Snow Joe, LLC v. Linemart Inc.

CourtDistrict Court, C.D. California
DecidedJuly 18, 2022
Docket2:20-cv-00587
StatusUnknown

This text of Snow Joe, LLC v. Linemart Inc. (Snow Joe, LLC v. Linemart Inc.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Snow Joe, LLC v. Linemart Inc., (C.D. Cal. 2022).

Opinion

Case 2:20-cv-00587-RSWL-RAO Document 60 Filed 07/18/22 Page 1 of 21 Page ID #:574 'O' 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 CV20-00587-RSWL-RAOx 11 SNOW JOE, LLC, ORDER re: Plaintiff’s 12 Plaintiff, Motion for Contempt and 13 v. Enforcement of Settlement [55] 14 LINEMART INC., et al., 15 Defendants. 16 17 18 Plaintiff Snow Joe, LLC (“Plaintiff”) brought the 19 instant Action against Defendants Linemart, Inc.; 20 Linemart NJ, Inc.; Shenzhen Sailvan Network Technology 21 Ltd.; and Shenzhen Sailvan Ecommerce Co., Ltd. 22 (collectively, “Defendants”) alleging: (1) direct and 23 contributory false advertising under 15 U.S.C. 24 § 1125(a)(1)(B); and (2) violations of California 25 Business and Professions Codes §§ 17200 and 17500. 26 Currently before the Court is Plaintiff’s Motion for 27 Contempt and Enforcement of Settlement [55] (“Motion”). 28 Having reviewed all papers submitted pertaining to this 1 Case 2:20-cv-00587-RSWL-RAO Document 60 Filed 07/18/22 Page 2 of 21 Page ID #:575

1 Motion, the Court NOW FINDS AND RULES AS FOLLOWS: the

2 Court GRANTS IN PART and DENIES IN PART Plaintiff’s

3 Motion. 4 I. BACKGROUND 5 A. Factual Background 6 1. Plaintiff’s Underlying Complaint 7 Plaintiff sells pressure washers online, including 8 through Amazon.com (“Amazon”). Compl. ¶¶ 14-16, 21, ECF 9 No. 1. Defendants sell electric pressure washers that 10 directly compete with Plaintiff’s. Id. ¶ 22. 11 Plaintiff’s Complaint alleged that Defendants falsely 12 advertised their pressure washers’ Pounds Per Square 13 Inch (“PSI”) pressure ratings and adherence to European 14 Conformity (“CE”) safety standards. Id. ¶¶ 26-28. 15 2. Parties’ Settlement and Injunction Order 16 On November 7, 2021, Plaintiff and Defendants 17 entered into a Settlement Agreement (the “Original 18 Agreement”), relating specifically to HOMDOX-branded 19 (“Homdox”) pressure washers. See generally Notice of 20 Settlement of Entire Action, ECF No. 47. The Original 21 Agreement required Defendants, inter alia, to: (1) 22 immediately submit their pressure washers for third- 23 party testing and label them according to the results; 24 (2) identify all their pressure washers, including the 25 model numbers, Amazon Standard Identification Numbers 26 (“ASINs”), and Standard Product Numbers (“SPUs”); and 27 (3) retain a third-party service to monitor and remove 28 inaccurate listings. Mot. for Contempt Ex. 1 (“Original 2 Case 2:20-cv-00587-RSWL-RAO Document 60 Filed 07/18/22 Page 3 of 21 Page ID #:576

1 Agreement”), ECF No. 55-3. Pursuant to the Original

2 Agreement, the Court entered a Permanent Injunction

3 Order (“Original Injunction”) on November 17, 2021, 4 enjoining Defendants from falsely advertising their 5 pressure washers.1 See generally Permanent Inj., ECF 6 No. 49. 7 On December 20, 2021, Plaintiff notified Defendants 8 of their breach of each provision of the Original 9 Agreement. Pl.’s Mem. of P. & A. (“Mot.”) 3:11-16, ECF 10 No. 55. The parties then entered into an Amended 11 Settlement Agreement (“Amended Agreement”) on February 12 17, 2022.2 Id. at 3:18-22. Accordingly, on February 13 18, 2022, the Court entered an Amended Permanent 14 Injunction Order (“Amended Injunction”). See generally 15 Am. Permanent Inj., ECF No. 54. 16 On February 28, 2022, Plaintiff sent Defendants 17 another notice of breach of the Amended Agreement.3

18 1 The Original Injunction also expressly retained jurisdiction over the matter to enforce the terms of the Original 19 Agreement. Permanent Inj. 2:25-3:2. 20 2 The Amended Agreement expanded the scope of the Original Agreement to include Defendants’ MRLIANCE-, SYNCLL-, and TEANDE- 21 branded pressure washers, and it also added a provision allowing 22 for recovery of attorneys’ fees for the enforcement of the agreement. Decl. of Christopher Q. Pham in Supp. of Mot. (“Pham 23 Decl.”) Ex. 2 ¶ 5, ECF No. 55-4. It further provided that any terms in the Original Agreement not modified by the Amended 24 Agreement remain in full force. Id. 25 3 Also on February 28, 2022, Defendants provided Plaintiff with a declaration identifying the model numbers, ASINs, and SPUs 26 for all of Defendants’ pressure washers, as well as Defendants’ Amazon account names, as required by the Settlement Agreements. 27 Mot. 4:13-23. The same day, Defendants submitted five Homdox pressure washers for testing; the testing results were not 28 completed until March 31, 2022. Id. at 5:5-11. 3 Case 2:20-cv-00587-RSWL-RAO Document 60 Filed 07/18/22 Page 4 of 21 Page ID #:577

1 Mot. Ex. 6, ECF No. 55-9. On March 10, 2022, Plaintiff

2 captured evidence of three Amazon listings for pressure

3 washers under Defendants’ accounts advertising false PSI 4 claims. Mot. 8:7-11. The parties then engaged in meet- 5 and-confer sessions on March 11, March 21, and April 13, 6 2022. Id. at 4:6-9. Later, on April 19, 2022, 7 Plaintiff purchased a pressure washer from one of 8 Defendants’ confirmed Amazon listings that also 9 contained false PSI claims. Id. at 9:21-10:28. The 10 parties then held a fourth meet-and-confer session on 11 April 27, 2022. Id. at 4:6-9. 12 B. Procedural Background 13 Plaintiff filed the instant Motion [55] on April 14 28, 2022. Defendants filed their Opposition [56] on May 15 9, 2022, and Plaintiff replied [58] on May 16, 2022. 16 II. DISCUSSION 17 A. Legal Standard 18 “[C]ourts have inherent power to enforce compliance 19 with their lawful orders through civil contempt.” 20 Spallone v. United States, 493 U.S. 265, 276 (1990); 21 Shillitani v. United States, 384 U.S. 364, 370 (1966). 22 Civil contempt consists of a party’s disobedience to a 23 specific and definite court order by failure to take all 24 reasonable steps within the party’s power to comply. In 25 re Dual-Deck Video Cassette Recorder Antitrust Litig., 26 10 F.3d 693, 695 (9th Cir. 1993). “The moving party has 27 the burden of showing by clear and convincing evidence 28 that the contemnors violated a specific and definite 4 Case 2:20-cv-00587-RSWL-RAO Document 60 Filed 07/18/22 Page 5 of 21 Page ID #:578

1 order of the court. The burden then shifts to the

2 contemnors to demonstrate why they were unable to

3 comply.” Stone v. City & County of San Francisco, 968 4 F.2d 850, 856 n.9 (9th Cir. 1992) (citations omitted). 5 A person should not be held in contempt if his 6 action “appears to be based on a good faith and 7 reasonable interpretation of the [court's order].” 8 Vertex Distrib., Inc. v. Falcon Foam Plastics, Inc., 689 9 F.2d 885, 889 (9th Cir. 1982). Nevertheless, “there is 10 no good faith exception to the requirement of obedience 11 to a court order.” In re Dual-Deck, 10 F.3d at 695. 12 “[C]ivil contempt may be established even though the 13 failure to comply with the court order was 14 unintentional.” Perry v. O’Donnell, 759 F.2d 702, 705 15 (9th Cir. 1985). A showing of willfulness is not a 16 necessary element for civil contempt because while the 17 purpose of criminal contempt is punishment, the purpose 18 of civil contempt is remedial. Id. 19 B. Analysis 20 1. Evidentiary Objections 21 Plaintiff objects to the Declaration of XiaoShuang 22 Zheng in Opposition to the Motion for Contempt and 23 Enforcement of Settlement (“Zheng Declaration”), along 24 with its accompanying exhibits. See generally Evid. 25 Objs. to Zheng Decl. and Exs. 1-33, ECF No. 57.

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Snow Joe, LLC v. Linemart Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/snow-joe-llc-v-linemart-inc-cacd-2022.