X Social Media, LLC v. X Corp.

District Court, M.D. Florida·Decided June 26, 2025·No. 6:23-cv-01903·Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION X SOCIAL MEDIA LLC, Plaintiff, Vv. CASE NO. 6:23-cv-1903-JA-NWH X CORP., Defendant.

ORDER This case is before the Court on Plaintiff, X Social Media LLC’s motion for reconsideration (Doc. 81) and Defendant, X Corp.’s response (Doc. 91). Based on the Court’s review of the parties’ submissions, the motion must be denied. I. BACKGROUND During the discovery period, Plaintiff did not disclose any affirmative expert reports by its deadline to do so, but Defendant served two affirmative expert reports: (1) a marketing report authored by Peter N. Golder, Ph.D., and (2) a consumer survey report on the likelihood of reverse confusion authored by Hal Poret. On its rebuttal report deadline, Plaintiff served the “Rebuttal Report of David Franklyn” (Franklyn Report) (Doc. 51-1). Sections [X—XIV of the Franklyn Report include a reverse two-room Squirt! sequential lineup survey

1 See SquirtCo v. Seven-Up Co., 628 F.2d 1086 (8th Cir. 1980).

as well as a survey to measure initial-interest confusion (Franklyn Surveys). Upon Defendant’s motion (Doc. 51), the Court struck the Franklyn Surveys because they are untimely affirmative opinions. (Doc. 70). Now, Plaintiff requests the Court to reconsider its order, citing to “new evidence” and

claiming that the Court “misunderstood or misconstrued” the record. (See Doc.

81 at 3, 5, 21). Il. LEGAL STANDARDS District courts are afforded considerable discretion to reconsider prior decisions. See Harper v. Lawrence Cnty., 592 F.3d 1227, 1231-32 (11th Cir.

2010) (discussing reconsideration of interlocutory orders); Lamar Advert. of Mobile, Inc. v. City of Lakeland, 189 F.R.D. 480, 488-89, 492 (M.D. Fla. 1999) (discussing reconsideration generally and under Federal Rule of Civil Procedure

54(b)); Sussman v. Salem, Saxon & Nielsen, P.A., 153 F.R.D. 689, 694 (M.D. Fla.

1994) (discussing reconsideration under Rules 59(e) and 60(b)). Courts in this

district recognize “three grounds justifying reconsideration of an order: (1) an

intervening change in controlling law; (2) the availability of new evidence; and

(3) the need to correct clear error or manifest injustice.” McGuire v. Ryland Grp., Inc., 497 F. Supp. 2d 1356, 1858 (M.D. Fla. 2007) (quoting True v. Comm’ of the

LR.S., 108 F. Supp. 2d 1361, 1865 (M.D. Fla. 2000)); Montgomery v. Fla. First

Fin. Grp., Inc., No. 6:06-cv-1639-Orl-31KRS, 2007 WL 2096975, at *7 (M.D. Fla.

July 20, 2007). “Reconsideration of a previous order is an extraordinary measure and

should be applied sparingly.” Scelta v. Delicatessen Support Servs., Inc., 89 F.

Supp. 2d 1311, 1320 (M.D. Fla. 2000). “[M]otions for reconsideration should not

be used to raise arguments which could, and should, have been previously made.” Id. (quoting Prudential Sec., Inc. v. Emerson, 919 F. Supp. 415, 417 (M.D. Fla. 1996)). “A party who fails to present its strongest case in the first instance

generally has no right to raise new theories or arguments in a motion for

reconsideration.” McGuire, 497 F. Supp. 2d at 1358 (quoting Villaflores v. Royal

Venture Cruise Lines, Ltd., No. 96-2108-CIV-T, 1997 WL 728098, at *2 (M.D. Fla. Nov. 17, 1997)). To permit otherwise would “essentially afford[] a litigant

two bites at the apple.” Am. Home Assurance Co. v. Glenn Estess & Assocs., Inc.,

763 F.2d 1237, 1239 (11th Cir. 1985) (citing Union Planters Natl Leasing, Inc.

v. Woods, 687 F.2d 117, 121 (5th Cir. 1982), and Willens v. Univ. of Mass., 570

F.2d 403, 406 (1st Cir. 1978)). Ill. DISCUSSION In the motion for reconsideration, Plaintiff does not claim that a change

in law has occurred that makes the Franklyn Surveys admissible. Rather, Plaintiff argues that the Court wrongly construed the record and that new

evidence shows that the Franklyn Surveys are proper rebuttal opinions that

cause no prejudice to Defendant. A. Untimely Affirmative Opinions The Court determined that the Franklyn Surveys were affirmative

opinions in part because Professor Franklyn himself identified the Franklyn

Surveys as his “affirmative opinions.” (Doc. 51-1 at 6). Nevertheless, Plaintiff

argues that “new evidence,” including Professor Franklyn’s deposition

testimony, demonstrates that the Franklyn Surveys prop erly rebut claims made

by Dr. Golder and Mr. Poret. (Doc. 81 at 5). Plaintiff also relies on the Complaint

(Doc. 1) and McCarthy on Trademarks and Unfair Competition (5th ed.), (see

Doc. 81 at 14-21), to show that the Franklyn Surveys are rebuttal opinions. As

an initial matter, the Court notes that this purportedly new evidence, including

the opinions Professor Franklyn provided in his deposition testimony, was

reasonably available to Plaintiff at the time Plaintiff filed its opposition and

should have been presented to the Court at that time. See Scelta, 89 F. Supp. at

1320 (explaining that “motions for reconsideration ‘should not be used to raise

arguments which could, and should, have been [previously] made.” (quoting Prudential, 919 F. Supp. at 417)); Michael Linet, Inc. v. Vill. of Wellington, 408

F.3d 757, 763 (11th Cir. 2005). Additionally, none of this purportedly new evidence provides an adequate basis for reconsideration. Plaintiff points to Professor Franklyn’s testimony that

Mr. Poret should have used a Squirt survey rather than an Eveready? survey

and that Dr. Golder should have considered the possibility of initial-interest

confusion. (See Doc. 81 at 15; Doc. 82-4 at 121:5-12, 273:2-18). But these

opinions are within the proper scope of rebuttal and were not struck in the

Court’s prior order. (Doc. 51-1 at 14-19, 42-48). The same is also true of

Professor Franklyn’s testimony about marketplace proximity, (Doc. 51-1 at 15—

16; Doc. 81 at 17; Doc. 82-4 at 137:3-12). Thus, this testimony does not address

the admissibility of the Franklyn Surveys. Plaintiff insists that Professor Franklyn’s initial-interest-confusion

survey was “used to critique both Golden [sic] and Poret.” (Doc. 81 at 16). But

as the Court previously explained, the Franklyn Surveys are affirmative opinions because they tested theories that were never discussed by Dr. Golder

or Mr. Poret. (See Doc. 70 at 6). Plaintiffs line of argument to the contrary has

already been considered and rejected. See Loc. Access, LLC v. Peerless Network,

Inc., 222 F. Supp. 8d 1118, 1115 (M.D. Fla. 2016) (“It is wholly inappropriate in

a motion for reconsideration to relitigate the merits of the case, to raise new

arguments which should have been raised in previous briefing, or to ‘vent

dissatisfaction with the Court’s reasoning.” (quoting Madura v. BAC Home

2 See Union Carbide Corp. v. Ever-Ready Inc., 581 F.2d 366 (7th Cir. 1976).

Loans Servicing L.P., No. 8:11-cv—2511-T, 2013 WL 4055851, at *2 (M.D. Fla.

Aug. 12, 2013))). The Court also found that because the concept of initial-interest confusion

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