XYZ Corp. v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint

CourtDistrict Court, S.D. New York
DecidedApril 1, 2024
Docket1:24-cv-01962
StatusUnknown

This text of XYZ Corp. v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint (XYZ Corp. v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
XYZ Corp. v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint, (S.D.N.Y. 2024).

Opinion

Dmitry Lapin, Esq. (NY, NJ, PA, and ME) □ f 535 N. Church Street #304 West Chester, PA 19380 □□ A MST eld Law Group (917)-979-4570 =. dmitry@axenfeldlaw.com

VIA ECF March 29, 2024 Hon. Lorna G. Schofield Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: XYZ Corp., v. Individuals, et. al., (Dkt # 1:24-cv-01962-LGS) Motion to Adjourn the Preliminary Injunction Hearing Motion for Alternative Service of Process Motion to Permit Law Student Rachel Mihlstin to Appear on This Matter Dear Hon. Schofield: This office represents Plaintiff in the above referenced copyright infringement action against Defendants, who have infringed upon Plaintiff's rights by selling products through their e-commerce storefronts. On March 19, 2024, the Court entered a Temporary Restraining Order (the “TRO”) [Doc. No. 9], requiring Etsy, Inc., (“Etsy”) and the Financial Institutions to restrain Defendants’ online seller's accounts. Among other items, the Court set forth a preliminary injunction hearing for April 3, 2024. Etsy was served with, and received the TRO, on March 20, 2024. Although the TRO required Etsy to respond within five days of receipt of the TRO, Etsy’s response was not received until approximately 11pm on March 28, 2024. As such, Plaintiff has only now received Defendants’ contact information. Moreover, Etsy has not yet provided all of the information that it was ordered to produce as part of the TRO, e.g., information relating to Defendants’ connected accounts with financial institutions. Therefore, Plaintiff has not had any opportunity to serve any financial institutions as Plaintiff does not know which financial institution is connected to any Defendant. Additionally, no Defendant has been served with the TRO, thus implicating their opportunity to appear in this matter and/or oppose the issuance of a preliminary injunction. For the aforementioned reasons, it is respectfully requested that the Court 1) adjourn the April 3, 2024, preliminary injunction hearing until April 17, 2024, 2) require any defendant that wishes to modify or dissolve the TRO to serve its notice on or by April 12, 2024, and 3) extend the deadline for any opposing papers to filed on or before April 15, 2024. This is Plaintiffs first request for an adjournment of this hearing. Plaintiff also moves the Court for leave to serve certain Defendants by alternative methods, namely registered e-mail to their now known e-mail addresses which are connected to their Etsy accounts. In briefly reviewing the information thus far received from Etsy, it is clear that certain Defendants are located in the United States, Canada, United Kingdom, Hong Kong, Australia, Vietnam, and other countries that are 1) members to the Hague Convention on the Service of Process Abroad, and 2) do not object to service of process by postal channels.

Hon. Lorna G. Schofield -( + )\- March 29, 2024 Axenfeld Law Group 2|Page = Trademark - Patent - Intellectual Property Law

As for the Defendants residing in the United States, Fed. R. Civ. P. 4(e)(1) provides that a defendant residing in the United States may be served according to the procedures allowed by state law in the state where the district court is located. New York C.P.L.R. allows for alternative service when traditional service is “impracticable.” See N.Y. C.P.L.R. § 308(5). GPAcoustics (US), Inc. v. J&V Audio,inc. 2017 WL 11570459 at *2 (S.D.N.Y 2017), quoting Snyder v. Alternate Energy Inc., 857 N.Y.S. 2d 442, 446 (Civ.Ct.2008). In order to grant the instant motion as it relates to the individuals/entities based in the United States, a movant must show that service on Defendants’ email address meets the constitutional requirements of due process and that traditional service is “impracticable.” Impracticability “does not require proof of due diligence or of actual prior attempts to serve a party” under conventional methods. Shamoun v. Mushlin, 2013 WL 917085, at *2 (S.D.N.Y. 2013). Initially, it is worth noting that service of process by e-mail is the most practical option as there are numerous Defendants in different parts of the country. It would also be impractical to attempt service of process through traditional avenues under the presence circumstances considering that 1) many of the Defendants have multiple addresses associated with their accounts — thereby potentially multiplying Plaintiffs efforts to effectuate service of process, and 2) the short time period in which Defendants would have to appear in this matter, file any opposition, etc., prior to the preliminary injunction hearing. Fed. R. Civ. P. (4) governs service on international Defendants. Plaintiff may serve international defendants pursuant to Fed. R. Civ. P. 4(f)(3), which enables a court to grant an alternative method of service so long as it: “(1) is not prohibited by international agreement; and (2) comports with constitutional notions of due process.” SEC v. Anticevic, No. 05 CV 6991 (KMW), 2009 U.S. Dist. LEXIS 11480, at *7 (S.D.N.Y. Feb. 8, 2009). Notably, service under subsection 4(f)(3) “is neither a last resort nor extraordinary relief. It is merely one means among several which enables service of process on an international defendant.” Sulzer Mixpac AG v. Medenstar Indus. Co., 312 F.R.D. 329, 330 (S.D.N.Y. 2015). The decision whether to allow alternative methods of serving process under Rule 4(f)(3) is committed to the sound discretion of the district court. /d. Ultimately, service on Defendants by electronic means comports with due process, as it is “reasonably calculated, under all circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” Mullane v. Cent. Hanover Bank & Trust Co., 339 U.S. 306, 309 (1950). This is particularly true when service is effectuated through a service provider that send the e-mail as a registered e-mail whereby a delivery receipt will be provided, as well as when the Defendant actually opens the email. Additionally, this Court, as well as courts in other Districts, have held that service by e-mail is appropriate and may be the sole means of effecting service of process “when faced with an international e-business scofflaw.” Rio Props., Inc. v. Rio Int’! Interlink, 284 F.3d 1007, 1018 (9th Cir. 2002); Cengage Learning, Inc. v. Doe 1 2018 WL 2244461 at *5 (S.D.N.Y. Jan. 17, 2018) (email service appropriate under Rule 4(f)(3)); Popular Enters., LLC v. Webcom Media Group, Inc., 225 F.R.D. 560,563 (E.D. Tenn. 2004) (e-mail service permitted). The Defendants’ email addresses are essential to operating their Online Storefronts. Defendants communicate with customers, receive order information, payment receipts, deposit confirmations through their email addresses. The maintenance of an active and monitored email

Hon. Lorna G. Schofield -( + \- March 29, 2024 4 Axenfeld Law Group 3|Page = Trademark - Patent - Intellectual Property Law

address is also required by the service providers as it is the means by which Etsy communicates with the Defendants regarding their accounts. For the aforementioned reasons, Plaintiff respectfully requests that the Court permit Plaintiff to serve those Defendants residing in the United States, and any other Hague-Member country that has not objected to service of process through postal channels.

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XYZ Corp. v. Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A to the Complaint, Counsel Stack Legal Research, https://law.counselstack.com/opinion/xyz-corp-v-individuals-corporations-limited-liability-companies-nysd-2024.