Lifetime Brands, Inc. v. QIMA Ltd.

CourtDistrict Court, E.D. Texas
DecidedMarch 1, 2024
Docket2:23-cv-00216
StatusUnknown

This text of Lifetime Brands, Inc. v. QIMA Ltd. (Lifetime Brands, Inc. v. QIMA Ltd.) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lifetime Brands, Inc. v. QIMA Ltd., (E.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

LIFETIME BRANDS, INC., § § Plaintiff, § § v. § CIVIL ACTION NO. 2:23-CV-00216-JRG § QIMA LTD., § § Defendant. §

MEMORANDUM OPINION AND ORDER I. INTRODUCTION Before the Court are two motions. The first is Defendant’s Motion to Dismiss for Lack of Personal Jurisdiction Pursuant to FED. R. CIV. P. 12(b)(2) (the “First Motion”) filed by Defendant QIMA Ltd. (Dkt. No. 14.) After Defendant filed the First Motion, Plaintiff Lifetime Brands, Inc. (“Lifetime”) filed an amended complaint and Defendant filed another motion requesting the same substantive relief on the same grounds. (See Dkt. Nos. 20, 21.) A later-filed amended complaint moots a motion to dismiss based on that earlier complaint. See Griffin v. Am. Zurich Ins. Co., 697 F. App’x 793, 797 (5th Cir. 2017) (“Once filed, that amended complaint rendered all earlier motions … moot.”) Accordingly, the Court finds that the First Motion should be DENIED-AS- MOOT. The second is Defendant’s Motion to Dismiss Plaintiff’s Amended Complaint for Lack of Personal Jurisdiction Pursuant to FED. R CIV. P. 12(b)(2) (the “Second Motion”) filed by Defendant QIMA Ltd. (Dkt. No. 21.) Lifetime opposes the Motion. (See Dkt. No. 23.) For the following reasons, the Court finds that the Second Motion should be CARRIED until limited jurisdictional discovery is completed. II. BACKGROUND Plaintiff Lifetime Brands is a Delaware corporation with its primary place of business in New York. (Dkt. No. 20 at ¶ 1.) Defendant QIMA Ltd. is a limited company organized under the laws of the Hong Kong Special Administrative Region with its principal place of business in Hong

Kong, China. (Id. at ¶ 2.) QIMA Ltd. is a provider of quality assurance and supply chain solutions, operating in 95 countries, including in the United States, with over 40 offices and labs. (Id. at ¶ 18.) One such lab is in New York. (Dkt. No. 21 at 15.) QIMA Ltd. has two relevant subsidiaries, neither of which are named in the complaint. The first, QIMA (US) LLC, is a New York company with its principal place of business in New York. (Dkt. No. 21 at 15; Dkt. No. 21-2 at 3.) The second, QIMA LLC, is also a New York company with its principal place of business in New York. (Dkt. No. 21 at 15; Dkt. No. 21-2 at 4.) Lifetime alleges that QIMA Ltd. “directly participates in the stream of commerce in the Eastern District of Texas by providing ‘quality control along the supply chain’ … in [] Wills Point, Texas.” (Dkt. No. 20 at ¶ 5 (quotations omitted).) Lifetime includes a picture of stuffed animal

giraffes in the First Amended Complaint, seemingly to indicate that these are some of the products that QIMA Ltd. provides quality control for. (See id. at ¶¶ 5–6.) Lifetime also alleges that “[u]pon information and belief, QIMA posts job listings for workers, such as Fruit Quality Control Inspectors, to be employed in the State of Texas (e.g., Garland, TX).” (Id. at ¶ 7.) Further, Lifetime alleges that “QIMA’s website … posts jobs for its various subsidiaries” including subsidiaries which conduct “regular business in the State of Texas.” (Id. at ¶ 8.) Next, Lifetime puts forth that QIMA Ltd., “through its subsidiaries, participates yearly in the BRCGS [] Connect event based in Texas.” (Id.) BRCGS, which stands for “Brand Reputation Compliance Global Standard”, is a certification offered by QIMA. (Id.; Dkt. No. 23 at 11.) Lifetime contends that QIMA Ltd. “describes how it has been BRCGS-accredited send 2012 and kept a 5- star rating that enabled it to win the Food Safety Americas BRCGS Certification Body of the Year Award in 2021.” (Dkt. No. 20 at ¶ 8.) Lifetime also alleges that QIMA Ltd. “publishes Public

Regulatory updates that show it complies with various state laws in the states in which QIMA does business, including the laws of Texas (e.g., Texas bedding law requirements).” (Dkt. No. 20 at ¶ 9.) QIMA Ltd. owns the “QIMA” mark and maintains that it first used the mark in commerce in the United States as early as July 18, 2017. (Dkt. No. 23 at 3–4.) The mark is utilized by two apps accused of infringement and distributed by QIMA Ltd.—QIMA and QIMAone. (Id. at 8.) Lifetime contends that these apps are distributed in Texas and across the United States via the Apple App Store and the Google Play Store pursuant to agreements with Apple and Google. (Id. at 8–10.) III. LEGAL STANDARD

Federal Rule of Civil Procedure 12(b)(2) requires a court to dismiss a claim if the court does not have personal jurisdiction over the defendant. Fed. R. Civ. P. 12(b)(2). It is the plaintiff’s burden to establish that personal jurisdiction exists, but the plaintiff only needs to present facts to make out a prima facie case supporting such jurisdiction. Alpine View Co. v. Atlas Copco AB, 205 F.3d 208, 215 (5th Cir. 2000). “The Court may determine the jurisdictional issue by receiving affidavits, interrogatories, depositions, oral testimony, or any combination of the recognized methods of discovery.” Stuart v. Spademan, 772 F.2d 1185, 1192 (5th Cir. 1985). Additionally, conflicts between the facts contained in the parties’ affidavits must be resolved in favor of the plaintiff for the purpose of determining whether a prima facie case for personal jurisdiction has been made. Bullion v. Gillespie, 895 F.2d 213, 217 (5th Cir. 1990). The rule is well-established that “parties who choose to litigate actively on the merits thereby surrender any jurisdictional objections.” PaineWebber Inc. v. Chase Manhattan Private Bank (Switzerland), 260 F.3d 453, 459 (5th Cir. 2001) (citing General Contracting & Trading Co., LLC v. Interpole, Inc., 940 F.2d 20 (1st

Cir. 1991)). There are two steps to determine whether a federal court may exercise personal jurisdiction over a nonresident defendant: (1) the forum state’s long-arm statute must confer personal jurisdiction over that defendant; and (2) the exercise of personal jurisdiction must comport with the Due Process Clause of the Fourteenth Amendment. McFadin v. Gerber, 587 F.3d 753, 759 (5th Cir. 2009). “As the Texas long-arm statute extends as far as constitutional due process allows,” the Court only needs to consider the second step of the inquiry. Id.; Moncrief Oil Int’l Inc. v. OAO Gazprom, 481 F.3d 309, 311 (5th Cir. 2007); see also Johnston v. Multidata Sys. Int’l Corp., 523 F.3d 602, 609 (5th Cir. 2008) (“Because the Texas long-arm statute extends to the limits of federal due process, the two-step inquiry collapses into one federal due process analysis.”).

The due process analysis focuses on the number and nature of a defendant’s contacts with the forum to determine if the defendant has sufficient “minimum contacts” such “that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.” Int’l Shoe Co. v. Washington, 326 U.S. 310, 326 (1945). These contacts may give rise to specific or general jurisdiction. Daimler AG v.

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Lifetime Brands, Inc. v. QIMA Ltd., Counsel Stack Legal Research, https://law.counselstack.com/opinion/lifetime-brands-inc-v-qima-ltd-txed-2024.