State of Washington v. Landmark Technology A LLC

CourtDistrict Court, W.D. Washington
DecidedJanuary 7, 2025
Docket2:21-cv-00728
StatusUnknown

This text of State of Washington v. Landmark Technology A LLC (State of Washington v. Landmark Technology A 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
State of Washington v. Landmark Technology A LLC, (W.D. Wash. 2025).

Opinion

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

8 STATE OF WASHINGTON, Case No. C21-728RSM 9 Plaintiff, 10 ORDER GRANTING PLAINTIFF’S 11 v. SECOND MOTION TO AMEND

12 LANDMARK TECHNOLOGY A, LLC, and RAYMOND MERCADO, individually, 13 Defendants. 14

15 I. INTRODUCTION 16 17 This matter comes before the Court on Plaintiff State of Washington’s Second Motion 18 to Amend Complaint, Dkt. #105. Plaintiff seeks leave to amend its First Amended Complaint 19 to: “(1) join Melody Camp and Patrick Nunally as additional defendants; (2) add allegations 20 clarifying that [Defendant] Mercado’s, Camp’s, and Nunally’s actions violating the 21 Washington Consumer Protection Act (CPA) and the Washington Patent Troll Prevention Act 22 23 (PTPA) have been an ongoing, unbroken scheme stretching back to at least 2016; and (3) add 24 allegations clarifying that Mercado’s, Camp’s, and Nunally’s [sic] undertook illegal actions 25 under the names of both Landmark Technology, LLC (LT) and LTA involving two patents…” 26 Id. at 4. Defendants oppose. Dkt. #108. No party has requested oral argument. For the 27 reasons stated below, the Court GRANTS this Motion. 28 II. BACKGROUND 1 2 The Attorney General of the State of Washington brought this action on June 2, 2021, in 3 the name of the State, or as parens patriae on behalf of persons residing in the State, to enforce 4 the provisions of the Washington Consumer Protection Act, RCW 19.86 (“CPA”) and the 5 Patent Troll Prevention Act, RCW 19.350 (“PTPA”). 6 Defendant Landmark Technology A, LLC (“LTA”) is a North Carolina patent-assertion 7 8 entity (“PAE”). The sole member of LTA is Defendant Raymond Mercado, a North Carolina 9 resident. 10 On November 14, 2022, the State of Washington moved for leave to amend its 11 Complaint to add Mr. Mercado as a defendant. Dkt. #36. The Court granted that Motion. Dkt. 12 13 #41. A trial date was set and discovery proceeded. 14 Discovery has not gone well. After conducting a status conference, discovery issues 15 were referred to Magistrate Judge Fricke and the trial date has been stricken. See Dkts. #106 16 and #107. This case currently has no trial date. 17 Plaintiff contends that “[a]fter the close of discovery, and only in response to Plaintiff 18 19 State of Washington’s motion to compel, Defendants… produced tens of thousands of 20 previously undisclosed documents…. reveal[ing] that Defendants, together with two 21 individuals sought to be joined, collaborated on an uninterrupted scheme to engage in bad faith 22 patent assertion for much longer and on a wider scale than previously known.” Dkt. #105 at 4. 23 Plaintiff’s proposed amended complaint states that proposed Defendant Melody Camp 24 25 used databases to create a list of targeted companies. Dkt. #105-1 at 11. Camp then sent the 26 initial list of potential target companies to proposed Defendant Nunally, who performed a 27 check on the companies’ websites to determine whether or not to proceed. Id. at 12. 28 However, the proposed complaint also alleges that Camp participated with Defendant 1 2 Mercado in drafting or discussing a “Business Plan” that set the financial goals of the company 3 and served as a blueprint for Defendants’ bad faith patent assertion activities. Dkt. #105-1 at 9. 4 The Business Plan makes clear that Mercado, Nunally, and Camp were paid a total of $20,000 5 a month. Id. at 10. Subsequent emails indicate that this Business Plan continued into the 6 future, including LTA’s alleged activities at issue in this case. The proposed complaint also 7 8 alleges that Camp and Nunally and actually “sent” out demand letters to certain targeted 9 companies. Id. at 14. 10 III. DISCUSSION 11 A. Legal Standard 12 13 Pursuant to Fed. R. Civ. P. 15(a)(2), a “court should freely give leave [to amend] when 14 justice so requires,” Fed. R. Civ. P. 15(a)(2). Courts apply this policy with “extreme 15 liberality.” Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048, 1051 (9th Cir. 2003). Five 16 factors are commonly used to assess the propriety of granting leave to amend: (1) bad faith, (2) 17 undue delay, (3) prejudice to the opposing party, (4) futility of amendment, and (5) whether 18 19 plaintiff has previously amended the complaint. Allen v. City of Beverly Hills, 911 F.2d 367, 20 373 (9th Cir. 1990); Foman v. Davis, 371 U.S. 178, 182 (1962). In conducting this five-factor 21 analysis, the court must grant all inferences in favor of allowing amendment. Griggs v. Pace 22 Am. Group, Inc., 170 F.3d 877, 880 (9th Cir. 1999). In addition, the court must be mindful of 23 the fact that, for each of these factors, the party opposing amendment has the burden of 24 25 showing that amendment is not warranted. DCD Programs, Ltd. v. Leighton, 833 F.2d 183, 26 187 (9th Cir. 1987); see also Richardson v. United States, 841 F.2d 993, 999 (9th Cir. 1988). 27 28 A scheduling order “may be modified only for good cause and with the judge’s 1 2 consent.” Fed. R. Civ. P. 16(b)(4). The decision to modify a scheduling order is within the 3 broad discretion of the district court. Johnson, 975 F.2d at 607. “Rule 16(b)’s ‘good cause’ 4 standard primarily considers the diligence of the party seeking amendment.” Id. at 609. If a 5 party has acted diligently yet still cannot reasonably meet the scheduling deadlines, the court 6 may allow modification of the schedule. Id. However, “if that party was not diligent, the 7 8 inquiry should end” and the motion to modify should not be granted. Id. Local Civil Rule 9 16(m) states that “this rule will be strictly enforced” in order to “accomplish effective pretrial 10 procedures and avoid wasting the time of the parties, counsel, and the court.” While prejudice 11 to the party opposing the modification may provide additional reasons for denying the motion, it 12 13 is not required to deny a motion to amend under Rule 16(b). Coleman v. Quaker Oats Co., 232 14 F.3d 1271, 1295 (9th Cir. 2000). 15 B. Analysis 16 Typically, when a case is this far along the Court would look at diligence under Rule 16 17 because amending the complaint would require amending the scheduling order. Here, the trial 18 19 date has been stricken and discovery sent to a magistrate judge, largely due to the actions of 20 Defendants. There is no scheduling order to modify. In that sense, the proper legal standard 21 for this Motion is under Rule 15(a)(2).1 22 The Court finds that Plaintiff’s amendment is not made in bad faith, given the unusual 23 circumstances of this case. The Court believes there is some evidence of undue delay as these 24 25 proposed additional defendants were known to Plaintiff from early on in this case, however it is 26 undeniable that the extent of their involvement was not revealed until the late document dump. 27 1 The Court notes that it would still grant this Motion even under the more stringent Rule 16 diligence standard.

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State of Washington v. Landmark Technology A LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-landmark-technology-a-llc-wawd-2025.