Signature Auto Group, Inc. v. REV Recreation Group, Inc.

CourtDistrict Court, D. Nevada
DecidedSeptember 29, 2022
Docket2:21-cv-01996
StatusUnknown

This text of Signature Auto Group, Inc. v. REV Recreation Group, Inc. (Signature Auto Group, Inc. v. REV Recreation Group, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Signature Auto Group, Inc. v. REV Recreation Group, Inc., (D. Nev. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 * * *

7 SIGNATURE AUTO GROUP, INC., Case No. 2:21-CV-1996 JCM (DJA)

8 Plaintiff(s), ORDER

9 v.

10 REV RECREATION GROUP, INC.,

11 Defendant(s).

12 13 Presently before the court is REV Recreation Group, Inc., d/b/a Midwest Automotive 14 Designs’s (“defendant”) motion to dismiss. (ECF No. 22). Signature Auto Group, Inc. 15 (“plaintiff”), filed a response. (ECF No. 25). Defendant replied. (ECF No. 26). 16 I. BACKGROUND 17 Defendant is incorporated in Delaware and has its principal place of business in Elkhart, 18 19 Indiana. (ECF No. 22-1 at 2). It makes and sells various luxury sprinter van models, including 20 the “Signature Sprinter” van model at issue in this case. (ECF No. 1). Plaintiff brought this suit 21 alleging defendant’s use of the word “Signature” to promote its own vehicle customization 22 services violated plaintiff’s trademark rights in the word Signature. (Id.). 23 Defendant owns and operates a website that promotes and advertises defendant’s sprinter 24 25 vans to a nationwide audience. (Id.). The website features a link to the website of Van City RV, 26 a third party that sells and advertises defendant’s products in Las Vegas, Nevada, and other cities 27 across the country. (Id.). Though Van City RV of Las Vegas is an authorized dealer of 28 1 defendant’s products and sells some of defendant’s vans in Nevada, there is no evidence that Van 2 City has any Signature Sprinter model vans in its Nevada inventory. (See ECF Nos. 1; 22-4). 3 Plaintiff holds a registered trademark for the word “Signature” in connection with 4 aftermarket customization of vehicles. (ECF No. 1). In June 2021, after becoming aware of 5 6 defendant’s use of “Signature” in connection with its vans, plaintiff sent a cease-and-desist letter 7 to defendant regarding its use of “Signature.” (Id.). Plaintiff then filed the instant suit. (Id.). 8 Defendant now moves to dismiss the complaint for lack of personal jurisdiction. (ECF No. 22). 9 II. LEGAL STANDARD 10 Federal Rule of Civil Procedure 12(b)(2) allows a defendant to move to dismiss a 11 12 complaint for lack of personal jurisdiction. See Fed. R. Civ. P. 12(b)(2). To avoid dismissal 13 under Rule 12(b)(2), a plaintiff bears the burden of demonstrating that its allegations establish a 14 prima facie case for personal jurisdiction. See Boschetto v. Hansing, 539 F.3d 1011, 1015 (9th 15 Cir. 2008). Allegations in the complaint must be taken as true, and factual disputes should be 16 construed in the plaintiff’s favor. Rio Props., Inc. v. Rio Int’l Interlink, 284 F.3d 1007, 1019 (9th 17 18 Cir. 2002). 19 Personal jurisdiction is a two-prong analysis. First, an assertion of personal jurisdiction 20 must comport with due process. See Wash. Shoe Co. v. A-Z Sporting Goods Inc., 704 F.3d 668, 21 672 (9th Cir. 2012). “When no federal statute governs personal jurisdiction, the district court 22 applies the law of the forum state.” Boschetto, 539 F.3d at 1015; see also Panavision Int’l L.P. 23 24 v. Toeppen, 141 F.3d 1316, 1320 (9th Cir. 1998). However, Nevada’s “long-arm” statute applies 25 to the full extent permitted by the due process clause, so the inquiry is the same, and the court 26 need only address federal due process standards. See Arbella Mut. Ins. Co. v. Eighth Jud. Dist. 27 28 1 Ct., 134 P.3d 710, 712 (Nev. 2006) (citing Nev. Rev. Stat. § 14.065); see also Boschetto, 539 2 F.3d at 1015. 3 Two categories of personal jurisdiction exist: (1) general jurisdiction and (2) specific 4 jurisdiction. See Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 413–15 5 6 (1984); see also LSI Indus., Inc. v. Hubbell Lighting, Inc., 232 F.3d 1369, 1375 (Fed. Cir. 2000). 7 A. General Jurisdiction 8 “[T]he place of incorporation and principal place of business are paradigm bases for 9 general jurisdiction.” Daimler AG v. Bauman, 571 U.S. 117, 137 (2014) (quotation marks and 10 citation omitted). A court may also assert general jurisdiction over a defendant when the 11 12 plaintiff shows that “the defendant has sufficient contacts that approximate physical presence.” 13 In re W. States Wholesale Nat. Gas Litig., 605 F. Supp. 2d 1118, 1131 (D. Nev. 2009) (internal 14 quotation marks and citations omitted). In other words, the defendant’s affiliations with the 15 forum state must be so “continuous and systematic” as to render the defendant essentially “at 16 home” in that forum. See Daimler AG, 571 U.S. at 137. General jurisdiction is appropriate even 17 18 if the defendant’s continuous and systematic ties to the forum state are unrelated to the litigation. 19 See Tuazon v. R.J. Reynolds Tobacco Co., 433 F.3d 1163, 1171 (9th Cir. 2006) (citing 20 Helicopteros Nacionales de Colombia, S.A., 466 U.S. at 414–16). 21 B. Specific Jurisdiction 22 The Ninth Circuit has established a three-prong test for analyzing specific personal 23 24 jurisdiction: 25 (1) The non-resident defendant must purposefully direct his activities or consummate some transaction with the forum or 26 resident thereof; or perform some act by which he purposefully avails himself of the privilege of conducting activities in the 27 forum, thereby invoking the benefits and protections of its laws; 28 1 (2) the claim must be one which arises out of or relates to the defendant’s forum-related activities; and 2

3 (3) the exercise of jurisdiction must comport with fair play and 4 substantial justice, i.e., it must be reasonable. 5 Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797, 802 (9th Cir. 2004). 6 Under the first prong, the Ninth Circuit treats purposeful availment and purposeful 7 direction as separate methods of analysis. Wash. Shoe Co., 704 F.3d at 672. Purposeful 8 9 availment is for suits sounding in contract, whereas purposeful direction is for suits sounding in 10 tort. Schwarzenegger, 374 F.3d at 802 (citing Dole Food Co. v. Watts, 303 F.3d 1104, 1111 (9th 11 Cir. 2002)). Because plaintiff has alleged trademark infringement, a tort-like cause of action, 12 purposeful direction is the proper analytical framework. See AMA Multimedia, LLC v. Wanat, 13 970 F.3d 1201, 1208 (9th Cir. 2020). 14 15 Purposeful direction is evaluated under the three-part “effects” test. See Calder v. Jones, 16 465 U.S. 783, 104 (1984).

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Related

Calder v. Jones
465 U.S. 783 (Supreme Court, 1984)
Helicopteros Nacionales De Colombia, S. A. v. Hall
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374 F.3d 15 (First Circuit, 2004)
Lsi Industries Inc. v. Hubbell Lighting, Inc.
232 F.3d 1369 (Federal Circuit, 2000)
Washington Shoe Company v. A-Z Sporting Goods Inc
704 F.3d 668 (Ninth Circuit, 2012)
Boschetto v. Hansing
539 F.3d 1011 (Ninth Circuit, 2008)
Zippo Manufacturing Co. v. Zippo Dot Com, Inc.
952 F. Supp. 1119 (W.D. Pennsylvania, 1997)
In Re Western States Wholesale Natural Gas Litig.
605 F. Supp. 2d 1118 (D. Nevada, 2009)
Medinah Mining, Inc. v. Amunategui
237 F. Supp. 2d 1132 (D. Nevada, 2002)
Daimler AG v. Bauman
134 S. Ct. 746 (Supreme Court, 2014)
Walden v. Fiore
134 S. Ct. 1115 (Supreme Court, 2014)
Ama Multimedia, LLC v. Marcin Wanat
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Bluebook (online)
Signature Auto Group, Inc. v. REV Recreation Group, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/signature-auto-group-inc-v-rev-recreation-group-inc-nvd-2022.