REX - Real Estate Exchange Inc v. Zillow Inc

CourtDistrict Court, W.D. Washington
DecidedJanuary 18, 2024
Docket2:21-cv-00312
StatusUnknown

This text of REX - Real Estate Exchange Inc v. Zillow Inc (REX - Real Estate Exchange Inc v. Zillow Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
REX - Real Estate Exchange Inc v. Zillow Inc, (W.D. Wash. 2024).

Opinion

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3 4 5 6 UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 8 9 REX – REAL ESTATE EXCHANGE, INC., 10 Plaintiff, C21-0312 TSZ 11 v. ORDER 12 ZILLOW GROUP, INC., 13 Defendant. 14 THIS MATTER comes before the Court on a motion for a new trial, docket 15 no. 556, brought by plaintiff REX – Real Estate Exchange, Inc. (“REX”). This case 16 proceeded to trial on two claims, a Lanham Act claim for false advertising and a claim 17 for violating Washington’s Consumer Protection Act (“CPA”). After an eight-day trial, 18 the jury rendered a verdict against REX on both claims. See Verdict (docket no. 539). 19 The jury found that REX had not established a Lanham Act false advertising claim and 20 that, although REX had proven all of the elements of the CPA claim, defendant Zillow 21 Group, Inc. (“Zillow”) had proven its affirmative defense. Id. In the pending motion, 22 1 REX does not seek any relief regarding its Lanham Act false advertising claim; REX 2 requests a new trial only with respect to its CPA claim, contending that the Court erred

3 in (i) instructing the jury with respect to Zillow’s affirmative defense, (ii) precluding 4 testimony regarding real estate commission rates in other countries, and (iii) limiting 5 REX’s rebuttal evidence. Having reviewed all papers filed in support of, and in 6 opposition to, REX’s motion for a new trial as to its CPA claim, the Court DENIES 7 REX’s motion for the reasons set forth in this Order. 8 Discussion

9 REX’s CPA claim concerned Zillow’s websites (Zillow.com and Trulia.com) and 10 related mobile-device applications (“Apps”). Prior to January 2021, Zillow’s websites 11 and Apps displayed, on one page, all homes for sale in a certain region, regardless of how 12 they were listed, i.e., by a real estate agent or broker,1 a property owner, or another entity. 13 In mid-January 2021, Zillow unveiled a two-tab design, which segregated content

14 between tabs or pages labeled as “Agent listings” and “Other listings.” When the two-tab 15 system was activated, REX employed licensed agents and brokers, see Instr. No. 5 at ¶ 12 16 (docket no. 531), and thus, REX’s for-sale listings qualified as “agent listings,” as 17 opposed to for-sale-by-owner or non-agent listings. Nevertheless, when the two-tab 18 display was implemented, REX’s listings were shown on only the “Other listings” page.

20 1 A real estate agent or broker who is a member of the National Association of REALTORS® 21 may also be called a “realtor.” See Prince Report at ¶ 21 (docket no. 344-2); see also Galicia Decl. at ¶ 2 (docket no. 65). 22 1 A. Jury Instruction on Affirmative Defense to CPA Claim 2 REX proved that, in relegating its listings to the “Other listings” tab, Zillow

3 engaged in an unfair or deceptive act or practice, which occurred in the conduct of 4 Zillow’s trade or commerce, affected the public interest, and proximately caused injury to 5 REX’s business. See Verdict at Ans. No. 4 (docket no. 539); see also Instr. No. 15 6 (docket no. 531) (outlining the elements of a CPA claim). The jury also found, however, 7 that Zillow proved its affirmative defense of having engaged in conduct that “was 8 reasonable in relation to the development and preservation of its business.” See Instr.

9 No. 15 (docket no. 531); see also Verdict at Ans. No. 5 (docket no. 539). REX contends 10 that (i) the Court erred in giving a reasonableness defense instruction; and (ii) the Court’s 11 reasonableness defense instruction was deficient. 12 1. An Instruction Was Required 13 REX’s argument that an instruction should not have been given is contrary to

14 Washington law. The Washington Supreme Court has made clear that refusal to provide 15 an instruction when reasonableness is raised as a defense to a CPA claim constitutes 16 error. See Travis v. Wash. Horse Breeders Ass’n, Inc., 111 Wn.2d 396, 408–09, 759 P.2d 17 418 (1988). In this matter, Zillow timely pleaded the reasonableness defense, see Ans. at 18 31 (docket no. 100), REX never moved to strike the defense, and the defense was part of

19 the case at trial, having been explicitly enumerated in the Pretrial Order, docket no. 503. 20 Thus, an instruction on the reasonableness defense was required. 21 / / / 22 / / / 1 2. The Court’s Instruction Correctly Stated the Law 2 REX’s challenge to the wording of the instruction (as opposed to the giving of the

3 instruction) lacks merit for four reasons. First, the instruction at issue (i.e., Instruction 4 No. 15) accurately recited the applicable standards. The text concerning the reasonable- 5 ness defense was drawn from Washington Pattern Instruction 310.02,2 which is virtually 6 identical to the instruction deemed by the Washington Supreme Court in Travis to be a 7 correct statement of the law.3 See 111 Wn.2d at 408–09. The Court properly informed 8 the jury that Zillow was required to “prove by a preponderance of the evidence that [its]

9 act or practice was reasonable in relation to the development and preservation of its 10 business.” See Instr. No. 15 (docket no. 531).4 11 12 13 2 The Washington Pattern Instruction reads: “The Consumer Protection Act does not prohibit acts or practices that are reasonable in relation to the development and preservation of business 14 or that are not injurious to the public interest.” WPI 310.02 (emphasis added). 15 3 The applicable statute provides: “It is . . . the intent of the legislature that this [Consumer Protection A]ct shall not be construed to prohibit acts or practices which are reasonable in 16 relation to the development and preservation of business or which are not injurious to the public interest . . . .” RCW 19.86.920 (emphasis added). The Travis Court was unpersuaded by an 17 attempt to characterize the statute as merely a “legislative preamble.” 111 Wn.2d at 408–09. 18 4 Whether the burden of proof falls on a plaintiff or a defendant in a CPA case was not addressed in Travis, and WPI 310.02 is silent on the question. See WPI 310.02 cmt. (indicating that 19 RCW 19.86.920 does not specify “whether reasonableness is an affirmative defense, a simple defense, or something else,” and observing that “[a]bsent a burden of proof, jurors may find it difficult to fit the instruction into the framework of the plaintiff’s required elements”). The 20 legislature, however, has made clear that the CPA “shall be liberally construed” to serve its “beneficial purposes,” RCW 19.86.920, and placing the burden on a CPA defendant to prove a 21 reasonableness defense is consistent with this legislative directive. REX does not challenge the Court’s decision to place the burden of proof on Zillow. 22 1 Second, in arguing otherwise, REX does not identify any error in the Court’s 2 explanation of the law,5 but rather contends the Court should have instructed about the

3 ultimate factual issue that the jury needed to decide, namely whether Zillow’s conduct 4 “was reasonable in relation to the development and preservation of its business.” The 5 two-tab display that was the focus of this litigation resulted in part from Zillow’s efforts 6 to (i) receive, in a timely fashion, complete information from certain multiple-listing 7 services (“MLSs”) via Internet Data Exchange (“IDX”) feeds, and (ii) comply with a rule 8 (adopted by roughly two-thirds of these MLSs) requiring that IDX-feed listings be

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REX - Real Estate Exchange Inc v. Zillow Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rex-real-estate-exchange-inc-v-zillow-inc-wawd-2024.