Tari Labs, LLC v. Lightning Labs, Inc.

CourtDistrict Court, N.D. California
DecidedMarch 13, 2023
Docket3:22-cv-07789
StatusUnknown

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

Bluebook
Tari Labs, LLC v. Lightning Labs, Inc., (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 TARI LABS, LLC, Case No. 3:22-cv-07789-WHO

8 Plaintiff, ORDER ENTERING TEMPORARY 9 v. RESTRAINING ORDER

10 LIGHTNING LABS, INC., Re: Dkt. No. 25 Defendant. 11

12 13 Tari Labs, LLC, brings this motion for a temporary restraining order (“TRO”) against 14 Lightning Labs, Inc., seeking to temporarily restrain Lightning’s use of the name “TARO” for its 15 protocol because it infringes Tari’s trademark for the “TARI” protocol. Both are blockchain- 16 based software protocols used to create and transfer digital assets, and both companies market 17 their protocols to similar software developer customers. Although Tari purports to make 18 consumer-facing products itself while Lightning creates the protocol so outside developers can 19 make consumer-facing products, those retail products seem to overlap both in use and in customer 20 bases, and so the similar names and marks are likely to confuse customers. For those and the 21 following reasons, on this record I find Tari is likely to succeed on the merits, has shown 22 likelihood of irreparable harm, and shows the balance of equities and public interest favor a TRO. 23 BACKGROUND 24 I. FACTUAL BACKGROUND 25 Tari alleges in this trademark infringement lawsuit that Lightning’s use of the name 26 “TARO” for its blockchain-based “protocol” infringes Tari’s trademark for its “platform” of 27 blockchain and cryptocurrency-related products, including its own blockchain-based protocol, 1 “TARI.”1 2 The “TARI protocol” is an “open-source” software based on blockchain technology that 3 “enables users to create and transfer digital assets.” Declaration of Naveen Jain (“Jain Decl.”) 4 [Dkt. No. 28] ¶ 1. The protocol was initially launched in April 2020 by a team of individuals 5 experienced in cryptocurrency and startups. Id. ¶¶ 9-10. Though still in its development, the 6 TARI protocol will allow users to transfer many kinds of digital assets, “including stablecoins, 7 non-fungible tokens (NFTs), tickets, in-app purchases on mobile devices, loyalty points, and other 8 assets.” Id. ¶ 2. Tari targets developers for the use and development of the protocol itself, and 9 also targets retail consumers with other products and services from its TARI platform, that use or 10 work with the Tari protocol. Id. ¶¶ 2-4. Its products currently include a “Tari wallet” and “Tari 11 tokens,” though it plans to expand. See id. ¶¶ 4-6. Tari and the TARI protocol have been featured 12 by various news sources and have been marketed to consumers, and Tari has a moderate social 13 media following. Id. ¶¶ 10-12. 14 The TARO protocol was developed after the Bitcoin blockchain was updated in late 2021 15 with functionality called “Taproot,” which allows for more types of transactions to take place on 16 that blockchain.2 Declaration of JP Singh (“Singh Decl.”) [Dkt. No. 38] ¶ 30; Declaration of 17 Olaoluwa Osuntokon (“Osuntokon Decl.”) [Dkt. No. 36] ¶¶ 15-17. In response to this 18 development, Lightning—which builds tools intended for developers to use to build consumer- 19 facing applications—announced in April 2022 the “TARO protocol,” which is built using the 20 Taproot functionality. Jain Decl. ¶¶ 27-29, 31. The TARO protocol is intended to be used to issue 21 and transfer digital assets over the blockchain. Id. ¶¶ 31-33. Lightning says the TARO protocol 22 1 The trademark is for: 23 Cryptocurrency trading and exchange services, namely, providing a digital 24 currency or digital token for use by members of an on-line community via a global computer network; cryptocurrency trading and exchange services, namely, 25 providing a digital currency or digital token, incorporating cryptographic protocols, used to operate and build applications and blockchains on a decentralized computer 26 platform and as a method of payment for goods and services and as a method of transfer of digital assets. 27 Declaration of Naveen Jain (“Jain Decl.”) [Dkt. No. 28] Ex. 8. 1 was named as such because one founder liked the name, because another founder was Nigerian 2 and ate taro as a child,3 and because “taproot” and “taro” are related. Declaration of Elizabeth 3 Stark (“Stark Decl.”) [Dkt. No. 39] ¶ 39; Osuntokon Decl. ¶¶ 21, 25. 4 Concerned that that TARO protocol would operate in the same product area and confuse 5 customers with its name choice, Tari executives reached out to Lightning executives several times 6 throughout 2022, alerting them to the TARO trademark and concerns about consumer confusion 7 and asking for a name change. See Stark Decl. Ex. 16; Declaration of J. Noah Hagey (“Hagey 8 Decl.”) [Dkt. No. 26]; Supplemental Declaration of Naveen Jain (“Jain Supp. Decl.”) [Dkt. No. 9 45] Ex. 1. Tari contends that the TARI and TARO protocols directly compete by selling their 10 products and by seeking feedback from similar developers. See Jain Decl. ¶¶ 20-23. Tari asserts 11 that both companies use the same marketing channels, media and technology platforms, and 12 industry press publications. Id. ¶¶ 24-26. Tari also says that Lightning’s TARO protocol is 13 receiving increased press attention, in part due to recent “Community Calls” Lightning has held to 14 promote the product. Id. ¶¶ 28-30. 15 Lightning ignored or denied the accusations throughout 2022, see Stark Decl. Ex. 16; 16 Hagey Decl.; Jain Supp. Decl. Ex. 1, and in September, it publicly released its open-source 17 “TARO protocol.”4 Singh Decl. ¶ 33. In December 2022, Tari sued for trademark infringement. 18 [Dkt. No. 1]. 19 Tari now asserts that on February 5, 2023, Lightning’s Chief Technology Officer 20 announced that a new version of the TARO protocol would be released within a month. See Jain 21 Decl. ¶ 32. Tari says that the following day, another Lightning executive stated that this newest 22 version of the TARO protocol would have “just about everything needed to fully get off the 23 ground.” Id. ¶ 3; see also id. Ex. 27. Concerned this impending “launch” would immediately 24 harm its brand, reputation, and business, Tari filed the present motion for a temporary restraining 25 order (“TRO”). 26 3 See also infra n.11. 27 II. PROCEDURAL BACKGROUND 1 Tari filed its complaint on December 8, 2022. [Dkt. No. 1]. Lightning answered on 2 February 7, 2023. [Dkt. No. 24]. On February 21, 2023, Tari filed its TRO, (“Mot.”) [Dkt. No. 3 25], along with nearly 500 pages of exhibits, [Dkt. Nos. 26, 27, 28]. I held a short hearing to set a 4 briefing schedule and issued an order maintaining the status quo. [Dkt. Nos. 32, 34]. Lightning 5 filed its opposition on February 27, 2023, (“Oppo.”) [Dkt. No. 35], along with nearly 700 pages of 6 exhibits, [Dkt. Nos. 36, 37, 38]. Tari replied on March 2, 2023, (“Repl.”) [Dkt. No. 435], with 7 over 150 pages of exhibits, [Dkt. Nos. 43, 44, 45]. I order Lightning to file a sur-reply specifically 8 addressing the new evidence raised by Tari in its reply concerning the “Taro Wallet,” which 9 Lightning did. (“Surrepl.”) [Dkt. No. 48]. I held a hearing on March 8, 2023, at which counsel 10 for both parties appeared. 11 LEGAL STANDARD 12 Federal Rule of Civil Procedure 65 governs preliminary injunctions and temporary 13 restraining orders. Fed. R. Civ. Proc. 65. The standard for both forms of relief is the same. See 14 Stulhbarg Int’l Sales Co. v. John D. Brush & Co., 240 F.3d 832, 839 n.7 (9th Cir. 2001). 15 A preliminary injunction may be issued if a plaintiff establishes: (1) likelihood of success 16 on the merits; (2) likelihood of irreparable harm in the absence of preliminary relief; (3) that the 17 balance of equities tips in his favor; and (4) that an injunction is in the public interest. See Winter 18 v. Nat. Res. Def.

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Tari Labs, LLC v. Lightning Labs, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/tari-labs-llc-v-lightning-labs-inc-cand-2023.