Trader Joe’s Co. v. Hallatt

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Trader Joe's filed suit against defendant for trademark infringement and unfair competition under the Lanham Act, 15 U.S.C. 1051 et seq., and Washington law after defendant purchased Trader Joe's-branded goods in Washington state and transported them to Canada for resell in a store defendant designed to mimic a Trader Joe's store. The district court dismissed the Lanham Act and state law claims for lack of subject matter jurisdiction. The court held, consistent with recent case law from the Supreme Court and this court, that the extraterritorial reach of the Lanham Act raises a question relating to the merits of a trademark claim, not to federal courts’ subject-matter jurisdiction. The court concluded, on the merits, that Trader Joe’s alleges a nexus between defendant's conduct and American commerce sufficient to warrant extraterritorial application of the Lanham Act. Therefore, the court reversed as to the Lanham Act claim. The court affirmed the dismissal of the state law claims because Trader Joe’s did not allege trademark dilution in Washington or harm to a Washington resident or business. View "Trader Joe's Co. v. Hallatt" on Justia Law