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Trader Joe’s Co. v. Hallatt

United States Court of Appeals for the Ninth Circuit
835 F.3d 960 (2016)


Facts

Trader Joe’s Co. (plaintiff) was a grocery store company that operated distinctive stores in the United States selling mainly its own branded products. Trader Joe’s did not franchise the sale of its products or intellectual property and had numerous trademarks for its logo and products, as well as trade-dress protections for its store design. Michael Hallatt (defendant) was a Canadian who frequently crossed the border to buy vast quantities of Trader Joe’s goods at a Trader Joe’s store. Trader Joe’s learned that Hallatt was reselling the products at a large markup in Canada, at a store he had named “Pirate Joe’s” that sported a logo and store design similar to Trader Joe’s. Hallatt refused Trader Joe’s request to stop this activity, and began using disguises and other individuals to evade Trader Joe’s refusal to sell products to him. Trader Joe’s sued Hallatt in federal court alleging trademark infringement and unfair competition under the Lanham Act and state law. The district court dismissed the complaints for lack of subject-matter jurisdiction, and Trader Joe’s appealed.

Rule of Law

Issue

Holding and Reasoning (Christen, J.)

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