WBS, Inc. v. Juan Croucier

CourtDistrict Court, C.D. California
DecidedMarch 11, 2020
Docket2:15-cv-07251
StatusUnknown

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

Bluebook
WBS, Inc. v. Juan Croucier, (C.D. Cal. 2020).

Opinion

1 2 O 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 WBS, INC., a California ) Case No. CV 15-07251 DDP (JCx) Corporation, ) 12 ) Plaintiff, ) 13 ) v. ) ORDER GRANTING MOTION FOR 14 ) ATTORNEY FEES [Dkt. No. 255] JUAN CROUCHER, an ) 15 individual; CROUCIER ) PRODUCTIONS, INC., a ) [Dkt. 183 (closed case)] 16 California Corporation; ROB ) HOFFMAN, an individual; ONE ) 17 MANAGEMENT, a business of ) unknown formation, ) 18 ) Defendants. ) 19 ) 20 Presently before the court on remand from the United States 21 Court of Appeals for the Ninth Circuit is Defendant Juan Croucier’s 22 Motion for Attorney Fees (Dkt. 183). Having considered the 23 submissions of the parties, oral argument, Defendant’s supplemental 24 filing, and the objections thereto, the court grants the motion and 25 adopts the following Order. 26 I. Background 27 The facts of this case are set forth in great detail in this 28 1 court’s prior orders. In short, Plaintiff asserted that in 1997, 2 a partnership that owned trademarks associated with the rock band 3 RATT 4 assigned its rights in the marks to Plaintiff. Plaintiff brought 5 trademark infringement claims in this Court against Defendants and 6 Defendant Croucier filed a counterclaim against Plaintiff. 7 Croucier and Plaintiff brought cross-motions for summary 8 judgment on Plaintiffs’ infringement claims. This Court denied 9 Plaintiff’s motion for summary judgment and granted Croucier’s 10 motion, concluding that the evidence established beyond dispute 11 that the supposed 1997 assignment of the trademarks to Plaintiff 12 was invalid. Plaintiff sought reconsideration of the court’s 13 order, arguing, among other things, that Croucier was collaterally 14 estopped and barred by the Rooker-Feldman doctrine from challenging 15 the validity of the assignment of the marks to Plaintiff. The 16 court denied Plaintiff’s motion for reconsideration without 17 considering the merits of Plaintiff’s collateral estoppel argument, 18 observing that Plaintiff’s new evidence in support of that argument 19 could have been, but was not, presented at the summary judgment 20 stage. The court further explained that the Rooker-Feldman 21 doctrine is inapplicable because Croucier was not a party to any 22 related state court suit. Although the court also observed that 23 Plaintiff’s counsel had repeatedly violated the letter and spirit 24 of the local rules of this district, the court nevertheless denied 25 without comment Croucier’s motion for attorney’s fees. 26 The parties both appealed, on various grounds. In an 27 unpublished disposition, the Ninth Circuit affirmed in all 28 respects, save one. (Dkt. 245) With respect to reconsideration of 1 summary judgment, the appellate court agreed that the Rooker- 2 Feldman doctrine is inapplicable and addressed Plaintiff’s 3 collateral estoppel argument on the merits. The court explained 4 that estoppel or issue preclusion does not apply because, even if 5 Croucier’s partner was a party to a state-court proceeding alleged 6 to have preclusive effect, Croucier himself was not such a party, 7 and mere partnership does not establish privity under California 8 law. (Dkt. 245 at 6-7.) 9 The appellate court did, however, vacate this Court’s denial 10 of Croucier’s motion for attorney’s fees. As the court observed, 11 discretionary decisions regarding attorney’s fees may be set aside 12 “if the record does not support the district court’s decision.” 13 (Dkt. 245 at 8 (quoting Mattel, Inc. v. Walking Mountain Prods., 14 353 F.3d 792, 815 (9th Cir. 2003). The Ninth Circuit remanded for 15 this Court to determine whether attorneys’ fees are appropriate “in 16 light of the objectively unreasonable arguments WBS has advanced, 17 its vexatious approach to this litigation, and WBS’ repeated 18 failures to follow procedural rules.” (Dkt. 245 at 8.) 19 II. Discussion 20 A. Legal Standard 21 Courts may award reasonable attorney fees to the prevailing 22 party in “exceptional” trademark cases. 15 U.S.C. § 1117(a). 23 Courts looks to the totality of the circumstances in determining 24 whether a case is exceptional, such that it “stands out from others 25 with respect to the substantive strength of a party’s litigating 26 position (considering both the governing law and the facts of the 27 case) or the unreasonable manner in which the case was litigated.” 28 SunEarth, Inc. v. Sun Earth Solar Power Co., 839 F.3d 1179, 1180 (9th Cir. 2016) (quoting Octane Fitness, LLC v. ICON Health & Fitness, Inc., 572 U.S. 545, 554 (2014)). Relevant factors include, but are not limited to, “frivolousness, motivation, objective unreasonableness (both in the factual and legal components of the case) and the need in particular circumstances to advance considerations of compensation and deterrence.” Octane Fitness, 572 U.S. at 554 n.6 (quoting Fogerty v. Fantasy, 510 U.S. 8517, 534 n. 19 (1994)). The exceptional case standard applies equally to prevailing plaintiffs and prevailing defendants. Gracie 10}}v. Gracie, 217 F.3d 1060, 1071 (9th Cir. 2000). 11 B. This is an “exceptional” case 12 This Court has, notwithstanding its initial denial of attorney fees, repeatedly highlighted Plaintiff’s improper litigation conduct. In its summary judgment order, for example, the court 15] noted that Plaintiff had violated several local rules and 16] unconvincingly attempted to shift blame for those violations to 17] Croucier’s counsel. (Dkt. 181 at 1 n.1). The court further cautioned Plaintiff’s counsel to comply with all procedural rules, 19]/on pain of sanctions. Id. Nevertheless, the violations continued. 20]/As set forth in this Court’s order denying reconsideration, Plaintiff failed to timely file documents, filed unauthorized briefs, and provided explanations for those violations that were not credible. (Dkt. 222 at 10.) These examples, though not 241 exhaustive, are illustrative of Plaintiff and its counsel’s 25 ||) unreasonable approach to this litigation.! 26 27 ' Plaintiff’s baseless ex parte requests, requests for 28 sanctions, and allegations of fraud and deceit against Croucier’s counsel are too numerous to list here in full.

1 The bulk of Plaintiff’s opposition to Croucier’s fee motion is 2 devoted to the argument that Plaintiff had a “legal and reasonable 3 basis for its claims.” As an initial matter, Plaintiff misstates 4 the relevant standard, citing to several non-binding and outdated 5 authorities that do not apply the “exceptional case” framework. 6 (Opp. at 4:28-5:12.) Furthermore, the Ninth Circuit has rejected 7 Plaintiff’s contention, finding that the arguments Plaintiff 8 advanced were “objectively unreasonable.” This Court cannot, 9 therefore, avoid the conclusion that Plaintiff’s position was 10 substantively weak. 11 In his objections to Croucier’s supplemental briefing, 12 Plaintiff suggests that Plaintiff’s litigation position could not 13 have been meritless because the Ninth Circuit found that 14 Plaintiff’s appeal was not frivolous or “wholly without merit.” 15 (Dkt. 254 at 1:15-24.) Plaintiff appears, however, to conflate 16 distinct issues. Croucier sought attorney fees on appeal under 15 17 U.S.C. § 1117(a), and Plaintiff failed to oppose the motion. (Dkt.

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Related

Sunearth, Inc. v. Sun Earth Solar Power Co.
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Gracie v. Gracie
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134 S. Ct. 1749 (Supreme Court, 2014)

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Bluebook (online)
WBS, Inc. v. Juan Croucier, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wbs-inc-v-juan-croucier-cacd-2020.