MacNeil Automotive Products Limited v. Yita LLC

CourtDistrict Court, W.D. Washington
DecidedAugust 1, 2025
Docket2:20-cv-00278
StatusUnknown

This text of MacNeil Automotive Products Limited v. Yita LLC (MacNeil Automotive Products Limited v. Yita LLC) 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. Yita LLC, (W.D. Wash. 2025).

Opinion

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3 4 5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8 MacNEIL AUTOMOTIVE PRODUCTS LIMITED d/b/a WEATHERTECH; and 9 MacNEIL IP LLC, 10 Plaintiffs, 11 v. C20-0278 TSZ 12 YITA, LLC d/b/a Oedro or YitaMotor; ORDER and JINRONG (SH) AUTOMOTIVE 13 ACCESSORY DEVELOPMENT CO., LTD., 14 Defendants. 15

16 THIS MATTER comes before the Court on cross-motions for summary judgment, 17 docket nos. 225 and 234. Having reviewed all papers filed in support of, and in 18 opposition to, the motions, and having concluded that oral argument would not be 19 beneficial, the Court enters the following Order. 20 Background 21 This case has a long and tortured procedural history, and the parties, which are 22 competitors in the vehicle floor tray market, have been litigating in various forums for 1 several years.1 Now on the verge of trial, they ask the Court to enter summary judgment 2 in favor of one or the other side. The Court declines to do so because the factual issues

3 involved must be decided by a jury. Those issues include (i) whether the unregistered 4 trade dress defendants allegedly imitated is functional de jure2 and therefore not subject 5 to protection under the Lanham Act; (ii) if not functional de jure, whether the trade dress 6 has acquired secondary meaning3; (iii) if the trade dress has secondary meaning, whether 7 8

9 1 The two consolidated cases before the Court began in April 2019 in the Northern District of 10 Illinois. See Order at 2 (docket no. 129). Since then, the parties have appeared in inter partes review proceedings before the United States Patent and Trademark Office (“PTO”) Patent Trial 11 and Appeal Board (“PTAB”), as well as the United States Court of Appeals for the Federal Circuit; plaintiffs’ claims relating to U.S. Patents Nos. 8,889,655 and 9,138,917 are currently 12 stayed pending the Federal Circuit’s review of the PTAB’s decisions concerning those patents. See Minute Order at ¶ 1 (docket no. 182). Plaintiffs’ claim of infringement as to U.S. Patent 13 No. 8,382,186 has been dismissed in light of the Federal Circuit’s invalidation of all claims of the patent. See Minute Order at ¶ 1 (docket no. 172) (citing Yita LLC v. MacNeil IP LLC, 69 F.4th 1356 (Fed. Cir.), cert. denied, 144 S. Ct. 499 (2023)). 14 2 A product design may be functional in two ways: (i) functional de facto, meaning that the 15 product has a particular function (for example, a bottle of any design holds a substance); and (ii) functional de jure, meaning that the product has a particular shape or configuration because it 16 works better that way. See Great Neck Saw Mfrs., Inc. v. Star Asia U.S.A., LLC, 727 F. Supp. 2d 1038, 1059 (W.D. Wash. 2010). In contrast to designs that are functional de facto, designs that 17 are functional de jure are not entitled to trade dress protection. Id. (citing Leatherman Tool Grp., Inc. v. Cooper Indus., Inc., 199 F.3d 1009, 1012 (9th Cir. 1999)). Because the trade dress at 18 issue is not on the PTO’s Principal Register, plaintiffs bear “the burden of proving that the matter sought to be protected is not functional.” 15 U.S.C. § 1125(a)(3). Functionality is a question of 19 fact. Fuddruckers, Inc. v. Doc’s B.R. Others, Inc., 826 F.2d 837, 843 (9th Cir. 1987) (holding that the trial court erred in failing to instruct the jury about functionality). 20 3 Trade dress attains “secondary meaning” when “the purchasing public associates the dress with a particular source.” See, e.g., Clicks Billiards Inc. v. Sixshooters, Inc., 251 F.3d 1252, 1262 21 (9th Cir. 2001). A product feature whose only impact is “decorative and aesthetic, with no source-identifying role,” is not protected by the Lanham Act. See id. Whether a particular trade 22 dress has acquired secondary meaning is a question of fact. Id. 1 a likelihood of confusion4 between plaintiffs’ and defendants’ products exists; and 2 (iv) whether any of defendants’ products infringe United States Patent No. 8,833,834

3 (“the ’834 Patent”). 4 The Court’s analysis necessarily begins with the operative pleading, i.e., the Third 5 Amended Complaint (“TAC”), docket no. 144. In that document, plaintiffs MacNeil 6 Automotive Products, Limited, WeatherTech Direct, LLC, and MacNeil IP LLC 7 (collectively, “MacNeil Entities”) alleged that their vehicle floor trays contain the 8 following nonfunctional features: (i) “a fore-and-aft oriented parallel array of ribs that

9 have a constant, predetermined width and a constant spacing apart from each other,” with 10 the fore-and-aft ribs all being straight; (ii) “a recessed rectangular badge receptable 11 located near the aft, outboard corner of the floor tray,” with the receptable being 12 “elongate” in a fore-and-aft direction; and (iii) “a specific surface texture on the upper 13 surface” of the floor tray. See TAC at ¶¶ 28–30 (docket no. 144). In response to an

14 interrogatory asking the MacNeil Entities to describe in detail the trade dress at issue, 15 they initially stated: 16 The MacNeil Trade Dress generally comprises multiple channels and a group of ribs, the channels create the perception of multiple straight lines of varying 17 length, each line parallel to each other, equal [sic] spaced apart and having a consistent width, the ribs create the perception of multiple lines that resemble 18 a reverse facing “L” or an angled “V”, other ribs create the perception of multiple lines that resemble an “L” or an angled “V”, the straight lines are 19 aligned with the lines formed by the ribs to create the perception that the lines

20 4 Likelihood of confusion exists when “customers viewing the mark would probably assume that 21 the product or service it represents is associated with the source of a different product or service identified by a similar mark.” Clicks Billiards, 251 F.3d at 1265 (quoting Fuddruckers, 826 F.2d 22 at 845). Likelihood of confusion is a question of fact. Id. at 1264. 1 are continuous, the trade dress further comprising a rectangular area for a label with color located at the lower, outboard corner of the floor tray, 2 parallel to the long axis of the floor tray. 3 Pls.’ Resp. to Interrog. No. 1, Ex. 4 to Iqbal Decl. (docket no. 235-4 at 8). The MacNeil 4 Entities later revised their answer to read: 5 The MacNeil Trade Dress comprises multiple channels positioned fore and a group of baffles/ribs* positioned aft, the channels create the perception of 6 multiple straight lines of varying length, each line parallel to each other, equal [sic] spaced apart and having a consistent width, some of the 7 baffles/ribs create the perception of multiple lines that resemble a reverse facing “L” or an angled “V”, other baffles/ribs create the perception of 8 multiple lines that resemble an “L” or an angled “V”, the straight lines of the channels are aligned with the lines formed by the baffles/ribs to create the 9 perception that the lines are continuous between the channels and the baffles/ribs. The MacNeil Trade Dress further comprises a rectangular area 10 for a label with offsetting color located at the lower, outboard half of the floor tray, parallel to the long axis of the floor tray. The MacNeil Trade Dress 11 further comprises a unique upper surface texture. *For the avoidance of doubt, the terms baffle(s) and rib(s) are interchangeable and 12 equivalent when referring to these structures/designs and they always have been. 13 Pls.’ Supp. Resp. to Interrog. No. 1, Ex. 4 to Iqbal Decl. (docket no.

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MacNeil Automotive Products Limited v. Yita LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/macneil-automotive-products-limited-v-yita-llc-wawd-2025.