COACH, INC. v. PAULA'S STORE SPORTWEAR LLC
2:13-cv-03263
D.N.J.Jan 31, 2014Background
- Coach alleges Defendants sold counterfeit Coach wallets and handbags at 160 Lexington Ave, Passaic, NJ.
- April 2, 2013 search resulted in seizure of six counterfeit items and the arrest of Paula Sanchez.
- Defendants were served June 5, 2013 but failed to answer; default entered August 21, 2013.
- Coach asserts multiple Lanham Act claims and state-law equivalents, plus unjust enrichment.
- Court determines willful infringement and grants default judgment, damages, costs, fees, and injunctive relief.
- Damages chosen: $80,000 in statutory damages for eight marks across two goods.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether default judgment is proper | Coach argues Defendants failed to appear, prejudiced Coach, and claims liability established. | N/A | Default judgment granted. |
| Whether Coach stated valid Lanham Act claims | Coach claims counterfeiting, infringement, trade dress, false designation, and dilution supported by findings. | N/A | Claims established; liability found. |
| Appropriate damages under the Lanham Act | Seek $100,000 per mark infringed (8 marks, 2 goods) = $800,000; statutory damages applicable. | N/A | Court awards $80,000 total in statutory damages. |
| Costs and attorneys’ fees | Lanham Act allows costs and attorneys’ fees in exceptional cases; conduct deemed culpable. | N/A | Costs $401.20 and fees $3,178.95 awarded. |
| Injunctive relief | Permanent injunction necessary to prevent further infringement and protect Coach marks. | N/A | Permanent injunction granted. |
Key Cases Cited
- Comdyne I, Inc. v. Corbin, 908 F.2d 1142 (3d Cir. 1990) (uncontested facts may support liability; damages separate)
- Chanel, Inc. v. Gordashevsky, 558 F. Supp. 2d 532 (D.N.J. 2008) (whether unchallenged facts show legitimate causes of action)
- Hritz v. Woma Corp., 732 F.2d 1178 (3d Cir. 1984) (discretion in entering default judgment)
- Times Mirror Magazine, Inc. v. Las Vegas Sports News, LLC, 212 F.3d 157 (3d Cir. 2000) (factors for dilution and famous marks considerations)
- Securacom, Inc. v. Securacom, Inc., 166 F.3d 182 (3d Cir. 1999) (exceptional cases and attorney’s fees/culpable conduct)
- Opticians Ass’n of Am. v. Indep. Opticians of Am., 920 F.2d 187 (3d Cir. 1990) (irreparable injury and likelihood of confusion support injunctions)