Helix Environmental Planning, Inc. v. Helix Environmental and Strategic Solutions

CourtDistrict Court, S.D. California
DecidedMay 20, 2020
Docket3:18-cv-02000
StatusUnknown

This text of Helix Environmental Planning, Inc. v. Helix Environmental and Strategic Solutions (Helix Environmental Planning, Inc. v. Helix Environmental and Strategic Solutions) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Helix Environmental Planning, Inc. v. Helix Environmental and Strategic Solutions, (S.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 HELIX ENVIRONMENTAL Case No.: 3:18-cv-2000-AJB-AHG PLANNING, INC., a California 12 ORDER DENYING PLAINTIFF’S corporation, MOTION FOR PRELIMINARY 13 Plaintiff, INJUNCTION (Doc. No. 33) 14 v. 15 HELIX ENVIRONMENTAL AND STRATEGIC SOLUTIONS, a California 16 corporation; IVAN DEAN MYERS, and 17 DOES 1-10, Defendants. 18 19 Currently pending before the Court is Plaintiff Helix Environmental Planning, Inc.’s 20 (“Plaintiff”) motion for preliminary injunction. (Doc. No. 33.) Defendants Helix 21 Environmental and Strategic Solutions and Ivan Dean Myers (“Defendants”) opposed, and 22 Plaintiff replied. (Doc. Nos. 37–38.) For the reasons set forth below, the Court DENIES 23 Plaintiff’s motion for preliminary injunction. 24 I. BACKGROUND 25 Plaintiff brings this action against Defendants for trademark infringement, 26 cybersquatting, unfair competition, and violation of California common law. (Doc. No. 33- 27 1 at 7.) Based in San Diego, California, Plaintiff is a company that specializes in providing 28 environmental consulting services to private and public clients. (First Amended Complaint 1 (“FAC”) ¶ 9.) The business primarily focuses on advising companies and individuals on 2 issues of environmental impact, conservation, preservation and protection, and other 3 environmental services. (Id. ¶ 10.) 4 On October 7, 1991, Plaintiff allegedly began using the service mark “Helix 5 Environmental Planning, Inc.” in connection with its services. (Id.) On January 11, 1999, 6 Plaintiff registered the website domain name, www.helixepi.com. (Id. ¶ 11.) From as early 7 as 2002, Plaintiff asserts it began using “Helix Environmental” as an abbreviated service 8 mark. (Id. ¶ 12.) On June 19, 2018, Plaintiff received a federal registration for “Helix 9 Environmental Planning, Inc.” (Id. ¶ 24.) Plaintiff’s trademark is registered on the Principal 10 Register. (Doc. No. 33-1 at 24.) 11 Defendant Helix Environmental and Strategic Solutions, on the other hand, was 12 founded in 2016 in Los Angeles, California. (FAC ¶ 28.) Defendant is a small business 13 operating as an industrial hygiene company. (Doc. No. 37 at 18.) Defendant evaluates 14 indoor air quality and performs environmental surveys for lead, asbestos, mold, hazardous 15 materials, and worksite chemicals exposure. (Id.) Defendants’ domain name is purportedly 16 www.helixenvironmental.com, although the website has since been deactivated. (Doc. No. 17 33-1 at 20.) 18 II. PROCEDURAL HISTORY 19 On August 27, 2018, Plaintiff filed its initial complaint in this Court alleging 20 Defendants were infringing on Plaintiff’s service mark. (Doc. No. 1.) The First Amended 21 Complaint was filed on July 30, 2019. (Doc. No. 24.) Plaintiff then filed its motion for 22 preliminary injunction on October 15, 2019. (Doc. No. 33.) Defendants opposed the motion 23 for preliminary injunction, and Plaintiff replied. (Doc. Nos. 37–38.) The Court heard 24 Plaintiff’s motion for preliminary injunction on January 23, 2020. This order follows. 25 III. LEGAL STANDARD 26 A party seeking a preliminary injunction must fulfill one of two standards, described 27 by the Ninth Circuit as the “traditional” and “alternative” standards. See Cassim v. Bowen, 28 824 F.2d 791, 795 (9th Cir. 1987). Under the traditional standard, a court may issue 1 preliminary relief if it finds: (1) the moving party will probably prevail on the merits; (2) 2 the moving party will suffer irreparable injury if the relief is denied; (3) the balance of the 3 hardships favor the moving party; and (4) the public interest favors granting relief. Id. 4 Under the alternative standard, the moving party may meet its burden by 5 demonstrating either: (1) a combination of probable success on the merits and the 6 possibility of irreparable injury; or (2) that serious questions exist and the balance of 7 hardships tips sharply in its favor. See id. This latter formulation represents two points on 8 a sliding scale in which the required degree of irreparable harm increases as the probability 9 of success decreases. See Oakland Tribune, Inc. v. Chronicle Publishing Co., 762 F.2d 10 1374, 1376 (9th Cir. 1985). 11 A preliminary injunction can be either prohibitory, which means it “preserves the 12 status quo pending a determination of the action on the merits,” or mandatory, which means 13 it “orders a responsible party to take action.” Marlyn Nutraceuticals, Inc. v. Mucos Pharma 14 GmbH & Co., 571 F.3d 873, 878–79 (9th Cir. 2009) (internal quotations omitted). “A 15 mandatory injunction goes well beyond simply maintaining the status quo and is 16 particularly disfavored. In general, mandatory injunctions are not granted unless extreme 17 or very serious damage will result and are not issued in doubtful cases or where the injury 18 complained of is capable of compensation in damages.” Id. at 879 (internal quotations and 19 citations omitted). 20 IV. DISCUSSION 21 Plaintiff seeks preliminary injunctive relief against Defendants to preclude 22 Defendants from using “Helix Environmental” in its trademark. Plaintiff contends 23 Defendants’ mark is confusingly similar to Plaintiff’s registered trademark of “Helix 24 Environmental Planning, Inc.” (Doc. No. 33-1 at 6.) The Court will proceed to review each 25 element required for a preliminary injunction to issue. 26 A. Likelihood of Success on the Merits 27 In order to demonstrate that Plaintiff is entitled to a preliminary injunction, Plaintiff 28 must show a probable likelihood of succeeding on the merits on its claims. As such, the 1 Court will analyze in turn the likelihood of success of its trademark infringement, 2 cybersquatting, and California unfair competition claims. 3 1. Likelihood of Success of Plaintiff’s Federal and Common Law 4 Trademark Infringement Claims 5 Under both the Lanham Act and California law, trademark infringement occurs 6 when two elements are satisfied: (1) the defendant engages in the commercial use of 7 another’s registered trademark without the plaintiff’s consent; and (2) the defendant’s use 8 of the plaintiff’s registered mark is likely to cause consumer confusion. See 15 U.S.C. 9 § 1114(1)(a), (c) (“Any person who shall, without the consent of the registrant, use in 10 commerce any reproduction . . . of a registered mark . . . which is likely to cause consumer 11 confusion . . . shall be liable.”); see also Rearden LLC v. Rearden Commerce, Inc., 683 12 F.3d 1190, 1221 (9th Cir. 2012) (holding that a trademark infringement claim under 13 California law is subject to the same standard as a trademark infringement claim under the 14 Lanham Act). 15 a) First Prong: Validity of Plaintiff’s Trademark 16 As relevant to the first prong for the trademark infringement analysis, the parties 17 disagree as to the validity of Plaintiff’s mark. Plaintiff asserts its trademark is valid because 18 it is registered on the Principal Register. However, Defendants argue Plaintiff does not own 19 the “Helix Environmental” mark it asserts. (Doc. No. 37 at 10.) Defendants provide three 20 bases for this assertion. First, Defendants contend Plaintiff failed to put forth evidence 21 showing Plaintiff’s use of its mark in commerce. Second, Defendants maintain that 22 Plaintiff’s mark is subject to invalidation because it is a combination of the “descriptively 23 geographic” term “Helix” and the disclaimed descriptive term “environmental planning.” 24 (Id. at 11.) And third, Defendants point out that although Plaintiff owns registration for 25 “Helix Environmental Planning, Inc.,” it does not own the rights to the abbreviated mark 26 “Helix Environmental.” (Id.) The Court addresses each argument below.

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Bluebook (online)
Helix Environmental Planning, Inc. v. Helix Environmental and Strategic Solutions, Counsel Stack Legal Research, https://law.counselstack.com/opinion/helix-environmental-planning-inc-v-helix-environmental-and-strategic-casd-2020.