Joe Hand Promotions Incorporated v. Taco Spot III LLC

CourtDistrict Court, D. Arizona
DecidedApril 10, 2025
Docket2:24-cv-00993
StatusUnknown

This text of Joe Hand Promotions Incorporated v. Taco Spot III LLC (Joe Hand Promotions Incorporated v. Taco Spot III LLC) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joe Hand Promotions Incorporated v. Taco Spot III LLC, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Joe Hand Promotions Incorporated, No. CV-24-00993-PHX-ROS

10 Plaintiff, ORDER

11 v.

12 Taco Spot III LLC, et al.,

13 Defendants. 14 15 Plaintiff filed a Motion for Default Judgment (Doc. 21) against Defendants Taco 16 Spot III LLC and Jorge Ruiz. No response to the Motion has been filed. For the reasons 17 set forth below, the Court will grant the Motion. 18 BACKGROUND 19 Because the Clerk entered default, the Court will take the Complaint’s factual 20 allegations as true. See Geddes v. United Fin. Grp., 559 F.2d 557, 560 (9th Cir. 1977) 21 (stating that upon default, a complaint’s allegations are taken as true, except those relating 22 to damages). 23 On May 1, 2024, Plaintiff filed this action alleging Defendants violated two 24 provisions of the Communications Act of 1934, 47 U.S.C. §§ 553 and 605. (Doc. 1 ¶ 1). 25 Defendants are the owners and operators of The Taco Spot, a commercial establishment in 26 Mesa, Arizona. (Id. ¶¶ 4-5). Plaintiff alleges it held the exclusive right to license the 27 exhibition of Canelo Álvarez vs. John Ryder on May 6, 2023 (the “Program”). (Id. ¶ 3). 28 Plaintiff alleges Defendants broadcasted the Program to its patrons without authorization 1 and without paying the sublicense fee to Plaintiff. (Id. ¶ 10). Plaintiff further alleges it 2 hired an auditor, Sarah Jennings, to investigate whether The Taco Spot was publicly 3 exhibiting the Program without proper authorization. (Doc. 21-1 at 4). On May 6, 2023, 4 Ms. Jennings went to The Taco Spot and observed that the Program was broadcasted on 5 two televisions to approximately 15 patrons. (Id. at 4-5). 6 Plaintiff asserts Defendants publicly displayed the Program at The Taco Spot 7 without authorization by means of unlawfully intercepting or receiving a satellite or cable 8 signal. Plaintiff served Defendant Taco Spot III LLC on August 22, 2024 (Doc. 12) and 9 Defendant Jorge Ruiz on October 19, 2024 (Doc. 17). Defendants failed to appear in the 10 action, and Plaintiff filed an Application for Entry of Default on November 26, 2024 11 (Doc. 18). The Clerk filed the Entry of Default on November 27, 2024, and the Plaintiff 12 filed its present Motion for Default Judgment pursuant to Fed. Riv. Civ. P. 55(b)(2) on 13 February 4, 2025. 14 JURISDICTION 15 When a party seeks default judgment “against a party who has failed to plead or 16 otherwise defend, a district court has an affirmative duty to look into its jurisdiction over 17 both the subject matter and the parties.” In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999). 18 Because Plaintiff’s Complaint invokes a federal cause of action under the Communications 19 Act of 1934, the Court has subject matter jurisdiction over the action. See 28 U.S.C. § 20 1331. The Court also has personal jurisdiction over Defendants. Plaintiff’s claims arise 21 from Defendants’ activities in Arizona and their alleged failure to comply with federal 22 communications laws during those activities. (See Doc. 1 at ¶¶ 1-2). 23 DEFAULT JUDGMENT 24 Once default is entered, the Court may enter default judgment under Rule 55(b). 25 Deciding to grant default judgment is discretionary and the Court must consider: (1) the 26 possibility of prejudice to the plaintiff; (2) the merits of plaintiff’s substantive claim; (3) 27 the sufficiency of the complaint; (4) the amount in controversy; (5) the possibility of factual 28 dispute; (6) whether the default was due to excusable neglect; and (7) the strong preference 1 to decide cases on the merits. Eitel v. McCool, 782 F.2d 1470, 1472 (9th Cir. 1986). 2 I. Factor (1): Prejudice to Plaintiff 3 Because Defendants have failed to litigate this action, Plaintiff will be left with no 4 alternative recourse and would thus suffer prejudice without default judgment. This factor 5 thus weighs in favor of default judgment. See Zekelman Indus. Inc. v. Marker, 2020 WL 6 1495210, *3 (D. Ariz. Mar. 27, 2020). 7 II. Factors (2) and (3): Merits of the Claim and Sufficiency of the Complaint 8 The second and third Eitel factors, taken together, require courts to consider whether 9 a plaintiff has stated a claim on which relief may be granted. See PepsiCo, Inc. v. Cal. Sec. 10 Cans, 238 F. Supp. 2d 1172, 1175 (C.D. Cal. 2002); Danning v. Lavine, 572 F.2d 1386, 11 1388–89 (9th Cir. 1978). Here, the Complaint’s factual allegations are taken as true, but 12 the plaintiff must establish all damages sought. Geddes v. United Fin. Group, 559 F.2d 13 557, 560 (9th Cir. 1977). 14 Plaintiff pled alternative liability claims under both 47 U.S.C. § 605 and 47 U.S.C. 15 § 553, but only seeks relief under § 605. (Docs. 1 at 7; 21-1 at 6). “Both sections prohibit 16 the unauthorized interception and reception of transmissions, but § 553 applies to cable 17 television transmissions and § 605 applies to interstate radio communications, including 18 satellite television signals.” Joe Hand Promotions Inc. v. Sand B. Enterprises LLC, 2024 19 WL 4769777, at *3 (D. Ariz. Nov. 13, 2024). “A plaintiff may recover under only one 20 statute for a single act of interception.” Id. (citing G & G Closed Cir. Events, LLC v. 21 Macias, 2021 WL 2037955, at *3 (N.D. Cal. May 21, 2021)). Because Plaintiff only seeks 22 damages under § 605, the Court will analyze the merits of Plaintiff’s § 605 claim. 23 Section 605(a) “prohibits commercial establishments from intercepting and 24 broadcasting to its patrons satellite cable programming.” Kingvision Pay–Per–View v. 25 Guzman, 2009 WL 1475722, at *2 (N.D. Cal. May 27, 2009). “To be held liable for a 26 violation of § 605, Plaintiff must plead Defendants were (1) not authorized by the sender, 27 (2) intercepted a radio communication, and (3) divulged or published the protected 28 communication to any person.” G & G Closed Cir. Events, LLC v. Ayala, 2023 WL 1 4269637, at *3 (D. Ariz. June 29, 2023) (citing 47 U.S.C. § 605(a); Nat’l Subscription 2 Television v. S & H TV, 644 F.2d 820, 826 (9th Cir. 1981)). 3 Plaintiff alleges it possessed exclusive rights to distribute and authorize the public 4 display of the Program. (Doc. 1 ¶ 8). The Program was nationally televised on May 6, 5 2023, and Plaintiff alleges it did not authorize Defendants to broadcast the Program to its 6 patrons. (Id. ¶¶ 3, 16). Plaintiff alleges “Defendants’ unauthorized exhibition of the 7 Program was accomplished through the interception and/or receipt of a satellite signal” or 8 through a cable signal. (Id. ¶ 20). Plaintiff also alleges “Defendants willfully engaged in 9 wrongful acts to intercept and/or receive the Program for free or at a nominal cost or 10 assisted in such actions, while Plaintiff’s legitimate customers paid substantially more for 11 the proper commercial sublicense.” (Id. ¶ 13). The interception and publication of the 12 Program was “for purposes of commercial advantage or private financial gain.” (Id. ¶ 20).

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Joe Hand Promotions Incorporated v. Taco Spot III LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joe-hand-promotions-incorporated-v-taco-spot-iii-llc-azd-2025.