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Anhing Corp. v. Thuan Phong Co.

Citations: 215 F. Supp. 3d 919; 2015 U.S. Dist. LEXIS 188422; 2015 WL 12745548Docket: CV 13-05167 BRO (MANx)

Court: District Court, C.D. California; April 17, 2015; Federal District Court

Narrative Opinion Summary

This case involves a legal dispute between two corporations over allegations of fraud in trademark registration and claims of trade dress infringement. The Plaintiff corporation, established in 1980, has been selling rice noodles under the federally registered 'MY-THO' mark. The Defendant, a company established in 2002, produces rice paper and noodles under the 'BÁNH TRÁNG MY THO' mark. The Defendant accused the Plaintiff of fraudulently obtaining the trademark by misrepresenting the geographic significance of 'My Tho,' a city in Vietnam, and sought its cancellation. The Court granted the Plaintiff's Motion for Partial Summary Judgment on the fraud claim, concluding that the Defendant failed to provide clear and convincing evidence of fraudulent intent. Conversely, the Court denied the Defendant's Motion for Partial Summary Judgment on the trade dress infringement claim, citing existing triable issues regarding potential consumer confusion. Additionally, the Plaintiff's Motion for Sanctions was denied as the Court found no evidence of bad faith by the Defendant during a settlement conference. The case underlines the necessity of clear evidence in allegations of trademark fraud and the complexity of trade dress disputes.

Legal Issues Addressed

Fraud in Trademark Registration

Application: Defendant failed to establish that Plaintiff knowingly deceived the USPTO regarding the 'MY-THO' mark, as Defendant did not provide clear and convincing evidence of fraudulent intent.

Reasoning: The Court concludes that Defendant has not established a triable issue regarding whether Plaintiff knowingly deceived the USPTO concerning the 'MY-THO' mark.

Sanctions under 28 U.S.C. § 1927 and Local Rule 83-7

Application: Plaintiff's Motion for Sanctions was denied due to lack of evidence of bad faith or violation of settlement authority requirements by Defendant.

Reasoning: The Court concludes that the Defendant did not violate its order regarding the production of a representative with full settlement authority, resulting in the denial of Plaintiffs' Motion for Sanctions.

Summary Judgment Standards

Application: The Court granted Plaintiff's Motion for Partial Summary Judgment on fraud and denied Defendant's Motion for Partial Summary Judgment on trade dress infringement due to the existence of triable issues.

Reasoning: During a hearing on April 13, 2015, the Court determined that no triable issue existed regarding fraud, leading to the granting of Plaintiff's Motion for Partial Summary Judgment. However, the Court found that triable issues remain concerning Plaintiff’s trade dress infringement claim, resulting in the denial of Defendant's Motion for Partial Summary Judgment.

Trade Dress Infringement

Application: The Court found that Defendant's packaging is distinctive enough to prevent consumer confusion, which precluded the granting of Defendant's Motion for Partial Summary Judgment.

Reasoning: The Court previously noted that the Defendant's packaging is distinctive enough to avoid consumer confusion, a conclusion derived from an earlier order in a preliminary injunction context.