Purple Innovation v. Responsive Surface Technology

CourtDistrict Court, D. Utah
DecidedFebruary 24, 2025
Docket2:20-cv-00708
StatusUnknown

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

Bluebook
Purple Innovation v. Responsive Surface Technology, (D. Utah 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

PURPLE INNOVATION, LLC, MEMORANDUM DECISION AND ORDER Plaintiff, Case No. 2:20-cv-00708-RJS v. Chief Judge Robert J. Shelby RESPONSIVE SURFACE TECHNOLOGY, LLC; PATIENTECH, LLC; and ROBERT GOLDEN,

Defendants.

Before the court is Plaintiff Purple Innovation, LLC’s (Purple’s) Motion for Costs and Attorney Fees against Defendants Responsive Surface Technology, LLC (ReST), PatienTech, LLC, and Robert Golden (collectively, Defendants).1 Also before the court is Purple’s Bill of Costs.2 For the reasons stated below, the court GRANTS IN PART Purple’s Motion and GRANTS Purple’s requested Bill of Costs. BACKGROUND In October 2020, Purple sued Defendants asserting claims related to their alleged breach of contract and misuse of Purple’s intellectual property.3 Thereafter, the parties submitted to a ten-day merits arbitration hearing in the summer of 2023.4 At the hearing, Purple pursued breach

1 Dkt. 252, Purple’s Motion for Costs and Attorney Fees (Motion). 2 Dkt. 251, Bill of Costs. 3 See Dkt. 1, Complaint and Demand for Jury Trial. 4 Dkt. 203-5, Interim Award on Liability and Damages (Interim Award) ¶ 33. of contract claims and various claims under the Lanham Act.5 Defendants pursued several counterclaims.6 On March 8, 2024, the arbitrator issued an Award resolving the parties’ claims and counterclaims.7 The arbitrator found ReST and PatienTech jointly and severally liable to Purple for breach of contract in the principal amount of $1,324,301.00, plus attorney fees and costs for

the arbitration as well as post-award interest.8 The arbitrator also found ReST individually liable on Purple’s Lanham Act claims in the principal amount of $664,482.00, plus post-award interest.9 However, the arbitrator also found Purple liable to ReST for breach of contract in the principal amount of $5,670.32, reducing ReST’s net liability for the Lanham Act claims to $658,811.68.10 The arbitrator denied all other claims and counterclaims, including Purple’s claims against Robert Golden.11 This court thereafter entered judgment consistent with the Award.12 The arbitrator declined to consider the issue of Purple’s entitlement to attorney fees and costs for the pre-arbitration litigation conducted before this court.13 Purple now moves to recover those attorney fees and costs.14 The Motion is fully briefed and ripe for decision.15

5 Id. ¶¶ 32, 133. 6 Id. ¶ 31. 7 See Dkt. 203-8, Final Award. 8 Id. ¶ 89–90. 9 Id. ¶ 91. 10 Id. ¶¶ 33, 91. 11 Id. ¶ 92. 12 See Dkt. 248, Judgment in a Civil Case. 13 Final Award ¶ 66. 14 Motion at 2. 15 See Dkt. 256, Memorandum Opposing Motion for Attorney Fees and Costs (Opposition); Dkt. 260, Reply in Support of Motion for Costs and Attorney Fees (Reply). ANALYSIS Purple seeks recovery of (1) its attorney fees and non-taxable costs under the Lanham Act and (2) its taxable costs under Federal Rule of Civil Procedure 54.16 The Court addresses each request in turn. I. Purple Is Entitled to Attorney Fees and Non-Taxable Costs from ReST Under the Lanham Act.

When considering a request for attorney fees, the court applies the American Rule, in which “[e]ach litigant pays his own attorney’s fees, win or lose, unless a statute or contract provides otherwise.”17 The Lanham Act provides, “[t]he court in exceptional cases may award reasonable attorney fees to the prevailing party.”18 The court first considers whether Purple is the prevailing party under the Lanham Act. It then determines whether this case is “exceptional.” Finally, the court concludes by analyzing the reasonableness of the requested fee award. A. Prevailing Party Under the Lanham Act, the “prevailing party” is the “party in whose favor judgment is rendered, regardless of the amount of damages awarded.”19 The court must have “awarded some relief” to the party such that the court “materially altered” the parties’ legal relationship.20

16 Motion at 2. 17 Baker Botts L.L.P. v. ASARCO LLC, 576 U.S. 121, 126 (2015) (quoting Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 252–53 (2010)). 18 15 U.S.C. § 1117(a). 19 Xlear, Inc. v. Focus Nutrition, LLC, 893 F.3d 1227, 1236 (10th Cir. 2018) (quoting Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Hum. Res., 532 U.S. 598, 603 (2001)). 20 Id. at 1236–37. Defendants do not dispute Purple is the prevailing party under the Lanham Act with respect to ReST,21 and the court agrees.22 The court therefore concludes Purple is the prevailing party under the Lanham Act with respect to ReST and now turns to whether this case is “exceptional.”

B. Exceptionality “District courts may determine whether a case is ‘exceptional’ in the case-by-case exercise of their discretion, considering the totality of the circumstances.”23 “[A]n ‘exceptional’ case is simply one that stands out from others with respect to the substantive strength of a party’s litigating position (considering both the governing law and the facts of the case) or the unreasonable manner in which the case was litigated.”24 The court considers factors such as a case’s lack of foundation, bad faith, and “the unusually vexatious and oppressive manner” in which the case is prosecuted.25 Other relevant factors include “frivolousness, motivation, objective unreasonableness . . . and the need . . . to advance considerations of compensation and

21 Opposition at 5. 22 Defendants argue “[t]here is no basis for a fee or nontaxable cost award against PatienTech or Robert Golden” because “Purple did not prevail on its Lanham Act claims against either PatienTech or Robert Golden.” Opposition at 6. Purple does not specifically address whether it is the prevailing party with respect to PatienTech on its Lanham Act claims, see generally Motion, nor does it contest Defendants’ argument in reply, see generally Reply. The court therefore finds that, for the purpose of the Lanham Act analysis, Purple is the prevailing party only with respect to ReST. See Tulsa Litho Co. v. Tile & Decorative Surfaces Mag. Pub., Inc., 69 F.3d 1041, 1043 (10th Cir. 1995) (explaining the court may award attorney fees and costs “on the basis of the separate judgments obtained, not the overall trial result”). 23 Octane Fitness, LLC v. ICON Health & Fitness, Inc., 572 U.S. 545, 554 (2014). 24 Id. (alteration in original). 25 See King v. PA Consulting Grp., Inc., 485 F.3d 577, 584 (10th Cir. 2007) (quoting Nat’l Ass’n of Pro. Baseball Leagues, Inc. v. Very Minor Leagues, Inc., 223 F.3d 1143, 1146 (10th Cir. 2000)); see also Derma Pen, LLC v. 4EverYoung Ltd., 999 F.3d 1240, 1243–46 (10th Cir. 2021) (extending Octane Fitness to the Lanham Act context). deterrence.”26 Actions such as “willfully deceiving consumers, failing to produce pertinent evidence, and abusing the discovery process” also support an exceptionality finding.27 Purple argues this case is exceptional for six reasons: ReST (1) “engage[d] in discovery abuse”; (2) “engaged in fraud on the arbitration forum and parties by i) forging evidence; ii) giving false deposition testimony; and iii) successfully tricking the Arbitrator in giving ReST

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Purple Innovation v. Responsive Surface Technology, Counsel Stack Legal Research, https://law.counselstack.com/opinion/purple-innovation-v-responsive-surface-technology-utd-2025.