Pietz v. Apple Inc.

CourtDistrict Court, S.D. Florida
DecidedMay 16, 2025
Docket0:25-cv-60259
StatusUnknown

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

Bluebook
Pietz v. Apple Inc., (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 25-CV-60259-DAMIAN/VALLE

ROBERT PIETZ,

Plaintiff,

v.

APPLE, INC.,

Defendant. /

REPORT AND RECOMMENDATION TO DISTRICT JUDGE

THIS MATTER is before the Court upon: (i) Defendant Apple Inc.’s Motion to Dismiss (ECF No. 14) (the “Motion to Dismiss”); and (ii) Plaintiff Robert Pietz’s Motion for Leave to Amend Complaint to Conform with Supplemental Rule C and with In Rem Jurisdiction, Asset Forfeiture, and Arrest Protocols (ECF No. 39) (the “Motion for Leave to Amend”). This case has been referred to the undersigned for rulings on all discovery and pretrial non-dispositive matters and for issuance of a Report and Recommendation on any dispositive matters. See (ECF No. 15). Accordingly, having reviewed the Motion to Dismiss, Plaintiff’s Response (ECF No. 28), Defendant’s Reply (ECF No. 33), and Plaintiff’s Motion for Leave to Amend, and being fully advised in the matter, the undersigned RECOMMENDS that Defendant’s Motion to Dismiss be GRANTED, Plaintiff’s Motion for Leave to Amend be DENIED, and the case be DISMISSED WITH PREJUDICE for the reasons set forth below. The undersigned further RECOMMENDS that all other pending Motions (ECF Nos. 36, 38) be DENIED AS MOOT. I. BACKGROUND In February 2025, Plaintiff, representing himself, filed a single-count Complaint against Defendant Apple, Inc. for unjust enrichment.1 See generally (ECF No. 1) (“Compl.”). More specifically, the Complaint alleges that on March 19, 2021, Defendant officially changed its name with the Florida Department of State from “Apple Computer, Inc.” to “Apple Inc.,” and thereby

relinquished its rights to the name “Apple Computer, Inc.” Compl. ¶ 4. The Complaint further alleges that on January 15, 2025, Plaintiff incorporated his own entity under the name “Apple Computer, Inc.” in Florida. Compl. ¶ 5. Less than a month later, on February 12, 2025, Plaintiff filed the instant Complaint alleging a claim of unjust enrichment against Defendant.2 The Complaint alleges that, as the CEO and owner of the newly incorporated Apple Computer, Inc., Plaintiff seized control over all existing copyrights that listed Apple Computer, Inc. as the copyright holder. Compl. ¶¶ 6, 15. Based on that, Plaintiff alleges that Defendant has

1 Additionally, a review of the Southern District of Florida’s CM/ECF filing system reflects that Plaintiff has recently filed at least four other cases in this District. See, e.g., Pietz v. United States Environmental Protection Agency et al., Case No. 25-CV-60394-AHS (S.D. Fla. Feb. 28, 2025) (ECF No. 1) (pending claim for breach of prudence against, among others, the EPA, City of Tamarac, and City of Fort Lauderdale); Pietz v. Amazon.com et al., Case No. 24-CV-62167-RS (S.D. Fla. Nov. 19, 2024) (voluntarily dismissed claims for violations of the Racketeer Influenced and Corrupt Organizations Act, civil conspiracy, infliction of emotional distress, antitrust violations, unjust enrichment, and tax fraud against Amazon and Google); Pietz v. The Florida Bar, Case No. 24-CV-61959-DSL (S.D. Fla. Nov. 13, 2024) (ECF No. 6) (voluntarily dismissed claim for declaratory and injunctive relief regarding mandatory bar admission requirements that purportedly infringed on Plaintiff’s constitutional rights); Pietz v. Tasso Partners, LLC et al., Case No. 24-CV-62176-RS (S.D. Fla. Nov. 26, 2024) (ECF No. 13) (pending claim for violation of the Securities Exchange Act of 1934 with ripe motions to dismiss by defendants and for preliminary injunction/TRO by Plaintiff). 2 Additionally, on February 17, 2025, Plaintiff filed a similar complaint with the Copyright Claims Board (“CCB”) alleging copyright infringement by Defendant. See Apple Computer, inc. et al v. Apple, inc., Case No. 25-CCB-0061, DE 1 (Plaintiff’s CCB complaint). The CCB has since found that Plaintiff was “an interloper who filed a baseless copyright infringement claim on behalf of himself and a corporation he formed in January [2025] and deceptively named ‘Apple Computer Inc.’” Id. at DE 3. Ultimately, the CCB concluded that Plaintiff and his “spuriously named Florida corporation” have no interest in Defendant’s copyrights. Id. at DE 4. been unjustly enriched by its continued use of these copyrights. Compl. ¶ 14. Among other relief, Plaintiff seeks restitution and disgorgement of Defendant’s profits related to its copyrights, a permanent injunction preventing Defendant from using its copyrights, judicial appointment of Plaintiff as the CEO of Defendant, and a device that Plaintiff can use to create a key fob for a car. Compl. ¶¶ 20-26.

In response, Defendant filed its Motion to Dismiss, arguing that the Complaint should be dismissed because: (i) Plaintiff does not own the copyrights; (ii) Plaintiff’s unjust enrichment claim is preempted by the Copyright Act; (iii) Plaintiff, as an individual, lacks standing to sue; (iv) the Complaint fails to state a claim for unjust enrichment; and (v) the non-monetary relief Plaintiff requests is inappropriate in a claim for unjust enrichment. See generally (ECF No. 14). Plaintiff opposes the Motion to Dismiss and has separately filed a Motion for Leave to Amend the Complaint. See generally (ECF Nos. 28, 39). In the Motion for Leave to Amend, Plaintiff explains that he seeks to amend his Complaint “for the limited purpose of: (i) conforming the pleading to the procedural requirements of a verified

admiralty complaint under Supplemental Rule C, and (ii) substantiating the factual basis for in rem jurisdiction and aligning the operative pleading with the statutory prerequisites for asset forfeiture and arrest, such that the Clerk of Court and the United States Marshals Service (or other appropriate port authority) may issue and execute a warrant for the arrest of contested goods introduced into U.S. commerce under unresolved legal title.” (ECF No. 39 at 1-2). Defendant has not responded to Plaintiff’s Motion. I. LEGAL STANDARDS A. Motion to Dismiss Under Federal Rule of Civil Procedure 12(b)(6), a court may dismiss a complaint for failure to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6). To withstand a Rule 12(b)(6) motion to dismiss, a plaintiff must plead enough facts to state a claim that is “plausible on its face.” Alcon Labs., Inc. v. Allied Vision Group, Inc., No. 18-CV-61638, 2019 WL 2245584, at *1 (S.D. Fla. Mar. 7, 2019), report and recommendation adopted, 2019 WL 2245262 (S.D. Fla. Apr. 2, 2019) (citing Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). This requirement is designed

to “give the defendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citation and alterations omitted). At the motion to dismiss stage, all factual allegations in the complaint are accepted as true and all reasonable inferences are drawn in plaintiff’s favor. Alcon Labs., Inc., 2019 WL 2245584, at *2 (citing Speaker v. U.S. Dep’t of Health & Human Servs. Ctrs. for Disease Control & Prevention, 623 F.3d 1371, 1379 (11th Cir. 2010)). While a plaintiff need not provide “detailed factual allegations,” the allegations must consist of more than “a formulaic recitation of the elements of a cause of action.” Twombly, 550 U.S. at 555 (citation omitted). Factual allegations must be enough to raise a right to relief above the speculative level. Id.

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Pietz v. Apple Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/pietz-v-apple-inc-flsd-2025.