MacNeil Automotive Products Limited v. Jinrong (SH) Automotive Accessory Development Co Ltd

CourtDistrict Court, W.D. Washington
DecidedAugust 19, 2021
Docket2:20-cv-00856
StatusUnknown

This text of MacNeil Automotive Products Limited v. Jinrong (SH) Automotive Accessory Development Co Ltd (MacNeil Automotive Products Limited v. Jinrong (SH) Automotive Accessory Development Co Ltd) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MacNeil Automotive Products Limited v. Jinrong (SH) Automotive Accessory Development Co Ltd, (W.D. Wash. 2021).

Opinion

1 2 UNITED STATES DISTRICT COURT 3 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 4 MacNEIL AUTOMOTIVE PRODUCTS 5 LIMITED d/b/a WEATHERTECH; and MacNEIL IP LLC, 6 Plaintiffs, 7 C20-856 TSZ v. 8 ORDER JINRONG (SH) AUTOMOTIVE 9 ACCESSORY DEVELOPMENT CO., LTD.; and RUI DAI, 10 Defendants. 11

12 THIS MATTER comes before the Court on (i) a motion for summary judgment, 13 docket no. 91, brought by defendant Jinrong (SH) Automotive Accessory Development 14 Co., Ltd. (“Jinrong”); (ii) a motion for sanctions, including judgment against Jinrong, 15 docket no. 125, brought by plaintiffs MacNeil Automotive Products Limited d/b/a/ 16 WeatherTech (“WeatherTech”) and MacNeil IP LLC; (iii) Jinrong’s motion for leave to 17 amend its answer, docket no. 133; and (iv) plaintiffs’ motion for leave to take additional 18 depositions, docket no. 148. Each side also moves to strike certain materials filed by the 19 opposition. Having reviewed all papers filed in support of, and in opposition to, the 20 various motions, the Court enters the following order. 21 Background 22 MacNeil IP LLC owns U.S. Patent Nos. 8,382,186 (the “’186 Patent”) and 1 is the exclusive licensee of the ’186 and ’834 Patents. Id. The ’186 Patent discloses a 2 vehicle floor tray that is thermoformed from a polymer sheet of substantially uniform

3 thickness. Abstract of ’186 Patent, Ex. 1 to Am. Compl. (docket no. 33-1). The 4 ’834 Patent similarly discloses a vehicle floor tray, but one that is molded (instead of 5 thermoformed) from a sheet of polymeric material of substantially uniform thickness. 6 Abstract of ’834 Patent, Ex. 2 to Am. Compl. (docket no. 33-1). WeatherTech 7 manufactures and distributes vehicle floor mats throughout the United States. See Am. 8 Compl. at ¶ 7 (docket no. 33).

9 In April 2019, WeatherTech and MacNeil IP LLC (collectively, “MacNeil”) 10 commenced this infringement action in the Northern District of Illinois against Jinrong 11 and Rui Dai, see Compl. (docket no. 1); Rui Dai has not yet appeared in this matter. In 12 January 2020, Jinrong moved for dismissal based on a lack of personal jurisdiction. See 13 Def.’s Mot. (docket no. 34). On May 13, 2020, Jinrong filed a responsive pleading

14 admitting that the Northern District of Illinois had subject matter jurisdiction and stating 15 that Jinrong did not contest personal jurisdiction. Answer to ¶ 5 (docket no. 59). On the 16 same day, Jinrong withdrew its motion challenging personal jurisdiction and moved to 17 transfer venue, citing as grounds its relationship with Yita LLC, its “exclusive retailer,” 18 which is a defendant in another infringement action brought by MacNeil, which had

19 already been transferred to this district. See Def.’s Mot. (docket no. 60); Def.’s Memo. 20 (docket no. 62). In June 2020, MacNeil and Jinrong filed a stipulation to transfer venue 21 to this district. See Jt. Stip. (docket no. 65). In connection with this stipulation, Jinrong 22 agreed (i) “not to object to personal jurisdiction,” and (ii) the Western District of 1 case was transferred on June 3, 2020. See Minute Entry (docket no. 66); Transfer Letter 2 (docket no. 67).

3 In July 2020, Jinrong sought to stay this matter pending determination of four inter 4 partes review (“IPR”) proceedings pending before the U.S. Patent and Trademark Office, 5 Patent Trial and Appeal Board (“PTAB”) involving MacNeil IP LLC and Yita LLC.1 See 6 Def.’s Mot. (docket no. 71). The motion was denied because Jinrong is not a party to the 7 IPR proceedings. See Minute Order at ¶ 2 (docket no. 74). Jinrong’s subsequent motion 8 for reconsideration, docket no. 75, and renewed motion to stay, docket no. 108, were also

9 denied. See Minute Order at ¶ 1 (docket no. 87); Minute Order at ¶ 1 (docket no. 115). 10 After reviewing the parties’ Joint Status Report, docket no. 86, which indicated 11 Jinrong anticipated filing a dispositive motion asserting that the accused infringement is 12 beyond the territorial scope of United States patent law, the Court set a deadline for filing 13 such motion. See Minute Order at ¶ 2 (docket no. 87). Jinrong timely filed a motion for

14 summary judgment, docket no. 91, but the Court’s consideration of the motion was 15 delayed while the parties engaged in “jurisdictional” discovery and the Court resolved 16 their related disputes. See Minute Order (docket no. 103); Minute Order (docket 17 no. 120). Jinrong’s motion for summary judgment is now fully briefed. MacNeil not 18 only opposes Jinrong’s motion for summary judgment, it seeks sanctions against Jinrong

20 1 The PTAB has since denied institution of two IPR matters, see Yita LLC v. MacNeil IP LLC, 21 No. IPR2020-01138, 2021 WL 129365 (PTAB Jan. 13, 2021) (’186 Patent); Yita LLC v. MacNeil IP LLC, No. IPR2020-001140, 2021 WL 130464 (PTAB Jan. 13, 2021) (’834 Patent), 22 but it has instituted trial with respect to the two other IPR petitions, Yita LLC v. MacNeil IP LLC, No. IPR2020-001139, 2021 WL 130633 (PTAB Jan. 13, 2021) (’186 Patent); Yita LLC v. 1 for allegedly making false representations to the Court, spoliating evidence, and 2 otherwise failing to comply with discovery obligations. Jinrong responds that MacNeil

3 lacks admissible evidence for its assertions and moves to strike certain materials on 4 hearsay grounds. Before turning to the parties’ respective accusations and motions to 5 strike, the Court must first assess its jurisdiction. 6 Discussion 7 A. Jurisdiction 8 As measured under the “well-pleaded complaint” rule, subject matter jurisdiction

9 exists if the operative pleading establishes that either (i) federal patent law creates the 10 cause of action set forth therein, or (ii) the plaintiff’s right to relief “necessarily depends 11 on resolution of a substantial question of federal patent law.” Litecubes, LLC v. N. Light 12 Prods., Inc., 523 F.3d 1353, 1360 (Fed. Cir. 2008). Subject matter jurisdiction does not 13 fail simply because the plaintiff might not be able to, or does not, succeed on the merits.

14 Id. 15 The Patent Act imposes liability for making, using, offering to sell, or selling any 16 patented invention, without authority, within the United States, or importing any patented 17 invention, without authority, into the United States. 35 U.S.C. § 271(a). The territorial 18 scope set forth in § 271(a) is not jurisdictional, but rather an element of a claim for

19 infringement. See Litecubes, 523 F.3d at 1360-66. In other words, this Court has subject 20 matter jurisdiction to preside over a dispute concerning whether the acts of infringement 21 defined in § 271(a), one or more of which a defendant is alleged to have performed, 22 occurred within the United States. 1 The Patent Act also prohibits actively inducing the infringement of a patent. 35 2 U.S.C. § 271(b). In contrast to § 271(a), § 271(b) has no territorial bounds, and an entity

3 may be liable for inducement even if its conduct occurred outside the United States. See 4 Merial Ltd. v. Cipla Ltd., 681 F.3d 1283, 1302-03 (Fed. Cir. 2012) (concluding that, 5 when “a foreign party, with the requisite knowledge and intent, employs extraterritorial 6 means to actively induce acts of direct infringement that occur within the United States, 7 such conduct is not categorically exempt from redress under § 271(b)”); Semcon IP 8 Inc. v. Kyocera Corp., No. 2:18-CV-197, 2019 WL 1979930, at *3 (E.D. Tex. May 3,

9 2019) (observing that “[a] claim for indirect infringement has no territorial requirement”).

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MacNeil Automotive Products Limited v. Jinrong (SH) Automotive Accessory Development Co Ltd, Counsel Stack Legal Research, https://law.counselstack.com/opinion/macneil-automotive-products-limited-v-jinrong-sh-automotive-accessory-wawd-2021.