Crs Recovery, Inc. v. John Laxton, 550 F. App'x 512

Appellants North Bay Real Estate and John Laxton appealed a jury verdict finding them liable for conversion of the domain name rl.com and declaring CRS Recovery, Inc. and Dale Mayberry the rightful owners.
Appellants contested subject-matter jurisdiction, arguing neither Mayberry nor CRS had standing at suit’s inception; the Ninth Circuit considered alternative scenarios and found standing existed under both.
Plaintiffs (CRS/Mayberry) presented evidence they demanded return of rl.com; appellants challenged sufficiency and the jury instruction about demand.
Appellants sought to admit emails and evidence about the price CRS paid for the assignment of rl.com and to cross-examine witnesses about those emails; the district court excluded certain evidence under Rule 608(b).
Appellants also challenged the district court’s fraud instruction and sought declaratory relief; the court affirmed conversion liability and rejected other claims as meritless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject-matter jurisdiction / standing at filing	CRS/Mayberry had standing from the start (owner/rightful possessor)	Appellants argued neither had standing initially	Court: Standing existed under either scenario; jurisdiction proper
Sufficiency of demand element for conversion	CRS demanded return of rl.com; demand need not explicitly claim right to possession	Appellants argued demand insufficient under cited CA instruction	Court: Demand was sufficient; jury instruction correct
Admissibility of emails and assignment price (Rule 608(b))	Emails and assignment price show witness interest/contradiction and impeach credibility	Appellants contended exclusion was erroneous and prejudicial	Court: Exclusion not an abuse; ample evidence of financial stake; any error harmless
Jury instruction on fraud vs theft (voluntary relinquishment/exploitation)	Instruction must incorporate "exploitation of carelessness" theory (per prior panel)	Appellants argued instruction misstated fraud elements	Court: Instruction properly included concept and emphasized voluntary vs involuntary relinquishment; no reversible error

Watt v. Energy Action Educ. Found., 454 U.S. 151 (standing and jurisdiction principles)
Kaahumanu v. Hawaii, 682 F.3d 789 (9th Cir. 2012) (standing analysis)
Biodiversity Legal Found. v. Badgley, 309 F.3d 1166 (9th Cir. 2002) (standing/toxic mootness principles)
Harper v. City of Los Angeles, 533 F.3d 1010 (9th Cir. 2008) (sufficiency of evidence review)
United States v. Castillo, 181 F.3d 1129 (9th Cir. 1999) (impeachment by prior inconsistent statements)
CRS Recovery, Inc. v. Laxton, 600 F.3d 1138 (9th Cir. 2010) (domain-name conversion and fraud/theft distinction)
Bank of N.Y. v. Fremont Gen. Corp., 523 F.3d 902 (9th Cir. 2008) (harmless error standard)
Dang v. Cross, 422 F.3d 800 (9th Cir. 2005) (harmless error review)
Kremen v. Cohen, 337 F.3d 1024 (9th Cir. 2003) (domain names as convertible personal property)
In re Forchion, 198 Cal. App. 4th 1284 (Cal. Ct. App. 2011) (addressed by court but not found controlling)

AFFIRMED.