Jay Wilfong v. Starstruck Entertainment and The Alexander Trust

District Court, M.D. Tennessee·Decided August 21, 2026·No. 3:23-cv-00044·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

JAY WILFONG, ) ) Plaintiff, ) ) v. ) Case No. 3:23-cv-00044 ) Judge Aleta A. Trauger STARSTRUCK ENTERTAINMENT ) AND THE ALEXANDER TRUST, ) ) Defendants. )

MEMORANDUM Before the court is the Motion for an Award of Attorneys’ Fees (“fee motion”) (Doc. No. 81) under the Lanham Act, filed by defendants Starstruck Entertainment and the Alexander Trust. For the reasons set forth herein, the motion will be granted in part, but the court will award attorney’s fees in an amount substantially less than that sought by the defendants. I. ATTORNEY’S FEES UNDER THE LANHAM ACT Federal Rule of Civil Procedure 54(d) governs the timing and procedure for seeking attorney fees in cases where such fees are permitted by a federal statute. The federal statute at issue here is the Lanham Act, which provides, succinctly, that “[t]he court in exceptional cases may award reasonable attorney fees to the prevailing party” in a trademark violation case. 15 U.S.C. § 1117(a). The Supreme Court and the Sixth Circuit have clarified how the term “exceptional” is to be construed. An “exceptional” case is “one that stands out from others with respect to the substantive strength of a party’s litigating position (considering both the governing law and the facts of the case) or the unreasonable manner in which the case was litigated.” Octane Fitness, LLC v. ICON Health & Fitness, Inc., 572 U.S. 545, 554 (2014) (construing an identical attorney’s fee provision in the Patent Act, 35 U.S.C. § 285). The Sixth Circuit has confirmed that this definition of “exceptional” also applies to attorney’s fee awards under the Lanham Act. Evoqua Water Techs., LLC v. M.W. Watermark, LLC, 940 F.3d 222, 235 (6th Cir. 2019); see also La Bamba Licensing, LLC v. La Bamba Authentic Mexican Cuisine, Inc., 75 F.4th 607, 614–15 (6th

Cir. 2023); Max Rack, Inc. v. Core Health & Fitness, LLC, 40 F.4th 454, 478 (6th Cir. 2022), reh’g denied, No. 20-3598, 2022 WL 3237492 (6th Cir. Aug. 10, 2022); Slep-Tone Ent. Corp. v. Karaoke Kandy Store, Inc., 782 F.3d 313, 318 (6th Cir. 2015). Octane Fitness suggests a number of factors district courts are to consider in determining whether to award fees. Octane, 572 U.S. at 554. As the Sixth Circuit has explained: The plaintiff might have an unusually strong (or unusually weak) case on the merits. Blatant trademark infringement might justify an award for the plaintiff, whereas a frivolous infringement claim might justify one for the defendant. Or the losing party might have litigated the case in an unreasonable manner—for example, by requesting costly discovery to coerce a settlement despite the weakness of its claims. Max Rack, 40 F.4th at 478 (internal citations omitted). “In the end,” a district court has discretion under the Act “to decide under the totality of the circumstances whether the case before it has the ‘rare’ qualities that distinguish it from a typical case.” Id. II. BACKGROUND Plaintiff Jay Wilfong purchased the farm known as Starstruck Farm in 2019. He registered the mark STARSTRUCK FARM with the U.S. Patent & Trademark Office in March 2020 for use in connection with “[p]roviding facilities for recreation activities.” (Doc. No. 30 at 2 (citing Doc. No. 23 ¶ 17; Doc. No. 19-2 at 2).) The defendants own the federal trademark registration for the use of the word mark STARSTRUCK in connection with the sale of “[p]re-recorded CDs and downloadable digital files featuring music” and have also used it in connection with other music- related services, such as recording and talent management. (Id. at 1–2; see also Doc. No. 19-13 at 27.) In April 2020, the defendants filed a Petition for Cancellation to the Trademark Trial and Appeal Board (“TTAB”), seeking to have Wilfong’s STARSTRUCK FARM registration cancelled. In November 2022, following full discovery and briefing by the parties and the denial of a motion for summary judgment by the defendants, the TTAB cancelled Wilfong’s registration.

Wilfong filed this case in January 2023, challenging the cancellation of his registration under 15 U.S.C. § 1071(b), which grants a party aggrieved by a TTAB ruling to obtain review in a federal district court. (Doc. No. 1.) This court, upon consideration of new evidence presented by Wilfong and applying a de novo review standard, denied the defendants’ Motion for Summary Judgment in April 2024. (See Doc. Nos. 30, 31.) The court specifically found that, although the defendants had identified sufficient evidence to permit a reasonable fact finder to conclude that cancellation was appropriately awarded, contested issues of fact as to the “commercial strength of the STARSTRUCK mark, the amount of overlap in the relevant services, and the sophistication and care of the relevant customers” precluded summary judgment on the “likelihood of confusion”

issue governing this case. (Doc. No. 30 at 16.) The matter was thereafter set for a bench trial later in 2024. Due to a scheduling conflict, the court continued the trial date to April 2025 and, meanwhile, ordered the parties to mediate. (See Doc. Nos. 35, 36, 39.) The parties mediated unsuccessfully in November 2024. (See Doc. No. 38.) After several resettings attributable to both the court and the parties, the court conducted a bench trial in this matter on January 15, 2026. The parties presented opening statements, and the plaintiff presented his case: both Wilfong and Mark Skota, General Manager of Starstruck Farm testified. (See Tr., Doc. No. 80.) Wilfong first testified that he owns the stone entry gates to Starstruck Farm (see id. at 25–26), even though the parties had entered into a pretrial stipulation of the fact that, prior to Wilfong’s purchase of the property, the defendants had conveyed a strip of the land along the eastern side of State Route 109 to the State of Tennessee as part of a proposed expansion of the highway, and this strip of land “includes stone gates which still bear the logo and name of Starstruck Farms” (Doc. No. 67 ¶ 13). In other words, Wilfong does not own the stone entry gates.

In addition, Wilfong testified that he has “tried consistently and diligently” to also use “Farm” when he uses the term “Starstruck” and trains his staff to use the full name and that, although he provides music at the Farm, he has no intention of operating as a recording studio or providing artist management services (Doc. No. 80 at 32, 37–38.) In his opinion, there was no risk that the public would confuse his facility, which primarily provides lodging, with the defendants, who engage in talent management and the promotion, advertising, branding, and guidance for established and new artists. (See id. at 40.) On cross-examination, he testified that, to the best of his knowledge, his company’s social media marketing posts always used the full name, “Starstruck Farm.” (Id. at 56.) He emphasized that he did not “want any confusion. And there hasn’t been any

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Jay Wilfong v. Starstruck Entertainment and The Alexander Trust, (M.D. Tenn. 2026).

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