Joe Hand Promotions, Inc. v. BH Lounge of DFW LLC

CourtDistrict Court, N.D. Texas
DecidedJanuary 14, 2025
Docket4:24-cv-00409
StatusUnknown

This text of Joe Hand Promotions, Inc. v. BH Lounge of DFW LLC (Joe Hand Promotions, Inc. v. BH Lounge of DFW LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joe Hand Promotions, Inc. v. BH Lounge of DFW LLC, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

JOE HAND PROMOTIONS, INC., § § Plaintiff, § § v. § Civil Action No. 4:24-cv-00409-O § BH LOUNGE OF DFW, LLC, et al., § § Defendants. §

FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Before the Court are the Motion for Default Judgment and Appendix in Support filed by Joe Hand Promotions, Inc. (“JHP”) on December 18, 2024. ECF Nos. 29, 30. United States District Judge Reed O’Connor referred the Motion to the undersigned on December 19, 2024. ECF No. 31. Having considered the Motion and applicable legal authorities, the undersigned RECOMMENDS that Judge O’Connor GRANT the Motion (ECF No. 29) and ENTER DEFAULT JUDGMENT against Defendant BH Lounge of DFW LLC d/b/a Tu-Chi Creative Kitchen (“BH Lounge”) and Tracy L. Trice (“Trice”) (collectively, “Defendants”) as explained below. I. BACKGROUND

JHP owns the licenses to display certain sporting events in commercial settings, including bars. ECF No. 1 at 4. In its business as a license-holder, JHP typically sells sublicensing rights to commercial establishments, allowing the establishments to display the programs to their patrons in exchange for a fee. Id. JHP held the exclusive commercial license to distribute and authorize the display of the June 26, 2021 boxing match between Gervonta Davis and. Mario Barrios (“the fight”). Id. at 2. JHP discovered that Defendants and Defendant Darrell G. Alexander (“Alexander”) displayed the boxing program without JHP's authorization through “interception and/or receipt of a signal transmitted over the air or, in the alternative, transmitted via cable.” Id. at 7. On May 8, 2024, JHP sued Defendants and Alexander to recover statutory damages, attorney’s fees, post-judgment interest, and costs of litigation under the Communications Act of

1934 (“FCA”), 47 U.S.C. §§ 553, 605. JHP alleged that Defendants and Alexander violated FCA sections 605 (unauthorized publication or use of communications) and 553 (unauthorized reception of cable service). ECF No. 1 at 7; 47 U.S.C. §§ 553, 605. On August 6, 2024, JHP properly served both Alexander and BH Lounge by private process server Denise I. Biggs securely affixing the requisite documents to the front entry way of a property previously authorized by Judge O’Connor. ECF Nos. 13, 14, 11. On September 10, 2024, JHP properly served Trice by private process server Victoria Steward securely affixing the requisite documents to the front entry way of a property previously authorized by the undersigned. ECF No. 19, 18. Alexander answered JHP’s Complaint (ECF No. 27) and is not included in the

definition of “Defendants” below. BH Lounge and Trice did not appear or otherwise respond to JHP's complaint. JHP moved for, and the clerk entered, default against them. ECF No. 26. Then, pursuant to Judge O’Connor’s order (ECF No. 20), JHP moved for default judgment. ECF No. 29. It now asks this Court to award it statutory damages under 47 U.S.C. § 605, along with attorneys’ fees, costs, and post-judgment interest. ECF No. 29 at 21-22; see ECF No. 29 at 1 n.1 (explaining that JHP moves for default judgment “solely under [section] 605”). II. LEGAL STANDARD Federal Rule of Civil Procedure 55 governs the entry of default and default judgment. There are three stages to entry of default judgment. First, a default occurs “when a defendant has failed to plead or otherwise respond to the complaint within the time required by the Federal Rules.” N.Y. Life Ins. Co. v. Brown, 84 F.3d 137, 141 (5th Cir. 1996); see also Fed. R. Civ. P. 55(a) (noting default occurs where the defendant “has failed to plead or otherwise defend” against the complaint). Second, the Clerk may enter a defendant’s default if it is “established by affidavit or otherwise.” Brown, 84 F.3d at 141 (citing Fed. R. Civ. P. 55(a)). Third, if the Clerk enters default,

the plaintiff must apply for a default judgment from the Court. Fed. R. Civ. P. 55(b)(2). The Court may not enter default judgment against an individual in military service until an attorney is appointed to represent the defendant. 50 U.S.C. § 3931. “[A] party is not entitled to a default judgment as a matter of right, even where the defendant is technically in default.” Lewis v. Lynn, 236 F.3d 766, 767 (5th Cir. 2001). Rather, courts retain ultimate discretion to grant or deny default judgments. Lindsey v. Prive Corp., 161 F.3d 886, 893 (5th Cir. 1998). The Fifth Circuit has “adopted a policy in favor of resolving cases on their merits and against the use of default judgments,” although this policy is “counterbalanced by considerations of social goals, justice and expediency, a weighing process . . . within the domain

of the trial judge’s discretion.” In re Chinese-Manufactured Drywall Prods. Liab. Litig., 742 F.3d 576, 594 (5th Cir. 2014) (quoting Rogers v. Hartford Life & Accident Ins. Co., 167 F.3d 933, 936 (5th Cir. 1999)). Default judgment remains “a drastic remedy, not favored by the Federal Rules.” Sun Bank of Ocala v. Pelican Homestead & Sav. Ass’n, 874 F.2d 274, 276 (5th Cir. 1989); see also U.S. for Use of M-Co Constr., Inc. v. Shipco General, Inc., 814 F.2d 1011, 1014 (5th Cir. 1987) (calling default judgments “draconian”). Courts use a three-pronged analysis to determine if default judgment is appropriate. J & J Sports Prods., Inc. v. Morelia Mex. Rest., Inc., 126 F. Supp. 3d 809, 813 (N.D. Tex. 2015). First, courts ask if default judgment is procedurally warranted. See Lindsey, 161 F.3d at 893. The Lindsey factors inform this inquiry. Under Lindsey, the Court may consider whether: (1) material issues of fact exist; (2) there has been substantial prejudice; (3) the grounds for default are clearly established; (4) the default was caused by a good faith mistake or excusable neglect; (5) default judgment would be too harsh; and (6) the court would be obliged to set aside the default upon motion from the defendant. Id.

Second, if default is procedurally warranted under Lindsey, courts analyze the substantive merits of the plaintiff’s claims and ask if the pleadings establish a sufficient basis for default judgment. Nishimatsu Constr. Co. v. Hous. Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975).

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Joe Hand Promotions, Inc. v. BH Lounge of DFW LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joe-hand-promotions-inc-v-bh-lounge-of-dfw-llc-txnd-2025.