Owen v. Askew

CourtDistrict Court, D. Oregon
DecidedJuly 24, 2025
Docket6:25-cv-01272
StatusUnknown

This text of Owen v. Askew (Owen v. Askew) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Owen v. Askew, (D. Or. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

EUGENE DIVISION

KURSTEN OWEN, individually Civ. No. 6:25-cv-01272-AA and dba Elegance & Geekery LLC,

Plaintiffs, OPINION & ORDER v.

BREANA ASKEW, individually and dba Breromi; KIANDRIA DEMONE BOYCE; DOES 1-100,

Defendants. _______________________________________

AIKEN, District Judge.

This case comes before the Court on Plaintiff’s Ex Parte Motion for Temporary Restraining Order. ECF No. 8. For the reasons set forth below, the Motion is GRANTED. LEGAL STANDARD “In deciding whether to grant a motion for a temporary restraining order (‘TRO’), courts look to substantially the same factors that apply to a court’s decision on whether to issue a preliminary injunction. Pacific Kidney & Hypertension LLC v. Kassakian, 156 F. Supp.3d 1219, 1222 (D. Or. 2016). A preliminary injunction is an “extraordinary remedy that may only be awarded upon a clear showing that the plaintiff is entitled to such relief.” Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 22 (2008). A plaintiff seeking a preliminary injunction must show (1) that he or she is likely to succeed on the merits; (2) he or she is likely to suffer irreparable harm in the absence of preliminary relief; (3) the balance of the equities tips in his or her

favor; and (4) an injunction is in the public interest. Id. at 20. In the Ninth Circuit, courts may apply an alternative “serious questions” test which allows for a preliminary injunction where a plaintiff shows that “serious questions going to the merits” were raised and the balance of hardships tips sharply in plaintiff’s favor, assuming the other two elements of the Winter test are met. Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1131-32 (9th Cir. 2011). This formulation applies a sliding scale approach where a stronger showing on one

element may offset a weaker showing in another element. Id. at 1131. Nevertheless, the party requesting a preliminary injunction must carry its burden of persuasion by a “clear showing” of the four elements set forth above. Lopez v. Brewer, 680 F.3d 1068, 1072 (9th Cir. 2012). DISCUSSION Plaintiff in this case is the owner of a business, Elegance & Geekery LLC,

which sells hair accessories. Compl. ¶¶ 3, 7. ECF No. 1. Defendant Breana Askew is a resident of Florida who does business as Breromi. Id. at ¶¶ 1, 4. Defendant Kiandra Demone Boyce is a resident of Georgia. Id. at ¶ 5. Beginning on July 14, 2025, Askew “began a coordinated online campaign making false statements,” including “publicly accusing Plaintiff of design/invention theft, racism, selling counterfeit versions of goods Defendant Askew claimed she owned patents and trademarks covering, and encouraging the public to report Plaintiff’s online shopping platforms on sites like Etsy, Shopify, and TikTok as fraudulent and/or engaged in illegal activity including selling counterfeit goods.”

Compl. ¶ 8. Askew’s campaign is based on her claim that Plaintiff is selling a hair accessory which Askew claims infringes on her patent. Compl. ¶ 10. Plaintiff alleges that “Askew’s only claim to any intellectual property is her filing of an application (not yet reviewed) for a trademark over the phrase ‘Magnetic Hair Clip’ and a filed patent application (not yet published)” and that the “content of that application has never been provided, so no one knows what she is even claiming she has rights to.” Id.

Plaintiff alleges that between July 14 and July 17, 2025, Defendants “engaged in an online smear campaign, attempting to leverage public hate and harassment as a means of forcing Plaintiff to flee the market.” Compl. ¶ 12. This campaign is “ongoing” and “will likely continue without court interference.” Id. Among other things, Defendants have accused Plaintiff of racism, theft of intellectual property relating to the hair clip, and the sale of counterfeit goods. Id. at ¶¶ 13-14. Boyce has

attempted to coordinate a large number of third-party complaints to Plaintiff’s vendors in an effort to have Plaintiff’s store removed from online platforms. Id. ¶ 14. Defendants’ campaign against Plaintiff has resulted in public confusion, as well as threats and abuse directed at Plaintiff by third parties who read Defendants’ statements concerning Plaintiff. Compl. ¶ 16. This campaign has damaged Plaintiff’s business reputation and her personal reputation. Plaintiff alleges that she had suffered lost profits, lost sales, and lost customer goodwill. Compl. ¶ 18.

Plaintiff bring claims for defamation (Claim 1); trade defamation (Claim 2); tortious interference with business relations and prospective economic advantage (Claim 3); civil conspiracy to defame and interfere with business (Claim 4); intentional infliction of emotional distress (Claim 5); false advertising and unfair competition pursuant to the Lanham Act, 15 U.S.C. § 1125(a) (Claim 6); unfair and deceptive trade practices under Oregon law as to Askew (Claim 7); and negligence (Claim 8). Plaintiff seeks injunctive and declaratory relief.

With respect to the TRO motion, Plaintiff focuses on her claims for defamation and seeks an injunction restraining Askew and Boyce from making further defamatory statements concerning Plaintiff or her business; engaging in harassing or misleading conduct or encouraging others to do so; and directing Askew and Boyce to remove the defamatory posts they have already made concerning Plaintiff or her business.

I. Likelihood of Success on the Merits To prevail on a motion for preliminary injunction, a plaintiff must show either a likelihood of eventual success on the merits or, under the Ninth Circuit’s alternative “sliding scale” formulation of the test, serious questions going to the merits of their claims. Winter, 555 U.S. at 20; Alliance for the Wild Rockies, 632 F.3d at 1131-32. However, a court’s decision on a motion for preliminary injunction is not a ruling on the merits of the claim. Sierra On-Line, Inc. v. Phoenix Software, Inc., 739 F.2d 1415, 1422 (9th Cir. 1984). As noted, Plaintiff’s TRO motion is focused on her claims for defamation. The

Oregon Supreme Court has “recognized a common-law action for defamation for injury to reputation for over 150 years.” Neumann v. Liles, 358 Or. 706, 711 (2016). To establish a claim for defamation, a plaintiff must show that a defendant made a defamatory statement about the plaintiff and published the statement to a third party. Wallulis v. Dymowski, 323 Or. 337, 342-43 (1996). A defamatory statement is one “that would subject the plaintiff to hatred, contempt or ridicule or tend to diminish the esteem, respect, goodwill or confidence in which the plaintiff is held or

excite adverse, derogatory or unpleasant feelings or opinions against the plaintiff.” Neumann, 358 Or. at 711 (internal quotation marks and citation omitted, alterations normalized). In the professional context, a statement is defamatory if it falsely “ascribes to another conduct, characteristics or a condition incompatible with the proper conduct of his lawful business, trade, [or] profession.” Brown v. Gatti, 341 Or. 452, 458 (2006) (internal quotation marks and citation omitted).

Some defamatory statements are actionable per se, meaning without proof of pecuniary loss or special harm. Neumann, 358 Or. at 716.

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Related

Sierra On-Line, Inc. v. Phoenix Software, Inc.
739 F.2d 1415 (Ninth Circuit, 1984)
Samuel Lopez v. Janice Brewer
680 F.3d 1068 (Ninth Circuit, 2012)
Brown v. Gatti
145 P.3d 130 (Oregon Supreme Court, 2006)
Wheeler v. Green
593 P.2d 777 (Oregon Supreme Court, 1979)
Wallulis v. Dymowski
918 P.2d 755 (Oregon Supreme Court, 1996)
Neumann v. Liles
369 P.3d 1117 (Oregon Supreme Court, 2016)
Barnett v. Phelps
191 P. 502 (Oregon Supreme Court, 1920)
Alliance for Wild Rockies v. Cottrell
632 F.3d 1127 (Ninth Circuit, 2011)

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