Seattlehaunts LLC v. Thomas Family Farm LLC

CourtDistrict Court, W.D. Washington
DecidedApril 6, 2020
Docket2:19-cv-01937
StatusUnknown

This text of Seattlehaunts LLC v. Thomas Family Farm LLC (Seattlehaunts LLC v. Thomas Family Farm LLC) 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
Seattlehaunts LLC v. Thomas Family Farm LLC, (W.D. Wash. 2020).

Opinion

1 2

3 4 5 6 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE

9 10 SEATTLEHAUNTS, LLC, CASE NO. C19-1937JLR 11 Plaintiff, ORDER DENYING MOTION TO v. DISMISS OR STAY 12 THOMAS FAMILY FARM, LLC, et 13 al., 14 Defendants. 15 I. INTRODUCTION 16 Before the court is Defendant Thomas Family Farm, LLC’s (“Thomas Family 17 Farm”) motion to dismiss or stay this case. (See Mot. (Dkt. # 8); see also Reply (Dkt. 18 # 15).) Plaintiff Seattlehaunts, LLC (“Seattlehaunts”) opposes the motion. (See Resp. 19 (Dkt. # 14).) The court has reviewed the motion, the parties’ submissions in support of 20 // 21 // 22 1 and in opposition to the motion, the relevant portions of the record, and the applicable 2 law. Being fully advised, the court DENIES Thomas Family Farm’s motion to dismiss.1

3 II. BACKROUND 4 A. Factual Background 5 This is an intellectual property dispute. Seattlehaunts provides haunted houses, 6 escape rooms, escape games and other similar attractions in Pierce, King, and Snohomish 7 counties in Washington. (See Am. Compl. (Dkt. # 7) ¶ 1.) Thomas Family Farm owns a 8 farm property (the “Farm”) that Thomas Family Farm and Seattlehaunts used to host an

9 annual haunted house event that the parties titled “Nightmare on 9.” (See id. ¶¶ 16-17.) 10 Seattlehaunts alleges that the first Nightmare on 9 event on the Farm occurred in the fall 11 of 2012 and that Seattlehaunts and Thomas Family Farm were “equal partners” in that 12 iteration of the event. (See id.) Seattlehaunts and Thomas Family Farm continued to run 13 the Nightmare on 9 event on the Farm from 2013 until 2018, but Seattlehaunts claims that

14 it took full control of the annual events beginning in 2013. (See id. ¶¶ 21-25, 29.) The 15 parties entered into an annual contract for the Nightmare on 9 events from 2013 to 2018 16 whereby Seattlehaunts leased the Farm from Thomas Family Farm in exchange for 25% 17 of the ticket sales from the event. (See id. ¶¶ 24, 29.) 18 //

19 20 1 Thomas Family Farm requested oral argument on the motion (see Mot.), but Seattlehaunts did not (see Resp.). The parties thoroughly briefed the issues, and the court finds 21 that this matter can be decided on the parties’ papers. Thus, the court DENIES Defendants’ request for oral argument. See Local Rules W.D. Wash. LCR 7(b)(4) (“Unless otherwise ordered 22 by the court, all motions will be decided by the court without oral argument.”). 1 Thomas Family Farm developed the following graphic for the Nightmare on 9 2 || events: 3 2

7 CO =

9 fe.

10 (See Jacobowitz Decl. (Dkt. #9) J 2, Ex. 1 (‘State Court Compl.”) 4 11, Ex. B (the “Hook Graphic’’); see also id., § 3, Ex. 2 (‘State Court Answer’), § 11 (admitting allegation in paragraph 11).7) However, Seattlehaunts alleges that it contracted with an independent artist, Joseph Wondell, in 2012 to design the following graphic for use in marketing and advertising for the Nightmare on 9 events: 15 NCS 17 nail 18 19 20 1 > As discussed below, the court takes judicial notice of the existence of a parallel lawsuit 9 filed by Thomas Family Farm in Snohomish County Superior Court and of select allegations from the pleadings in that action. See infra § IILA.

1 (See Am. Compl. ¶¶ 3, 18, 35-36 (hereinafter, the “Wondell Graphic”).) Thomas Family 2 Farm paid Mr. Wondell’s original invoice for designing the Wondell Graphic, and the

3 parties used the Wondell Graphic to promote the Nightmare on 9 events. (See id. ¶¶ 18, 4 35-36.) 5 On June 25, 2019, Thomas Family Farm informed Seattlehaunts that Seattlehaunts 6 was not welcome to run a Nightmare on 9 event at the Farm in the fall of 2019. (See id. ¶ 7 31.) Accordingly, Seattlehaunts advertised on its website that it would not run the 8 Nightmare on 9 event at the Farm in 2019, but that fans of the Nightmare on 9 event

9 should look for Seattlehaunts’ new location in 2020. (See id. ¶ 32.) However, Thomas 10 Family Farm advertised on its website that it would be offering a “renovated” Nightmare 11 on 9 event in 2019. (See id. ¶ 41.) Seattlehaunts alleges that Thomas Family Farm’s 12 website advertisements featured copies of the Wondell Graphic. (See id.) 13 On August 7, 2019, Seattlehaunts filed a Washington State trademark application

14 for the text “NIGHTMARE ON 9,” but the Washington Secretary of State denied the 15 application because Thomas Family Farm had already registered a trademark for Wondell 16 Graphic. (See id. ¶¶ 33-34, 42, Exs. 1, 5.3) On December 7, 2018 received a trademark 17 registration for the following trademark: THE WORDS “NIGHTMARE ON 9” OVER A 18 HIGHWAY SIGN. (See id. ¶ 42, Ex. 5.) On August 13, 2019, Thomas Family Farm

19 sent Seattlehaunts a demand letter alleging that Seattlehaunts was intentionally infringing 20 on Thomas Family Farm’s trademark by continuing to use it in Seattlehaunts’ advertising 21

3 The court may consider documents appended or attached to the complaint in ruling on a 22 Rule 12(b)(6) motion to dismiss. United States v. Ritchie, 342 F.3d 903, 908 (9th Cir. 2003). 1 and promotional material. (See id. ¶ 45.) Thomas Family Farm demanded payment of 2 $39,000.00 for a transfer of the trademark and registration to Seattlehaunts. (See id. ¶

3 46.) 4 On August 15, 2019, Seattlehaunts executed an agreement with Mr. Wondell in 5 which Mr. Wondell assigned his ownership interest and copyright in the Wondell 6 Graphic to Seattlehaunts. (See id. ¶¶ 37-38, Ex. 3.) The following day, Seattlehaunts 7 filed an application to register the copyright in the Wondell Graphic with the U.S. 8 Copyright Office. (See id. ¶ 39.) On August 20, 2019, the Register of Copyrights issued

9 Seattlehaunts a copyright registration with an effective date of August 16, 2019 in the 10 work titled “Nightmare on 9 Haunted House Graphics.” (See id. ¶ 39, Ex. 4.) After 11 receiving the registration, Seattlehaunts sent a response to Thomas Family Farm’s 12 demand letter that notified Thomas Family Farm that Seattlehaunts had registered the 13 copyright in the Wondell Graphic and demanded that Thomas Family Farm cease all use

14 of the intellectual property that Seattlehaunts believed it owned. (See id. ¶ 47, Ex. 6.) 15 According to Seattlehaunts, Thomas Family Farm did not stop using the Wondell 16 Graphic and instead ran a Nightmare on 9 event at the Farm in September and October 17 2019 and used the Wondell Graphic in its advertising for that event. (See id. ¶¶ 48-49.) 18 B. Procedural Background

19 On October 7, 2019, Thomas Family Farm filed a lawsuit against Seattlehaunts in 20 Snohomish County Superior Court, Thomas Family Farm, LLC v. Seattlehaunts, LLC, 21 Cause No. 19-2-09008-31 (the “State Court Action”). (See Am. Compl. ¶ 9; State Court 22 Compl.) In that lawsuit, Thomas Family Farm brings claims for state trademark 1 infringement and defamation against Seattlehaunts. (See Am. Compl. ¶ 9; State Court 2 Compl. at 5-7.) Seattlehaunts filed this lawsuit against Thomas Family Farm in this court

3 on November 26, 2019 (see Compl. (Dkt. # 1) at 17) and amended the complaint on 4 December 18, 2019 (see Am. Compl. at 21). Seattlehaunts brings claims for unregistered 5 trademark infringement and false designation or origin under the Lanham Act, 15 U.S.C 6 § 1125; Copyright Infringement under 17 U.S.C. § 101; unfair competition under the 7 Washington Consumer Protection Act, RCW ch. 19.86; declaratory judgment of 8 non-infringement; declaratory judgment of abandonment; and declaratory judgment of

9 non-disparagement. (See Am. Compl. ¶¶ 50-79.) 10 III.

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Seattlehaunts LLC v. Thomas Family Farm LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/seattlehaunts-llc-v-thomas-family-farm-llc-wawd-2020.