Now-Casting Economics, Ltd. v. Economic Alchemy LLC

CourtCourt of Appeals for the Second Circuit
DecidedMay 28, 2024
Docket23-947
StatusUnpublished

This text of Now-Casting Economics, Ltd. v. Economic Alchemy LLC (Now-Casting Economics, Ltd. v. Economic Alchemy LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Now-Casting Economics, Ltd. v. Economic Alchemy LLC, (2d Cir. 2024).

Opinion

23-947 Now-Casting Economics, Ltd. v. Economic Alchemy LLC, et al.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 28th day of May, two thousand twenty-four.

PRESENT: REENA RAGGI, DENNY CHIN, MYRNA PÉREZ, Circuit Judges. _____________________________________

NOW-CASTING ECONOMICS, LTD.,

Plaintiff-Counterclaim-Defendant-Appellee,

v. No. 23-947

ECONOMIC ALCHEMY LLC,

Defendant-Counterclaimant-Third- Party-Plaintiff-Appellant,

v.

FEDERAL RESERVE BANK OF NEW YORK,

Third-Party-Defendant-Appellee. * _____________________________________

* The Clerk of Court is respectfully directed to amend the official caption as set forth above. FOR PLAINTIFF-COUNTERCLAIM-DEFENDANT- APPELLEE: Brian A. Katz, Katherine E. Mateo, Olshan Frome Wolosky LLP, New York, NY.

FOR DEFENDANT-COUNTERCLAIMANT- THIRD-PARTY-PLAINTIFF-APPELLANT: Ronald D. Coleman, Dhillon Law Group Inc., Newark, NJ.

THIRD-PARTY-DEFENDANT-APPELLEE: Bruce W. Baber, Jeremy M. Bylund, Zoe M. Beiner, King & Spalding LLP, Atlanta, GA, Washington, D.C.

Appeal from a judgment of the United States District Court for the Southern District of

New York (Cronan, J.; Ramos, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the September 15, 2022 judgment of the district court is AFFIRMED.

This case concerns a trademark dispute. Plaintiff-Counterclaim-Defendant-Appellee

Now-Casting Economics, Ltd. (“NCE”) and Defendant-Counterclaimant-Third-Party-Plaintiff-

Appellant Economic Alchemy LLC (“EA”) are entities that provide services related to economic

“nowcasting,” which attempts to predict present economic conditions. EA timely appealed the

district court’s grant of summary judgment in favor of NCE, and the district court’s dismissal of

EA’s third-party complaint against Third-Party-Defendant-Appellee Federal Reserve Bank of

New York (the “NY Fed”). For the reasons explained below, we affirm.

BACKGROUND

We assume the parties’ familiarity with the underlying facts, the procedural history, and

the issues on appeal, and only recite them as necessary to explain our decision to affirm. NCE 2 began marketing its nowcasting services in the United States, using its present name, as early as

February 2011. In May 2013, EA obtained the United States registrations for the marks

“NOWCAST” and “NOW-CAST” (the “Marks”). In its registrations and applications for the

Marks, EA stated that the date of first use of the Marks in commerce was January 2012.

In 2016, EA sent NCE a cease-and-desist letter alleging that NCE was infringing the

Marks. In March 2018, NCE filed suit against EA in federal court seeking, as relevant here, a

declaratory judgment stating it was not infringing the Marks. EA filed a counterclaim against

NCE for, among other things, trademark infringement, and it also filed a third-party complaint

against twelve Federal Reserve Banks, including the NY Fed. 2 The district court dismissed EA’s

third-party complaint with prejudice in September 2019. In January 2020, the United States

Patent and Trademark Office (“PTO”) cancelled EA’s trademark registrations for the Marks on

administrative grounds. In September 2022, the district court granted summary judgment in

favor of NCE. On appeal, EA challenges the district court’s grant of summary judgment in favor

of NCE, and the district court’s dismissal of its third-party complaint against the NY Fed.

DISCUSSION

I. General Trademark Law Principles

Section 43(a) of the Lanham Act “protects qualifying unregistered trademarks” from

infringement. ITC Ltd. v. Punchgini, Inc., 482 F.3d 135, 154 (2d Cir. 2007) (quoting Two Pesos

v. Taco Cabana, 505 U.S. 763, 768 (1992)). A party asserting trademark infringement for an

unregistered mark or dress under the Lanham Act “must prove (1) that the mark or dress is

2 On appeal, the parties agreed to a stipulated dismissal of the other eleven Federal Reserve Banks and, therefore, the NY Fed is the only remaining Federal Reserve Bank in the instant appeal.

3 distinctive as to the source of the . . . service at issue, and (2) that there is the likelihood of

confusion between the plaintiff’s . . . service and that of the defendant.” Id.; see also 15 U.S.C.

§ 1125(a)(1). “Preliminary to making this showing, however, a [party seeking trademark

protection] must demonstrate its own right to use the mark or dress in question.” ITC Ltd., 482

F.3d at 154. “Whether a mark is entitled to protection depends, in part, upon a showing of prior

use.” Excelled Sheepskin & Leather Coat Corp. v. Or. Brewing Co., 897 F.3d 413, 417 (2d Cir.

2018).

II. EA Fails to Establish that the District Court Erred in Granting Summary Judgment in Favor of NCE

We review de novo a district court’s grant of summary judgment. See Garcia v. Hartford

Police Dep’t, 706 F.3d 120, 126 (2d Cir. 2013) (per curiam). “We may affirm summary judgment

on any ground supported by the record, even if it is not one on which the district court relied.”

McElwee v. County of Orange, 700 F.3d 635, 640 (2d Cir. 2012).

First, the district court did not err by placing the burden on EA to prove that NCE infringed

the Marks. The law is clear that in an action seeking a declaration that a party is not infringing a

mark, as in this case, the party seeking protection of the mark has the burden to prove infringement.

See Medtronic, Inc. v. Mirowski Family Ventures, LLC, 571 U.S. 191, 199 (2014) (“[I]n a

licensee’s declaratory judgment action, the burden of proving infringement should remain with the

patentee.”); see also Cross Commerce Media, Inc. v. Collective, Inc., 841 F.3d 155, 166 (2d Cir.

2016) (discussing that the alleged owner of a mark bears the burden of proving protected rights in

a mark despite being declaratory judgment defendant). EA does not and cannot convincingly

argue otherwise. Thus, to survive summary judgment, EA was required to produce sufficient

4 evidence showing that the Marks are entitled to protection.

Second, EA is wrong in its contention that evidence of the Marks’ previous registrations

was sufficient to meet its burden. EA’s argument is that the PTO’s prior registration of the Marks

created a presumption that the Marks are currently protectable. EA is incorrect. Although “[a]

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Now-Casting Economics, Ltd. v. Economic Alchemy LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/now-casting-economics-ltd-v-economic-alchemy-llc-ca2-2024.