Woodway USA, Inc. v. LifeCORE Fitness, LLC

District Court, S.D. California·Decided May 23, 2025·No. 3:24-cv-01936·Unknown

Opinion

WOODWAY USA, INC., Case No.: 24-cv-1936-AGS-AHG Plaintiff, ORDER GRANTING DEFENDANT’S MOTION TO DISMISS (ECF 10) v. LIFECORE FITNESS, LLC d/b/a Defendant. This trademark and unfair-competition case about treadmills runs on the heels of a related patent-infringement case. See Woodway USA, Inc. v. LifeCORE Fitness, Inc., No. 22-cv-0492-JO-BLM (S.D. Cal. 2022). Defendant won summary judgment in the patent case, id. ECF 175, and now moves to dismiss some of the unfair-competition claims against it here. Plaintiff Woodway USA, Inc., owns the trademark “FOR THE LONG RUN.” (ECF 1, at 3.) This trademark is affiliated with its “non-motorized exercise treadmills” that have a curved running surface, introduced in 2009 “under the trademark CURVE.” (Id.) “Since at least as early as 2010, Woodway’s CURVE Treadmills have been featured in various scientific and academic reports, studies, and publications” to “demonstrate, measure, and assess the health or physiological benefits of the use of non-motorized treadmills.” (Id.) Woodway uses the results from these studies to advertise that “users can burn up to ‘30% more calories’ by using a CURVE-branded treadmill than by using a motorized treadmill” (id. at 5), and that “the running surface can last ‘up to 150,000 miles’ without the need for substitution or repair” (id. at 6). “[A]gencies and news commentators” have been “linking” these studies to the CURVE Treadmills since “at least as early as” 2011 and 2012, respectively. (See id. at 5–6.) Defendant LifeCORE Fitness, LLC, doing business as Assault Fitness, is “a direct competitor of Woodway.” (ECF 1, at 2.) Assault began promoting its own line of non-motorized treadmills with the slogan “BUILT FOR THE LONG RUN” as well as advertising that they help burn up to “30% more calories” than motorized treadmills and last “up to 150,000 miles” without the need for repair or substitution. (Id. at 5–7.) Assault uses these attributes to advertise the Assault Treadmills on its website and in promotional material provided to its distributors. (See id. at 6–7.) Woodway filed suit alleging trademark violations stemming from both the “FOR THE LONG RUN” mark and the 30%-more-calories and up-to-150,000-miles advertising statements. (See ECF 1.) Assault moves to dismiss Woodway’s claims arising only from Assault’s use of the advertising statements: violations of the Lanham Act, 15 U.S.C. § 1051 et seq. (claims 2 through 5), California’s Unfair Competition Law, Cal. Bus. & Prof. Code § 17200 (claim 7), and California’s Consumer Legal Remedies Act, Cal. Civ. Code § 1770 (claim 8). (See ECF 10-1.) To survive a motion to dismiss, the complaint must contain enough facts to “state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (cleaned up). At this early stage, the Court accepts “the factual allegations in the complaint as true” and construes them “in the light most favorable to the plaintiff.” GP Vincent II v. Estate of Beard, 68 F.4th 508, 514 (9th Cir. 2023). Mere “conclusory allegations of law and unwarranted inferences are insufficient to defeat a motion to dismiss.” Adams v. Johnson, 355 F.3d 1179, 1183 (9th Cir. 2004). Claims sounding in fraud face a higher bar: they “must state with particularity the circumstances constituting fraud.” Fed. R. Civ. P. 9(b). “Although the Ninth Circuit has not definitively spoken as to whether Rule 9(b) applies to Lanham Act claims, the better reasoned district court authority is that, where a Lanham Act claim is predicated on the theory that the defendant engaged in a knowing and intentional misrepresentation, then Rule 9(b) is applicable.” Clorox Co. v. Reckitt Benckiser Grp. PLC, 398 F. Supp. 3d 623, 634 (N.D. Cal. 2019). Since Woodway alleges Assault’s violations are “deliberat[e], willful[], and in bad faith” (ECF 1, at 10), and since Woodway “allege[s] a unified course of fraudulent conduct and rel[ies] entirely on that course of conduct as the basis of” all the claims at issue here, “the pleading as a whole must satisfy the particularity requirement of Rule 9(b),” Kearns v. Ford Motor Co., 567 F.3d 1120, 1125 (9th Cir. 2009). So Woodway must plead “the who, what, when, where, and how of the misconduct charged.” Vess v. Ciba-Geigy Corp. USA, 317 F.3d 1097, 1106 (9th Cir. 2003). The claims considered here are all based on the same facts and each satisfies the who (Assault), what (the caloric-expenditure and durability advertising statements), when (various dates beginning in February 2017), and where (within multiple advertisements). (ECF 1, at 2, 6–9, 10.) The Court now turns to the “how.” A. Lanham Act Claims Woodway brings claims under two Lanham Act liability theories: false designation of origin (also called “false association”), 15 U.S.C. § 1125(a)(1)(A), and false advertising, id. § 1125(a)(1)(B). 1. False Designation of Origin The false-designation provision seeks to deter, among other things, “confusion” “as to the origin” of goods. 15 U.S.C. § 1125(a)(1)(A). Woodway must show that Assault “(1) use[d] in commerce (2) any word, false designation of origin, false or misleading description, or representation of fact, which (3) is likely to cause confusion or misrepresents the characteristics of his or another person’s goods or services.” Freecycle Network, Inc. v. Oey, 505 F.3d 898, 902 (9th Cir. 2007); see also AECOM Energy & Constr., Inc. v. Morrison Knudsen Corp., 748 F. App’x 115, 118 (9th Cir. 2018) (applying these elements to a false-designation claim). Among other points, Assault zeroes in on the confusion element and attacks Woodway’s “factual basis to show how” Assault’s use of “common industry words and phrases to describe its treadmills are false or misleading in fact” as to the origin of its products. (ECF 10-1, at 15.) According to Assault, Woodway “fails to articulate how consumers would be confused” by Assault’s “descriptive use of common product claims,” since “[c]onsumers do not associate such claims” “exclusively with” Woodway. (Id.) Assault is right. The Lanham Act’s “origin of goods” provision prohibits misleading claims specifically about “the producer of the tangible goods that are offered for sale,” but not about “the author of any idea, concept, or communication embodied in those goods.” Dastar Corp. v. Twentieth Century Fox Film Corp., 539 U.S. 23, 37 (2003). For example, in Baden Sports, Inc. v. Molten USA, Inc., 556 F.3d 1300 (Fed. Cir. 2009), the Federal Circuit applied Ninth Circuit law and rejected an argument that the defendant was liable for false designation of origin when it advertised certain basketball technology as its own “innovation,” even though it was plaintiff’s patented technology. Id. at 1303–05. The Baden court reasoned that the “innovation” advertisement referre

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Woodway USA, Inc. v. LifeCORE Fitness, LLC, (S.D. Cal. 2025).

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