Spy Optic Inc. v. AreaTrend, LLC

CourtDistrict Court, S.D. California
DecidedApril 13, 2020
Docket3:19-cv-01770
StatusUnknown

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

Bluebook
Spy Optic Inc. v. AreaTrend, LLC, (S.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 SPY OPTIC INC., a California Case No.: 3:19-cv-01770-WQH-BLM Corporation, 12 ORDER Plaintiff, 13 v. 14 AREATREND, LLC, an Ohio 15 Limited Liability Company; and DOES 1-10, 16 Defendants. 17 18 HAYES, Judge: 19 The matter pending before the Court is the Motion to Dismiss filed by Defendant 20 AreaTrend, LLC (ECF No. 7). 21 PROCEDURAL BACKGROUND 22 On September 16, 2019, Plaintiff Spy Optic Inc. (“Spy Optic”) initiated this action 23 by filing a Complaint against Defendant AreaTrend, LLC (“AreaTrend”) for (1) federal 24 trademark infringement and counterfeiting; (2) federal false designation of origin; (3) 25 tortious interference with existing contractual relations; (4) California common law 26 trademark infringement; (5) California common law unfair competition; and (6) California 27 statutory unfair competition. (ECF No. 1). On October 24, 2019, Defendant filed a Motion 28 to Dismiss for lack of personal jurisdiction. (ECF No. 7). On November 18, 2019, Plaintiff 1 filed a Response in opposition. (ECF No. 12). On November 19, 2019, Plaintiff filed a 2 Supplemental Declaration in opposition. (ECF No. 13). On November 25, 2019, 3 Defendant filed a Reply. (ECF No. 14). 4 ALLEGATIONS OF THE COMPLAINT 5 Plaintiff engages “in the extensive development, advertising, and marketing of 6 sunglasses, sunglass products, wearing apparel and sporting goods.” (ECF No. 1 at 3). 7 Plaintiff “uses and has used the trademarks ‘SPY’, ‘SPY OPTIC’ and a cross logo, among 8 others, in connection with its goods and/or services” (collectively, “Spy Marks”). Id. The 9 Spy Marks “are valid, subsisting, in full force and effect, and are incontestable pursuant to 10 15 U.S.C. § 1065.” Id. at 4. Plaintiff has “continuously used the S[py] Marks in interstate 11 commerce in connection with the sale, distribution, promotion, and advertising of genuine 12 Spy Optic® products since their respective dates of first use.” Id. “The Spy Marks have 13 never been abandoned.” Id. Plaintiff has “expended substantial time, money, and other 14 resources in developing, advertising, and otherwise promoting the Spy Marks.” Id. The 15 Spy Marks “are widely recognized and exclusively associated by consumers, the public, 16 and the trade as being high-quality products sourced from Spy Optic.” Id. The Spy Marks 17 “have achieved secondary meaning as an identifier of high-quality sunglasses, sunglass 18 products, apparel, and sporting goods.” Id. The Spy Marks “have come to symbolize the 19 enormous goodwill of Spy Optic and its products throughout the United States and the 20 world.” Id. “No other manufacturer lawfully uses the Spy Marks or any marks 21 substantially similar to them in connection with similar types of goods.” Id. Plaintiff 22 “suffers irreparable harm to its goodwill as well as a direct monetary loss any time any 23 third parties, including Defendant, sell counterfeit and infringing goods bearing trademarks 24 identical or substantially indistinguishable from Spy Marks.” Id. 25 “Defendant is an online retailer of various brand-name products including clothing, 26 accessories, and home décor via its website, www.areatrend.com ….” Id. at 5. “Defendant 27 has purchased, advertised, offered for sale, and/or sold eyewear bearing the Spy Marks” on 28 its website, despite not being “an authorized retailer of Spy Optic® branded goods.” Id. 1 [I]t is reasonable to conclude that these goods are either counterfeit, infringing, obtained from entities who are prohibited from selling said goods 2 to Defendant pursuant to the contractual relationship they have with Plaintiff 3 regarding the distribution of goods as described above, or a combination thereof. 4

5 Id. Defendant has “received actual notice to cease and desist from its improper acquisition 6 and deceptive promotion and sale of products bearing the Spy Marks ….” Id. at 5-6. 7 Defendant continues to “wrongfully purchase, advertise, promote, offer for sale, and/or 8 sell” eyewear bearing the Spy Optics trademarks “on its website.” Id. at 6. 9 STANDARD OF REVIEW 10 Under Federal Rule of Civil Procedure 12(b)(2), a defendant may move to dismiss a 11 complaint for lack of personal jurisdiction. See Fed. R. Civ. P. 12(b)(2). In opposing a 12 defendant’s Rule 12(b)(2) motion, “the plaintiff bears the burden of establishing that 13 jurisdiction is proper.” Boschetto v. Hansing, 539 F.3d 1011, 1015 (9th Cir. 2008) (citation 14 omitted). Where the court considers the motion without holding an evidentiary hearing, 15 “the plaintiff need only make a prima facie showing of jurisdictional facts to withstand the 16 motion to dismiss.” Mavrix Photo, Inc. v. Brand Techs., Inc., 647 F.3d 1218, 1223 (9th 17 Cir. 2011) (citing Brayton Purcell LLP v. Recordon & Recordon, 606 F.3d 1124, 1127 (9th 18 Cir. 2010), abrogated on other grounds as recognized by Axiom Foods, Inc. v. Acerchem 19 Int’l, Inc., 874 F.3d 1064 (9th Cir. 2017)). “The plaintiff cannot ‘simply rest on the bare 20 allegations of its complaint,’ but uncontroverted allegations in the complaint must be taken 21 as true.” Id. (quoting Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797, 800 (9th 22 Cir. 2004)). “[W]e may not assume the truth of allegations in a pleading which are 23 contradicted by affidavit ... but we resolve factual disputes in the plaintiff’s favor.” Id. 24 (alteration in original) (internal quotation marks, quotation, and citation omitted). In other 25 words, “the plaintiff need only demonstrate facts that if true would support jurisdiction 26 over the defendant.” Ballard v. Savage, 65 F.3d 1495, 1498 (9th Cir. 1995) (citation 27 omitted). 28 1 CONTENTIONS OF THE PARTIES 2 Defendant contends that Plaintiff’s Complaint should be dismissed for lack of 3 personal jurisdiction. Defendant contends that the maintenance of an interactive website 4 is insufficient to support general jurisdiction over a foreign defendant. Defendant asserts 5 that it has no employees or offices in California. Defendant asserts that it derives a trivial 6 amount of sales from California. Defendant contends that this Court lacks specific 7 jurisdiction. Defendant contends that it has not purposefully directed activities at 8 California or purposefully availed itself of the privilege of conducting activities in 9 California. Defendant contends that it has no California contacts that could be the but-for 10 cause of Plaintiff’s alleged injury. Defendant contends that the exercise of jurisdiction in 11 California would be constitutionally unreasonable. 12 Plaintiff contends that there is general jurisdiction over Defendant because 13 Defendant operates a highly interactive website through which California consumers can 14 purchase products. Plaintiff contends that there is specific jurisdiction over Defendant. 15 Plaintiff contends that the highly commercial nature of Defendant’s website constitutes 16 purposeful availment. In the alternative, Plaintiff contends that the purposeful availment 17 element is satisfied based on Defendant’s tortious conduct directed at the forum.

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Bluebook (online)
Spy Optic Inc. v. AreaTrend, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spy-optic-inc-v-areatrend-llc-casd-2020.