Vinh-Sanh Trading Corporation v. SFTC, Inc.

CourtDistrict Court, N.D. California
DecidedNovember 22, 2019
Docket3:19-cv-04315
StatusUnknown

This text of Vinh-Sanh Trading Corporation v. SFTC, Inc. (Vinh-Sanh Trading Corporation v. SFTC, 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
Vinh-Sanh Trading Corporation v. SFTC, Inc., (N.D. Cal. 2019).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 VINH-SANH TRADING Case No. 19-CV-04315-CRB CORPORATION, a California 9 Corporation

10 Plaintiff, ORDER DENYING PRELIMINARY INJUNCTION 11 v.

12 SFTC, INC., D.B.A. SUN FAT TRADING CORPORATION, a 13 California Corporation, 14 Defendant.

15 Now pending is Plaintiff Vinh-Sanh Trading Corporation’s (“Vinh-Sanh”) motion 16 for a preliminary injunction against Defendant SFTC, Inc. (“Sun Fat”). See MPI (dkt. 39) 17 at 1–2. Vinh-Sanh seeks to enjoin Sun Fat from further using allegedly infringing marks in 18 its sale of Thai jasmine rice. Id. The Court DENIES the preliminary injunction for the 19 reasons below. 20 I. BACKGROUND 21 Vinh-Sanh imports and distributes rice and rice-based products. Compl. (dkt. 1) ¶ 22 9. Its most popular product is Thai jasmine rice, which it sells throughout the United 23 States. Id. ¶¶ 10, 12. In the mid-1980s, Vinh-Sanh established the THREE LADIES 24 brand, and developed a trademark consisting of a drawing of three women wearing 25 clothing representing the countries of Cambodia, Vietnam, and Laos. Id. ¶ 11. Vinh-Sanh 26 has four trademarks in connection with the THREE LADIES brand. See Compl. ¶ 13; 27 TRO App. (dkt. 11) at 4. 1 22. Vinh-Sanh works with a variety of distributors and briefly had a wholesale 2 relationship with Sun Fat “for the sale of a small quantity of THREE LADIES rice.” Id. 3 ¶ 23. Vinh-Sanh “terminated the relationship with Sun Fat” when it discovered that, in its 4 view, Sun Fat was infringing the THREE LADIES mark. Id. ¶ 24. Sun Fat had started 5 marketing and selling Thai jasmine rice with the images—photographs, not drawings—of 6 three women wearing what Vinh-Sanh asserts is clothing representing the countries of 7 Cambodia, Vietnam, and Laos. Id. 8 Vinh-Sanh brought suit for federal trademark infringement under 15 U.S.C. § 1114, 9 Federal Unfair Competition under 15 U.S.C. § 1125(a), Common Law Trademark 10 Infringement, and Unfair Competition under Cal. Bus. & Prof. Code § 17200. See 11 generally Compl. Vinh-Sanh applied for a temporary restraining order (TRO) on August 12 2, 2019. See generally TRO App. The Court denied the TRO. The Court concluded that 13 while Vinh-Sanh was likely to succeed on the merits, and an injunction was in the public 14 interest, Vinh-Sanh had not shown irreparable harm. See Tr. of Aug. 9, 2019 Proceedings 15 (dkt. 27) at 3:19–22. The Court gave the parties leave to conduct further discovery on 16 irreparable harm prior to briefing a preliminary injunction motion. Tr. of Aug. 9, 2019 17 Proceedings at 3:13–4:12. Vinh-Sanh subsequently filed a motion for preliminary 18 injunction. See generally MPI. Sun Fat opposed the motion. See generally MPI Opp’n 19 (dkt. 44). Vinh-Sanh replied. See generally MPI Reply (dkt. 45). 20 In its motion for preliminary injunction, Vinh-Sanh asked the Court to enjoin Sun 21 Fat from: (1) manufacturing, producing, sourcing, importing, selling or offering for sale, 22 distributing, advertising, providing, or promoting any goods or services with the allegedly 23 infringing marks; (2) using the infringing marks or any “false designation of origin, or 24 false or misleading description or representation of fact”; (3) “further infringing the rights 25 of Vinh-Sanh in and to its THREE LADIES Marks or otherwise damaging Vinh-Sanh’s 26 goodwill or business reputation”; (4) “competing unfairly with Vinh-Sanh in any manner”; 27 and (5) “continuing to perform any other unlawful acts in any manner whatsoever II. LEGAL STANDARD 1 “A plaintiff seeking a preliminary injunction must establish that he is likely to 2 succeed on the merits, that he is likely to suffer irreparable harm in the absence of 3 preliminary relief, that the balance of equities tips in his favor, and that an injunction is in 4 the public interest.” Rodriguez v. Robbins, 715 F.3d 1127, 1133 (9th Cir. 2013) (quoting 5 Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 20 (2008)). The Ninth Circuit 6 allows a “sliding scale approach,” such that if the plaintiff can show “serious questions 7 going to the merits,” that a balance of hardships tips sharply toward the plaintiff, that there 8 is likelihood of irreparable injury, and that the injunction is in the public interest, a 9 preliminary injunction may still issue. See Kiva Health Brands, LLC v. Kiva Brands, Inc., 10 2019 WL 4249075, No. 19-cv-03459-CRB, at *3 (N.D. Cal. Sep. 6, 2019) (quoting 11 Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1134–35 (9th Cir. 2011) (internal 12 quotation marks omitted). 13 III. DISCUSSION 14 A. Likelihood of Success on the Merits 15 The Court continues to conclude that Vinh-Sanh is likely to succeed on the merits 16 of a trademark infringement claim. To prevail on such a claim, a plaintiff must 17 demonstrate (1) ownership of a valid trademark and (2) use by defendant in commerce of a 18 mark likely to cause confusion. See Network Automation, Inc. v. Advanced Sys. 19 Concepts, Inc., 638 F.3d 1137, 1144 (9th Cir. 2011). 20 1. Ownership of Mark 21 Vinh-Sanh owns its trademarks. Vinh-Sanh registered the THREE LADIES 22 Composite Mark on May 31, 2005, claiming a first use in commerce in May of 1986, and 23 registered its Vietnamese-language Word Mark on October 8, 2013, with a first use in 24 commerce of 2004. See MPI at 9; Aug. 2. Chen Decl. Ex. C, D, E, F (dkt. 12). Vinh- 25 Sanh’s registration and ownership of the marks constitutes prima facie evidence of the 26 marks’ validity and Vinh-Sanh’s exclusive right to use the marks in commerce. See 15 27 U.S.C. § 1115(b); Applied Info. Scis. Corp. v. eBAY, Inc., 511 F.3d 966, 970 (9th Cir. 1 2007). Vinh-Sanh has used the marks continuously in commerce since 1986. See MPI at 2 9; Aug. 2 Chen Decl. ¶ 10. 3 2. Likelihood of Confusion 4 Vinh-Sanh is also likely to succeed in demonstrating a likelihood of confusion. 5 There is a likelihood of confusion between two products “when consumers are likely to 6 assume that a product or service is associated with a source other than its actual source 7 because of similarities between the two sources’ marks or marketing techniques.” Int’l 8 Jensen, Inc. v. Metrosound U.S.A., Inc., 4 F.3d 819, 825 (9th Cir. 1993) (quoting Metro 9 Publishing, Ltd. v. San Jose Mercury News, 987 F.2d 637, 640 (9th Cir. 1993) (abrogated 10 on other grounds)). The Ninth Circuit analyzes likelihood of confusion by referring to 11 eight factors identified in AMF Inc. v. Sleekcraft Boats, 599 F.2d 341, 348–49 (9th Cir. 12 1979) (abrogated in part on other grounds by Mattel, Inc. v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Alejandro Rodriguez v. Timothy Robbins
715 F.3d 1127 (Ninth Circuit, 2013)
Applied Information Sciences Corp. v. eBay, Inc.
511 F.3d 966 (Ninth Circuit, 2007)
Lahoti v. VeriCheck, Inc.
586 F.3d 1190 (Ninth Circuit, 2009)
National Lead Co. v. Wolfe
223 F.2d 195 (Ninth Circuit, 1955)
Alliance for Wild Rockies v. Cottrell
632 F.3d 1127 (Ninth Circuit, 2011)
Sunearth, Inc. v. Sun Earth Solar Power Co.
846 F. Supp. 2d 1063 (N.D. California, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Vinh-Sanh Trading Corporation v. SFTC, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/vinh-sanh-trading-corporation-v-sftc-inc-cand-2019.