MGA Entertainment, Inc. v. Louis Vuitton Malletier, S.A.
United States District Court for the Central District of California
2019 U.S. Dist. LEXIS 81397 (2019)
- Written by Ann Wooster, JD
Facts
MGA Entertainment, Inc. (MGA) (plaintiff), a California developer and distributor of children’s products, created a toy container shaped like a handbag called a Pooey Puitton. Louis Vuitton Malletier, S.A. (Vuitton) (defendant), the maker of world-famous Louis Vuitton fashion handbags, filed an action in a French court to enforce its European Union (EU) trademarks. Vuitton claimed in the French court that the name Pooey Puitton and MGA’s handbag toy infringed upon and disparaged Vuitton’s EU trademarks. MGA brought an action in the United States district court, seeking a declaratory judgment that the Pooey Puitton name and handbag toy did not violate Vuitton’s intellectual-property rights in its US trademarks under the Lanham Trade-Mark Act. MGA argued that Vuitton’s US trademark rights were identical to Vuitton’s EU trademark rights and that by filing the action in French court, Vuitton was asserting claims against MGA and its customers in the US. MGA claimed that there was an actual controversy requiring the court’s judicial action because Vuitton had a history of failing to respect parody rights protected under the First Amendment by filing vexatious lawsuits to enforce its trademark rights. MGA requested that the district court declare that the Pooey Puitton name and handbag toy did not infringe or dilute Vuitton’s US trademarks. Vuitton argued that MGA failed to establish that an actual controversy existed between the parties that required the US court’s action based on the French court’s action concerning trademarks registered in the EU. Vuitton filed a motion to dismiss MGA’s claim in its entirety for a lack of subject-matter jurisdiction.
Rule of Law
Issue
Holding and Reasoning (Walter, J.)
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