AirDoctor, LLC v. Xiamen Qichuang Trade Co., Ltd.
2:22-cv-05784
C.D. Cal.May 27, 2025Background
- AirDoctor, LLC is a Delaware-based company holding federal trademarks for "AIRDOCTOR" and "ULTRAHEPA," used in connection with air purifiers.
- Defendant, Xiamen Qichuang Trade Co., Ltd., based in China, sold replacement filters for AirDoctor air purifiers through an Amazon storefront branded as “FCFMY.”
- Defendant’s filters were marketed as “HEPA,” “compatible” with AirDoctor, and capable of removing 99.97% of airborne particles, but third-party testing showed the filters did not meet these standards or fit properly in AirDoctor units.
- Plaintiff filed suit under the Lanham Act, alleging false advertising and trademark infringement, seeking damages, attorney’s fees, and injunctive relief.
- Defendant failed to appear in the action or respond to the complaint, resulting in default judgment being entered against them.
- The court awarded AirDoctor $2,787,089 in damages, $53,442.98 in attorneys’ fees, and entered a wide-ranging permanent injunction against the defendant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| False advertising and trademark use | Defendant falsely advertised filters as HEPA and compatible | None (Defaulted) | Plaintiff proved false advertising and trademark |
| Damages under the Lanham Act | Full disgorgement of infringer's revenues proper | None (Defaulted) | Plaintiff entitled to defendant’s sales revenue |
| Exceptionality for attorneys’ fees | Case is exceptional due to willful conduct | None (Defaulted) | Fees awarded under Lanham Act |
| Permanent injunctive relief | Continued violations likely; broad injunction required | None (Defaulted) | Comprehensive injunction issued |
Key Cases Cited
- AirDoctor, LLC v. Xiamen Qichuang Trade Co., Ltd., 134 F.4th 552 (9th Cir. 2025) (affirming entry of default judgment for trademark infringement and false advertising under the Lanham Act)