting the petition to confirm arbitration and 18 entry of default judgment. 19 “Congress enacted Chapter Two of the Federal Arbitration Act (“FAA”), see 9 U.S.C. 20 §§ 201-208, to provide for the effective and efficient resolution of international arbitral disputes 21 after the United States entered into the United Nations Convention on the Recognition and 22 Enforcement of Foreign Arbitral Awards (New York, June 1958) (‘the New York Convention’ or 23 ‘Convention’).” Day v. Orrick, Herrington & Sutcliffe, LLP, 42 F.4th 1131, 1133 (9th Cir. 2022). 24 “[A] party to a foreign arbitration may apply to federal district court ‘for an order confirming the 25 award as against any other party to the arbitration.’” Ministry of Def. of the Islamic Republic of 26 Iran v. Gould, Inc., 969 F.2d 764, 770 (9th Cir. 1992) (quoting 9 U.S.C. § 207). In considering a 27 petition to confirm an award, the “district court has little discretion: ‘The court shall confirm the 28 award unless it finds one of the grounds for refusal or deferral of recognition or enforcement of 1 the award specified in the Convention.’” Id. (emphasis in original). 2 An arbitration award falls under the New York Convention if it arises “out of a legal 3 relationship, whether contractual or not, which is considered as commercial” unless that 4 relationship is “entirely between United States citizens.” 9 U.S.C. § 202. The burden of 5 demonstrating the existence of a New York Convention lies with the party seeking to avoid 6 enforcement of the award. Polimaster Ltd. V. RAE Systems, Inc., 623 F.3d 832, 836 (9th Cir. 7 2010). 8 Petitioner alleged that the arbitration award arises out of contracts between it, a Hong 9 Kong limited liability company, and LB Accessories, a California company, and Castillo, a 10 United States citizen. Accordingly, the award falls under the New York Convention. Since 11 respondents have not appeared, they have not met their substantial burden of showing that a 12 defense applies.

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Bluebook (online)
Happy CP Company Limited v. LB Accessories LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/happy-cp-company-limited-v-lb-accessories-llc-caed-2025.