Jacobsen Outdoor Group, LLC v. Rocky Mountain Hunting Calls & Supplies, LLC

District Court, D. Idaho·Decided July 24, 2025·No. 2:23-cv-00088·Unknown

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

JACOBSEN OUTDOOR GROUP, LLC, Case No. 2:23-cv-00088-AKB Plaintiff, MEMORANDUM DECISION v. AND ORDER

ROCKY MOUNTAIN HUNTING CALLS & SUPPLIES, LLC,

Defendant.

Pending before the Court is Defendant Rocky Mountain Hunting Calls & Supplies, LLC’s (RMHC) Motion for Reconsideration (Dkt. 49) of the Court’s Memorandum Decision and Order granting in part and denying in part the summary judgment motion of Jacobsen Outdoor Group, LLC (Jacobsen Outdoor) and denying RMHC’s summary judgment motion (Dkt. 47). Having reviewed the record and the parties’ submissions, the Court finds the facts and legal arguments are adequately presented and oral argument would not significantly aid its decision-making process, and it decides the motion on the parties’ briefing. Dist. Idaho Loc. Civ. R. 7.1(d)(1)(B); see also Fed. R. Civ. P. 78(b) (“By rule or order, the court may provide for submitting and determining motions on briefs, without oral hearings.”). For the reasons discussed below, the Court denies RMHC’s motion for reconsideration. Further, the Court orders the parties to show cause why this case should not be stayed pending resolution of their state court action addressing the parties’ contractual relationship.

MEMORANDUM DECISION AND ORDER - 1 I. BACKGROUND In March 2023, Jacobsen Outdoor filed a complaint against RMHC alleging federal and state law claims for trademark infringement and unfair competition and several other state law claims, including breach of contract, quasi-contract/unjust enrichment and tortious interference

with economic advantage (Dkt. 1 at ¶¶ 20-122, 140-56). In response, RMHC asserted several affirmative defenses (Dkt. 8 at 12). Following discovery, both parties moved for summary judgment (Dkts. 34, 35). Jacobsen Outdoor sought partial summary judgment to establish its ownership of the Elk101 trademark; RMHC’s liability on Jacobsen Outdoor’s federal and state claims for trademark infringement and unfair competition; and the failure of each of RMHC’s affirmative defenses (Dkt. 34). Meanwhile, RMHC purportedly moved for summary judgment on all of Jacobsen Outdoor’s claims (Dkt. 35). In its briefing, however, RMHC did not address Jacobsen Outdoor’s claims for breach of contract, quasi-contract/unjust enrichment, or tortious interference with economic advantage (id.). Rather, it only challenged Jacobsen Outdoor’s trademark infringement and unfair competition claims (id).

As a result, the Court’s consideration of RMHC’s summary judgment motion was limited to those claims. In support of summary judgment, RMHC submitted several filings that did not comply with local rules, including multiple statements of fact. Jacobsen Outdoor moved to strike certain portions of these improper statements (Dkt. 40). The Court denied Jacobsen Outdoor’s motions, however, explaining that, although RMHC failed to comply with rules and many of RMHC’s statements were redundant and onerous, RMHC’s overlength statements did not impact the merits of the Court’s decision and did not prejudice Jacobsen Outdoor (Dkt. 47).

MEMORANDUM DECISION AND ORDER - 2 After consideration of all the filings, the Court denied RMHC’s summary judgment motion and granted Jacobsen Outdoor partial summary judgment on its trademark infringement and unfair competition claims and on RMHC’s affirmative defenses, except for its permissive use defense (id.). The Court ruled, among other things, that Jacobsen Outdoor undisputedly has a protectible

ownership interest in the Elk101 trademark; RMHC’s use of that mark after Jacobsen Outdoor terminated the parties’ license agreement in December 2022 constitutes trademark infringement and unfair competition (id. at 15-16, 21); and “[o]nce Jacobsen Outdoor terminated the license agreement in December 2022, RMHC had no right to continue using the mark”1 (Dkt. 47 at 21). The issues remaining for trial following the Court’s summary judgment decision are Jacobsen Outdoor’s state law claims (other than its state trademark and unfair competition claims); Jacobsen Outdoor’s damages; and RMHC’s permissive use defense. RMHC timely moves for reconsideration of the Court’s summary judgment ruling under both Rules 59 and 60 of the Federal Rules of Civil Procedure (Dkt. 49).

1 Following the Court’s summary judgment ruling, Jacobsen Outdoor moved for permission to conduct discovery related to ongoing damages incurred after the discovery deadline (Dkt. 53 at 2). In opposition to this motion, the owner of RMHC, Dale Ames, submitted a declaration stating that “I reviewed the Court’s January 24, 2025 Memorandum Decision and Order. Upon my review, I did not see any ruling or finding prohibiting RMHC from selling products with the term Elk101 on them” (Dkt. 54-2 at ¶ 3). While it is true the Court’s decision did not expressly “prohibit” RMHC from continuing to sell products using the Elk101 trademark, the Court very clearly ruled that “once Jacobsen Outdoor terminated the license agreement, RMHC had no right to continue using the mark (Dkt. 47 at 21) (emphasis added). Accordingly, the Court’s decision undisputedly notified RMHC that its continued use of the mark to sell products was unlawful and that RMHC risked incurring further damages if it continued using the mark.

MEMORANDUM DECISION AND ORDER - 3 II. LEGAL STANDARD A party may move for reconsideration of summary judgment under either Rule 59(e) or Rule 60(b) of the Federal Rules of Civil Procedure. Clifford v. Rice, 189 F.3d 472, 1 (9th Cir. 1999) (unpublished) (citing Fuller v. M.G. Jewelry, 950 F.2d 1437, 1442 (9th Cir. 1991)). The

Ninth Circuit has explained that Rule 59(e) is used to request a court’s substantive change of mind; meanwhile, Rule 60(a) is used to request a court correct an error in execution requiring the judgment to be corrected to implement its intended purpose. Tattersalls, Ltd. v. DeHaven, 745 F.3d 1294, 1299 (9th Cir. 2014); see also Garamendi v. Henin, 683 F.3d 1069, 1079 (9th Cir. 2012) (“Rule 60(a) allows for clarification and explanation, consistent with the intent of the original judgment, even in the absence of ambiguity if necessary for enforcement.”). Here, RMHC seeks substantively different rulings, which are contrary to the Court’s summary judgment rulings; RMHC’s request is not merely for clarification or explanation. Accordingly, Rule 59(e) is the applicable rule. Under Rule 59(e), a district court may grant relief to, among other reasons: (1) “correct manifest errors of law or fact upon which the judgment rests”;

(2) “present newly discovered or previously unavailable evidence”; (3) “prevent manifest injustice”; or (4) “if the amendment is justified by an intervening change in controlling law.” Allstate Ins. Co. v. Herron, 634 F.3d 1101, 1111 (9th Cir. 2011); see also Smith v. Clark Cnty. Sch. Dist., 727 F.3d 950, 955 (9th Cir. 2013). “Manifest injustice” is defined as “an error in the trial court that is ‘direct, obvious, and observable.’” Ctr. for Biological Diversity v. Little, No. 1:21- CV-00479-CWD, 2025 WL 733014, at *2 (D. Idaho Feb. 4, 2025) (quoting BLACK’S LAW DICTIONARY, 11th Ed., 2019).

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