V.V.V. & Sons Edible Oils Limited v. Meenakshi Overseas LLC

District Court, E.D. California·Decided June 20, 2025·No. 2:14-cv-02961·Unknown

Opinion

11 V.V.V. & SONS EDIBLE OILS LIMITED, No. 2:14-cv-02961-DJC-CKD

12 Plaintiff,

13 v. ORDER

15 Defendant.

18 This matter involves a trademark dispute over the mark IDHAYAM, an Indian

19 word for heart, in conjunction with the sale of sesame oil. Defendant Meenakshi

20 Overseas LLC sells sesame oil under the IDHAYAM mark and owns a federal

21 trademark registration for that mark. Plaintiff V.V.V. & Sons Edible Oils Limited, who

22 also sells sesame oil under the IDHAYAM mark, claims priority of use in the mark, and 23 seeks cancellation of Defendant’s registration and related relief on that basis. 24 Now before the Court are Defendant’s Motions to Preclude the Testimony of 25 Plaintiff’s Expert Witness Thomas J. Maronick (Maronick Mot. (ECF No. 138)) and 26 Plaintiff’s Non-Retained Expert Witness Janarathanan Rajaratnam (Rajaratnam Mot. 27 (ECF No. 139)). The Court held a hearing on May 1, 2025, with Kenneth Brooks 28 1 appearing for Plaintiff, and Richard Mandel appearing for Defendant. (ECF No. 157.)

2 The Motions were submitted.

3 Having considered the Parties’ briefing and arguments, the Court will deny

4 Defendant’s Motion to Preclude Testimony of Expert Witness Thomas J. Maronick but

5 will grant Defendant’s Motion to Preclude Testimony of Non-Retained Expert Witness

6 Janarathanan Rajaratnam in part.

8 Under Rule 702 of the Federal Rules of Evidence, a witness may offer expert

9 testimony if the following requirements are met:

10 (a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the 11 evidence or to determine a fact in issue;

12 (b) the testimony is based on sufficient facts or data;

13 (c) the testimony is the product of reliable principles and

14 methods; and

15 (d) the expert’s opinion reflects a reliable application of the principles and methods to the facts of the case. 16

17 Testimony is admissible under Rule 702 if the court finds by a preponderance of the

18 evidence that the expert is qualified and the testimony is both relevant and reliable.

19 See Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 597 (1993). Expert testimony

20 is relevant if it “will assist the trier of fact to understand or determine a fact in issue.”

21 Cooper v. Brown, 510 F.3d 870, 942 (9th Cir. 2007). “The evidence must logically

22 advance a material aspect of the party’s case.” Id. Expert testimony “is reliable if the

23 knowledge underlying it has a reliable basis in the knowledge and experience of the

24 relevant discipline.” Primiano v. Cook, 598 F.3d 558, 565 (9th Cir. 2010) (footnote

25 omitted). Expert testimony must “relate to scientific, technical, or other specialized 26 knowledge, which does not include unsupported speculation and subjective beliefs.” 27 Guidroz-Brault v. Mo. Pac. R.R. Co., 254 F.3d 825, 829 (9th Cir. 2001). Exclusion of 28 expert testimony is proper only when such testimony is clearly irrelevant or unreliable; 1 otherwise, “[v]igorous cross-examination, presentation of contrary evidence, and

2 careful instruction on the burden of proof are the traditional and appropriate means of

3 attacking shaky but admissible evidence.” Daubert, 509 U.S. at 596 (citing Rock v.

4 Arkansas, 483 U.S. 44, 61 (1987)).

6 I. Motion to Preclude Expert Testimony of Thomas J. Maronick

7 Plaintiff retained Dr. Thomas J. Maronick, an Emeritus Professor of Marketing in

8 the School of Business and Economics at Towson University, to perform a survey

9 purporting to measure the likelihood of confusion between the Parties’ respective

10 IDHAYAM sesame oil products. (ECF No. 138-2 at 2.) Dr. Maronick issued an expert

11 report (“Maronick Report”) describing and interpreting the results of this survey on

12 October 30, 2024. (Id. at 3–10.) Therein, Dr. Maronick opined that the “level of

13 likelihood of confusion found here, i.e., 46.7%, supports a conclusion that there is a

14 likelihood of confusion between the two brands of sesame oil among consumers who

15 buy Indian and Asian food.” (Id. at 2.) Plaintiff has indicated they intend for Dr.

16 Maronick to testify at trial in support of Plaintiff’s assertion that there is a likelihood of

17 confusion between the Parties’ products and marks. (Maronick Mot. at 1.)

18 Defendant has moved to exclude Dr. Maronick’s testimony on the basis that his

19 survey is neither relevant nor reliable. (Id. at 1–2, 4–14.) In particular, Defendant

20 argues that (1) Dr. Maronick targeted an overinclusive audience for the survey, as the

21 survey was not limited to Indian consumers nor limited to respondents who frequently

22 (as opposed to rarely) purchased Indian food; (2) Dr. Maronick did not include a

23 control group; and (3) Dr. Maronick did not adequately replicate marketplace

24 conditions, as the survey photos he used were poor quality, masking language that

25 would have distinguished the products for consumers, and did not include images of 26 any third-party products, thereby suggesting to survey respondents that the Parties’ 27 two products shown were similar. (Id. at 4–14.) Given these flaws, Defendant argues 28 1 Dr. Maronick should be precluded from testifying at trial because “the Maronick

2 Report [is] completely useless, and capable only of misleading the jury.” (Id. at 2.)

3 The Court disagrees. As the Ninth Circuit recently explained in BillFloat Inc. v.

4 Collins Cash Inc., 105 F.4th 1269 (9th Cir. 2024):

5 With respect to survey evidence, we have long held that it should be admitted as long as it is conducted according to 6 accepted principles and is relevant. Technical inadequacies in a survey, including the format of the 7 questions or the manner in which it was taken, bear on the

8 weight of the evidence, not its admissibility. In sum, follow- on issues of methodology, survey design, reliability, the 9 experience and reputation of the expert, critique of conclusions, and the like go to the weight of the survey 10 rather than its admissibility.

12 Id. at 1275 (cleaned up). Such is the case here. First, concerning the survey group,

13 the Court concurs with Plaintiff’s argument raised in their Opposition that, at

14 minimum, the respondents included in the survey all indicated they purchased Indian

15 food, even if only infrequently. (Opp’n Maronick Mot. (ECF No. 148) at 4–5.) Thus,

16 Defendant has not shown that the survey pool was clearly incorrect. To the extent

17 Defendant wishes to argue the survey respondents should have been more narrowly

18 tailored, they are free to do so at trial. Second, as to Dr. Maronick’s failure to include a

19 control group, the Parties disagree that a control group was required or helpful for

20 this type of survey. (See Maronick Mot. at 6–8; Opp’n Maronick Mot. at 5–6.) Given

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V.V.V. & Sons Edible Oils Limited v. Meenakshi Overseas LLC, (E.D. Cal. 2025).

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Related

Primiano v. Cook
598 F.3d 558 (Ninth Circuit, 2010)
Rock v. Arkansas
483 U.S. 44 (Supreme Court, 1987)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
United States v. Maher
454 F.3d 13 (First Circuit, 2006)
Cooper v. Brown
510 F.3d 870 (Ninth Circuit, 2007)
United States v. Roberto Lopez
762 F.3d 852 (Ninth Circuit, 2014)
Billfloat Inc. v. Collins Cash Inc.
105 F.4th 1269 (Ninth Circuit, 2024)