MARS Advertising, Inc. v. XMars Corp.

CourtDistrict Court, C.D. California
DecidedSeptember 13, 2024
Docket2:24-cv-03475
StatusUnknown

This text of MARS Advertising, Inc. v. XMars Corp. (MARS Advertising, Inc. v. XMars Corp.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MARS Advertising, Inc. v. XMars Corp., (C.D. Cal. 2024).

Opinion

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8 United States District Court 9 Central District of California

11 MARS ADVERTISING, INC., Case № 2:24-cv-03475-ODW (PVCx)

12 Plaintiff, ORDER GRANTING MOTION FOR 13 v. PRELIMINARY INJUNCTION [19]; 14 XMARS CORP.et al., AND DENYING REQUEST FOR 15 LEAVE TO FILE NEW EVIDENCE Defendants. [71] 16 17 I. INTRODUCTION 18 Plaintiff MARS Advertising, Inc. (“MARS”), a traditional advertising agency 19 that provides marketing and e-commerce services using the trademark “MARS,” 20 brings this trademark infringement action against Defendants XMars Corp., SparkX 21 Global Corp., and SparkX Marketing Co., Ltd. (collectively “Defendants”), which 22 also provide e-commerce advertising services under the trademark “XMARS.” (See 23 Compl., ECF No. 1.) MARS moves for a preliminary injunction prohibiting 24 Defendants’ use of the “XMARS” Mark to market and sell the same services offered 25 by MARS through the same channels of trade. (Mot. Prelim. Inj. (“Motion” or 26 “Mot.”), ECF No. 19.) On September 10, 2024, the Court heard argument and 27 received evidence from the parties. (Mins., ECF No. 70.) For the reasons that follow, 28 the Court GRANTS the Motion. (ECF No. 19.) 1 Il. BACKGROUND 2 Due to the complex nature of intellectual property disputes, the background is 3 || divided into two sections: (1) a general “factual background” of the parties, a brief 4|| discussion of the two marks currently in dispute, and a comparison of services that MARS and Defendants offer; and (2)a “procedural background” addressing the 6 || relevant filings in this matter. A. Factual Background 8 MARS has operated as an advertisement agency—using “MARS” as a 9 || trademark continuously and exclusively—for the past fifty-two years. (Mot. 1.) 10 | MARS owns registrations for the following trademarks for use in connection with 11 || their advertisement, marketing, and e-commerce services: 12 [Reg.No.| Mark _—i|,_ Date Registered Goods/Services 13 MARS Advertising agency rons] mans fosinsine Jeeenem 14 ® Advertising agency 16 Advertising and 4613927 THEMARSAGENCY September 30, 2014 | marketing services 17 (stylized) Class 35 Advertising agency 18 THE MARS services; advertising and 19 4657754 AGENCY December 16, 2014 | marketing services; shopper marketing 20 services (Class 35 21 | (Mot. 3.) 22 MARS also owns the MARS UNITED and MARS UNITED COMMERCE word 23 | marks and the following MARS UNITED COMMERCE design marks (together with 24 | the registrations above, the “MARS Marks”). (Compl. § 21; Mot. 3-4.) MARS 26 ABS MW commence UNITED COMMERCE 28 || (Mot. 12.)

1 Defendants began using the “XMARS” Mark on or around Fall of 2022. 2 || (Opp’n 1, ECF No. 35.) Through the “XMARS” Mark, Defendants offered a range of 3 || “ad technology tools” to brands, third-party sellers, and advertising agencies, to 4|| increase sales on the Amazon Marketplace. (/d.) Defendants offer similar or 5 || near-identical e-commerce advertising and marketing services as MARS under the 6 || “XMARS” Mark: : xmars 8 (Mot. 7.) The parties present several examples of how MARS and Defendants both 10 || use their respective marks. This is the actual side-by-side comparison of the two 11 || marks (in their current brand logo format): 2

16 || (Mot. 12.) 17 While the stylized Marks may at first glance seem dissimilar, when the two 18 | marks are searched online or appear on website databases and in print, the similarities 19 | are obvious. For instance, when typed, “MARS” and “XMARS” appear virtually 20 || identical and, when spoken, sound virtually identical. The two marks differ by a single letter, “X,” and when searched in online databases, the two marks frequently 22 || appear in the same search results. One example is the “Amazon Ads Partner 23 || Directory,” through which MARS and Defendants both offer services. (Opp’n 2; 24 || Reply 3, ECF No. 39.) A search for “mars” in the “Amazon Ads Partner Directory,” 25 || provides MARS and “XMARS” as the first two advertisement partners to appear: 26 27 28

ele Melina og 2 3 1140 results 4 © nivence © réraneed 5 Services vo UNITED. ( ) COMMERCE = Products ww 6 Mars United Commerce Xmars Countries w We are an independently-owned connected mars, powered by SparkXGlobal, is an 7 commerce agency that specializes in creating advanced Al plattorm that provides brands, breakthrough solutions by balancing the ... sellers and agencies with unparalleled ... 8 Corfications ~ @ 36 Services @ 36 Services Industries we & 12 Products: & 12 Products 9 # 7 Certifications # 12 Certifications More filters we ® 2 Awards 10 .

View profile View profile 12 13 || (Reply 3.) With regard to the goods and services MARS and Defendants’ “XMARS” 14 || offer, the Amazon Ads Partner comparison feature provides a clear picture of the near 15 || identical range of services: 16 Mars United Commerce | Mars 17 Media planning and buying Media planning and buying Campaign setup | Campaign setup 18 | Campaign management and optimization Campaign management and optimization 19 Campaign monitoring | Campaign monitoring 30 Campaign reporting and analytics Campaign reporting and analytics 1 _ Audience management and engagement Audience management and engagement | Creative and brand experience Creative and brand experience Pp Pp 22 | Photography | Photography 23 | Video production | Video production 4 Audio ads production Audio ads production | Rich media | Rich media

26 || Ud. at 4-5.)! 27 28 || | This is only a small portion of the near-identical services that MARS and Defendants via “XMARS?” offer.

1 B. Procedural Background: 2 On April 24, 2024, MARS sent Defendants a cease-and-desist letter demanding 3 Defendants discontinue their infringement of MARS’s trademarks. (Decl. Robert E. 4 Hough, II (“Hough Decl.”), Ex. Y (“Cease & Desist Letter” or “Letter”), ECF 5 Nos. 19-1, 19-26.) To be specific, MARS demanded that Defendants “[s]top all use 6 and promotion of ‘XMARS’ . . . in connection with marketing, advertising, consulting 7 and related goods and services.” (Letter 2.) The letter provided Defendants with 8 forty-eight hours to respond before MARS would file suit. (Id.) Defendants 9 acknowledged receipt of the Letter twice, but were unable to retain legal counsel and 10 formally respond to MARS within the time allotted. (See Mot. 8; Opp’n 18.) 11 On April 26, 2024, MARS filed this action. (See Compl.) MARS alleges five 12 causes of action for: (1) trademark infringement under 15 U.S.C. § 1114; (2) false 13 designation of origin and false descriptions and representation under 15 U.S.C. 14 § 1125(a); (3) trademark infringement and unfair competition under state common 15 law; (4) cancellation of federal trademark registration under 15 U.S.C. § 1119; and 16 (5) cyberpiracy pursuant to 15 U.S.C. § 1125(d). (Id. ¶¶ 38–72.) 17 On May 17, 2024, MARS filed the instant Motion seeking to: 18  Prohibit Defendants from using MARS or “XMARS” Marks to designate the 19 source of any advertising, marketing, or e-commerce-type services; 20  Prohibit Defendants from stating or suggesting that Defendants’ services originated with MARS, or that there is any affiliation or connection between 21 MARS and Defendants and their respective services; 22  Order Defendants to file proof of compliance within fifteen days to the 23 Court. 24 (MARS Proposed Order ISO Mot., ECF No. 19-36.) The Motion is fully briefed. 25 (Mot.; Opp’n; Reply; Surresponse,2 ECF No. 61 (sealed); Surreply, ECF No. 66.) 26 27

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MARS Advertising, Inc. v. XMars Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mars-advertising-inc-v-xmars-corp-cacd-2024.