Watkins v. MGA Entertainment, Inc.

CourtDistrict Court, N.D. California
DecidedDecember 10, 2021
Docket3:21-cv-00617
StatusUnknown

This text of Watkins v. MGA Entertainment, Inc. (Watkins v. MGA Entertainment, 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
Watkins v. MGA Entertainment, Inc., (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 ROBIN WATKINS, et al., 7 Case No. 21-cv-00617-JCS Plaintiffs, 8 v. ORDER GRANTING MOTION TO 9 DISMISS SECOND AMENDED MGA ENTERTAINMENT, INC., COMPLAINT 10 Defendant. Re: Dkt. No. 35 11

12 13 I. INTRODUCTION 14 This product defect case was originally brought as a putative class action by Plaintiffs 15 Robin Watkins and Adam Sensney under the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 16 1332(d)(1). They asserted claims for negligence, breach of express and implied warranties, and 17 violation of California’s Consumer Legal Remedies Act (“CLRA) and Unfair Competition Law 18 (“UCL”) against MGA Entertainment, Inc. (“MGA”), which manufactures, sells and distributes a 19 toy line called L.O.L. Surprise!, based on allegations that a product in the line, the 2-in-1 Glamper 20 Fashion Camper (“Glamper”), had a defective button in which a child’s finger could become 21 trapped. MGA brought a motion to dismiss, which the Court granted with leave to amend in its 22 July 26, 2021 Order (dkt.31) (“the July 26 Order”). The Second Amended Complaint (“SAC”) 23 was filed on August 27, 2021. Presently before the Court is MGA’s Motion to Dismiss Second 24 Amended Complaint (“Motion”). The Court finds that the Motion can be decided without oral 25 argument and therefore vacates the motion hearing set for December 17, 2021 pursuant to Civil 26 Local Rule 7-1(b). The Further Case Management Conference set for the same date is also 27 1 vacated. For the reasons stated below, the Motion is GRANTED.1 2 II. BACKGROUND 3 The factual allegations in the Second Amended Complaint (“SAC”) are largely the same as 4 those in the First Amended Complaint (“FAC”) and therefore, the Court does not summarize them 5 here, except as relevant. Among other things, the factual allegations in the SAC are amended to 6 remove an ambiguity in the FAC as to who purchased a Glamper for Sensney’s daughter. See July 7 26 Order at 4 n. 2 (“Despite the suggestion in Paragraph 66 [of the FAC] that the Glamper may 8 have been purchased by Sensney himself, Plaintiffs’ counsel stipulated at oral argument that the 9 Glamper was, in fact, purchased by his mother-in-law.”). The SAC makes clear that Sensney did 10 not purchase the Glamper for his daughter but instead, that his mother-in-law purchased the 11 Glamper for Sensney’s daughter from an online retailer. SAC ¶¶ 28 (“Plaintiff Sensney came in 12 possession of the Glamper when his mother-in-law purchased the Glamper for $89.99 from an 13 online retailer for the benefit of Plaintiff Sensney’s daughter, G.S., age 7, and shipped it to 14 Plaintiff Sensney’s home in Walnut Creek.”); 51 (“Plaintiff’s close family member purchased the 15 Glamper manufactured by Defendant for his child’s use because the child requested the Glamper 16 as a present.”). The SAC also alleges additional facts as to where the alleged express warranty 17 (“Age 3+”) was printed, alleging that it appeared on “the outside packaging of the Glamper” and 18 on “the cover of the manual.” SAC. ¶¶ 63–64. 19 The SAC also differs from the FAC in that only Sensney is named as a plaintiff; Watkins 20 has been dropped as a plaintiff. In addition, only two claims are asserted in the SAC: 1) a claim 21 for breach of implied warranty of merchantability (Claim One); and 2) breach of express warranty 22 that the Glamper was safe for “Age 3+” (Claim Two). 23 MGA contends both of the claims asserted in the SAC are insufficiently alleged and asks 24 the Court to dismiss them with prejudice. Motion at 1. With respect to the implied warranty 25 claim, MGA argues that it fails because such a claim requires both horizontal and vertical privity 26 under California law, and the SAC concedes there is no vertical privity. Motion at 5-9. MGA 27 1 further contends the claim fails because Sensney has not alleged facts showing that the Glamper is 2 unfit for its ordinary purpose and therefore “unmerchantable.” Id. at 9-12. 3 MGA argues that the breach of express warranty claim fails because Plaintiff has not pled 4 the precise terms of the warranty. Id. at 12-15. MGA further contends that to state a claim for 5 breach of express warranty, Plaintiff must allege facts establishing that the express warranty was 6 “part of the basis of the bargain” and Plaintiff fails to do so because he did not purchase the 7 Glamper from MGA and thus, is not in privity with MGA. Id. at 15-17. MGA argues that while 8 there is an exception to the privity requirement where an individual actually relied on an express 9 warranty, that exception does not apply here because Plaintiff does not allege actual reliance. Id. 10 (citing Burr v. Sherwin Williams Co., 42 Cal. 2d 682, 695 (1954)). Finally, MGA argues that the 11 SAC fails to state any claim because Sensney has not alleged that he suffered any injury as a result 12 of the alleged breach of express and implied warranties. Id. at 17-18. 13 Plaintiff rejects MGA’s argument that his breach of implied warranty claim fails for lack of 14 vertical privity, arguing that under California law, vertical privity is not required because Sensney 15 is a third-party beneficiary of the sale of the Glamper by an online retailer to his mother-in-law. 16 Opposition at 2-5. Plaintiff acknowledges that this Court has rejected this reading of California 17 law but asks the Court to revisit this question. Id. at 5 (citing See In re Seagate Tech. LLC Litig., 18 233 F. Supp. 3d 776, 787 (N.D. Cal. 2017)). In the alternative, Plaintiff contends he has alleged 19 facts sufficient to state a claim under the Song-Beverly Act, Cal. Civ. Code § 1792, which does 20 not require vertical privity, and requests leave to amend his complaint to assert such a claim if the 21 Court finds that there is no third-party beneficiary exception to the vertical privity requirement on 22 his breach of implied warranty claim. Id. at 5. Plaintiff also rejects MGA’s argument that he has 23 not alleged sufficient facts to show the Glamper was unmerchantable, citing the broad 24 interpretation courts give to unmerchantability in the implied warranty context. Id. at 6-7. 25 In response to MGA’s challenges to his breach of express warranty claim, Plaintiff argues 26 that the words “Age 3+” are sufficient to allege the existence of an express warranty. Id. at 7-8. 27 Moreover, he contends, because these words were printed on the packaging, they became part of 1 1213 (2010)). 2 III. ANALYSIS 3 A. Legal Standards Under Rule 12(b)(6) 4 A complaint may be dismissed under Rule 12(b)(6) of the Federal Rules of Civil Procedure 5 for failure to state a claim on which relief can be granted. “The purpose of a motion to dismiss 6 under Rule 12(b)(6) is to test the legal sufficiency of the complaint.” N. Star Int’l v. Ariz. Corp. 7 Comm’n, 720 F.2d 578, 581 (9th Cir. 1983). Generally, a plaintiff’s burden at the pleading stage 8 is relatively light. Rule 8(a) of the Federal Rules of Civil Procedure states that a “pleading which 9 sets forth a claim for relief . . . shall contain . . . a short and plain statement of the claim showing 10 that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a).

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Bluebook (online)
Watkins v. MGA Entertainment, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/watkins-v-mga-entertainment-inc-cand-2021.