KTM AG v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto

CourtDistrict Court, N.D. Illinois
DecidedMarch 31, 2025
Docket1:24-cv-03278
StatusUnknown

This text of KTM AG v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto (KTM AG v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
KTM AG v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

KTM AG,

Plaintiff,

v.

No. 24-cv-03278 THE INDIVIDUALS, CORPORATIONS,

LIMITED LIABILITY COMPANIES,

PARTNERSHIPS, AND Judge Franklin U. Valderrama UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A HERETO, Defendants.

ORDER Plaintiff KTM AG (KTM), a motorcycle and sports car manufacturer who owns several trademarks, sued several defendants, including Defendant Sirimotocycle (Sirimotocycle), alleging trademark infringement and counterfeiting under 15 U.S.C. § 1114, false designation of origin under 15 U.S.C. § 1125(a), and violations of the Illinois Uniform Deceptive Trade Practices Act, 815 ILCS § 510/1, et seq. R. 1, Compl.1 Sirimotocycle now moves to dismiss KTM’s complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. R. 47, Mot. Dismiss. For the reasons stated herein, the Court denies KTM’s motion to dismiss.

1Citations to the docket are indicated by “R.” followed by the docket number and, where necessary, a page or paragraph citation. Background2 KTM is a motorcycle and sports car manufacturer, who owns U.S. Trademark Registration Nos. 3,606,168; 3,547,084; 3,440,999; and 3,436,150 for its “KTM”

trademark (collectively, the KTM Trademarks). Compl. ¶ 8; R. 1-1, Exh. 1. Sirimotocycle operates an e-commerce storefront via multiple online marketplaces, including eBay.com (eBay), that sells aftermarket auto parts throughout the United States, including Illinois. Id. ¶ 14; Mot. Dismiss at 1. KTM sued Sirimotocycle for trademark infringement,3 claiming Sirimotocycle has “created numerous Internet Stores and design[ed] them to appear to be selling genuine [KTM products], which

includes using in commerce the “counterfeit imitations of [KTM’s] registered Trademarks.” Id. ¶ ¶ 4, 27. KTM has not authorized or licensed Sirimotocycle to utilize its KTM Trademarks. Id. ¶ 7. KTM further alleges that Sirimotocycle has “sold, offered to sell, marketed, distributed and advertised, and are still selling, offering to sell, marketing, distributing, and advertising products in connection with” KTM Trademarks without KTM’s permission. Id. ¶ 28. As a result of these alleged actions, KTM contends that Sirimotocycle’s use of the KTM Trademarks “is likely to

cause and has caused confusion . . . among consumers.” Id. ¶ 25. KTM filed and the Court granted a Motion for Entry of a Temporary Restraining Order (TRO). R. 27, 28. KTM subsequently filed, and the Court granted a Motion for Entry of a Preliminary Injunction. R. 39. Sirimotocycle now moves to

2The Court accepts as true all of the well-pleaded facts in the complaint and draws all reasonable inferences in favor of KTM. St. John v. Cach, LLC, 822 F.3d 388, 389 (7th Cir. 2016). dismiss KTM’s complaint pursuant to Federal Rule of Civil Procedure 12(b)(6). The fully briefed motion is before the Court. Legal Standard

A motion to dismiss under Fed. R. Civ. P. 12(b)(6) challenges the sufficiency of the complaint. Hallinan v. Fraternal Order of Police of Chi. Lodge No. 7, 570 F.3d 811, 820 (7th Cir. 2009). Under Rule 8(a)(2), a complaint must include only “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). To survive a motion to dismiss, a complaint need only contain factual allegations, accepted as true, sufficient to “state a claim to relief that is

plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. The allegations “must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. The allegations that are entitled to the assumption of truth are those that are factual, rather than mere legal conclusions. Iqbal, 556 U.S. at 678–79.

Discussion To state a clam for trademark infringement under the Lanham Act, a plaintiff must allege that (1) its mark is protectable; and (2) the defendant’s use of the trademark is likely to cause confusion among consumers. SportsFuel, Inc., v. PepsiCo, Inc., 932 F.3d 589, 595 (7th Cir. 2019). Sirimotocycle does not argue that KTM fails to plausibly allege it has a protectible mark or that it fails to sufficiently allege that Sirimotocycle’s use of the trademark is likely to cause confusion among consumers. Instead, Sirimotocycle argues that its use of the word “KTM” constitutes “fair use,” and as such, asserts that KTM fails to allege a claim under the Lanham Act or Illinois

law. Mot. Dismiss at 2–3. Alternatively, Sirimotocycle posits that its use constitutes “nominative fair use” of the KTM Trademarks. Id. at 7–9. The Lanham Act provides several affirmative defenses to a plaintiff's claims, including the "fair use" defense. See 15 U.S.C. § 1115(b). The “fair use” defense is an affirmative defense that “allows individuals to use otherwise trademarked language in a descriptive sense.” SportsFuel, Inc., 932 F.3d at 595. To prevail on this

affirmative defense, Sirimotocycle must show that (1) it did not use “KTM” as a trademark, (2) the use is descriptive of its goods, and (3) it used the mark fairly and in good faith. Packman v. Chi. Tribune Co., 267 F.3d 628, 639 (7th Cir. 2001). The “fair use” defense “involves fact-intensive determinations inappropriate for the motion to dismiss stage.” Trademark Rightsholder v. Individual, P’ships, & Unincorporated Ass’ns, 2024 WL 4382195, at *5 (N.D. Ill. Oct. 2, 2024) (citing Brownmark Films, LLC v. Comedy Partners, 682 F.3d, 687, 690 (7th Cir. 2012) (the

fair use defense “typically turn[s] on facts not before the court at [the motion to dismiss] stage in the proceeding.”). The Seventh Circuit has instructed that dismissing a claim based on an affirmative defense “is appropriate only when the factual allegations of the complaint unambiguously establish all of the elements of the offense.” S.C. Johnson & Son, Inc., v. Nutraceutical Corp., 835 F.3d 660, 666 (7th Cir. 2016). KTM counters that determining whether Sirimotocycle engaged in fair use and/or nominative fair use involves an intensive fact inquiry and therefore “neither defense provides a basis for a Rule 12(b)(6) dismissal.” Mot. Dismiss at 6. KTM

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KTM AG v. The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A Hereto, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ktm-ag-v-the-individuals-corporations-limited-liability-companies-ilnd-2025.