Legalforce RAPC Worldwide PC v. United States Patent and Trademark Office

CourtDistrict Court, D. Arizona
DecidedApril 29, 2025
Docket2:24-cv-03437
StatusUnknown

This text of Legalforce RAPC Worldwide PC v. United States Patent and Trademark Office (Legalforce RAPC Worldwide PC v. United States Patent and Trademark Office) 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
Legalforce RAPC Worldwide PC v. United States Patent and Trademark Office, (D. Ariz. 2025).

Opinion

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

9 Legalforce RAPC Worldwide PC, et al., No. CV-24-03437-PHX-JJT

10 Plaintiffs, ORDER

11 v.

12 United States Patent and Trademark Office, et al., 13 Defendants. 14 15 Two related motions are at issue. First, Plaintiffs LegalForce RAPC Worldwide P.C. 16 (LegalForce) and Raj Abhyanker have filed a Motion for Preliminary Injunction (Doc. 16). 17 The Defendant United States Patent and Trademark Office (USPTO), Defendant Secretary 18 of Commerce, and Defendant Under Secretary of Commerce and Director of the USPTO 19 combined their response in opposition thereto with a Motion to Dismiss Plaintiffs’ 20 Complaint (Doc. 27, MTD). Plaintiffs filed a combined response/reply to Defendants’ 21 filing, which the Court will denominate simply as Plaintiffs’ Response (Doc. 31, 22 Response), and Defendants filed a Reply. (Doc. 37, Reply).1 The Court finds these matters 23 appropriate for resolution without oral argument. See LRCiv 7.2(f). For the reasons set 24 forth below, the Court dismisses this action for want of subject matter jurisdiction. . . . 25

26 1 Ten days before Defendants filed their Reply, Plaintiffs submitted a notice and memorandum of supplemental authority (Doc. 34; Doc. 35). Plaintiffs also filed a motion 27 for leave to file a sur-reply (Doc. 39). Plaintiffs’ proposed sur-reply, currently lodged at docket number 40, is more a notice of errata than a substantive legal memorandum. The 28 Court perceives no issue with granting it, nor does the Court perceive a need to afford Defendants an opportunity to respond. 1 I. Background 2 Plaintiffs’ Complaint contains numerous allegations, the majority of which are not 3 germane to the matter currently before the Court. The factual predicate of this lawsuit is 4 Plaintiffs’ assertion that, since 2017, Defendants have engaged in a targeted campaign of 5 meritless and retaliatory disciplinary actions against Mr. Abhyanker. (See Doc. 1, 6 Complaint ¶¶ 1–3; Response ¶¶ 1–3.) However, Plaintiffs state that this lawsuit has very 7 little to do with the facts that gave rise to it. “The instant federal Complaint does not seek 8 to adjudicate any of the above referenced facts. Moreover, Plaintiffs are not asking this 9 Court to decide any issue of patent or trademark law, professional responsibility, or factual 10 guilt or innocence.” (Response ¶ 3.) Plaintiffs contend that the USPTO disciplinary 11 apparatus is facially unconstitutional, and that such unconstitutionality is divorced from 12 the specific animus that Mr. Abhyanker has allegedly been subjected to. According to 13 Plaintiffs, their “constitutional claims would remain if the USPTO charged a different 14 attorney, or even if there were no charges at all—they go to ‘the very existence and 15 structure’ of the USPTO’s disciplinary system.” (Response ¶ 3 (emphasis in original).) 16 Although that assertion might beg a standing challenge, the Court quotes it here simply to 17 highlight the avowedly facial nature of Plaintiffs’ lawsuit. 18 The facts that are relevant to the instant dispute are as follows. On December 23, 19 2019, the USPTO filed an administrative disciplinary complaint against Mr. Abhyanker 20 under 37 C.F.R. § 11.34. (Complaint ¶ 23; MTD at 3; Response ¶ 2.)2 In March of 2022 21 and April of 2023, an administrative law judge (ALJ), whom the USPTO retained “on loan” 22 from the Department of Housing and Urban Development (HUD), conducted a hearing

23 2 In ascertaining the facts relevant to this jurisdictional dispute, the Court looks to both Plaintiffs’ Complaint and Defendants’ Motion to Dismiss. In general, district courts 24 must consider information outside the pleadings when such information bears upon the presence or absence of subject matter jurisdiction. See Leite v. Crane Co., 749 F.3d 1117, 25 1121–22 (9th Cir. 2014). The consideration of extra-pleading evidence normally occurs in the context of “factual” jurisdictional disputes, as opposed to “facial” disputes. Id. The 26 parties do not address whether the instant matter is factual or facial, but the Court feels it unnecessary to so distinguish. The facts provided in Defendants’ Motion are purely 27 supplementary, offered only to fill in minor gaps left in Plaintiffs’ Complaint and not for the purpose of contradicting anything therein. Plaintiffs do not contest Defendants’ ability 28 to make supplementary factual allegations, nor do Plaintiffs challenge any particular allegation made by Defendants. 1 pursuant to 37 C.F.R. § 11.44. (Complaint ¶¶ 29–35; MTD at 3–4.) There were several 2 reasons for the year-long delay between the commencement and conclusion of the hearing, 3 including technical difficulties, a breach of court rules by USPTO personnel, a “Motion for 4 Interlocutory Appeal and Stay pending Resolution of Live Hearing Request” filed by 5 Mr. Abhyanker, a motion to reinstate counsel filed by Mr. Abhyanker, and a “Motion on 6 Hearing Scheduling” filed by Mr. Abhyanker. (Complaint ¶¶ 29–35.) 7 On November 22, 2024, the ALJ issued an “initial decision” pursuant to 37 C.F.R. 8 § 11.54. (Complaint ¶ 36; MTD at 3–4.) Initial decisions automatically become final 9 decisions unless an appeal is filed within thirty days of the issuance of the initial decision. 10 37 C.F.R. § 11.54(d). In this case, the ALJ’s initial decision did not become final because 11 Mr. Abhyanker filed a motion for reconsideration on December 2 followed by a notice of 12 appeal on December 6. (Complaint ¶ 39; MTD at 4.) In between those two filings, on 13 December 4, Plaintiffs3 filed the instant lawsuit. Although the ALJ has since denied 14 Mr. Abhyanker’s motion for reconsideration, the appeal of the ALJ’s decision is still 15 outstanding before the Director of the USPTO. (MTD at 4.) 16 The Eastern District of Virginia has exclusive jurisdiction to review final USPTO 17 disciplinary decisions. See 35 U.S.C. § 32. Here, that jurisdiction has not yet vested because 18 no final USPTO decision exists in this case, as Mr. Abhyanker elected to appeal the ALJ’s 19 initial decision rather than permit it to become final. However, Plaintiffs contend that the 20 absence of finality, as well as the absence of any adjudicative authority possessed by the 21 District of Arizona over administrative appeals of USPTO disciplinary decisions, is of no 22 moment in this case because the nature of their claims obviates the need for administrative 23 compliance. In Plaintiffs’ view, this lawsuit exists outside the ordinary administrative 24 channels, as it “concerns the overall structure of the proceedings under the [sic] Axon 25 Enterprise, Inc. v. FTC, 598 U.S. 175 (2023), and not on the underlying facts of matter 26 [sic] pending before the [USPTO Director].” (Complaint ¶ 40.)

27 3 Plaintiffs are Mr. Abhyanker and LegalForce, a law firm owned by Mr. Abhyanker that exists “to enhance access to legal services to first time entrepreneurs and small 28 businesses seeking to protect their intellectual property at an affordable price.” (Complaint ¶¶ 6–7.) 1 Plaintiffs bring four claims.

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Legalforce RAPC Worldwide PC v. United States Patent and Trademark Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/legalforce-rapc-worldwide-pc-v-united-states-patent-and-trademark-office-azd-2025.