Deckers Outdoor Corporation v. Wolverine Group Pty Ltd
1:24-cv-03164
N.D. Ill.Apr 28, 2025Background
- Deckers Outdoor Corporation (Deckers), owner of the UGG trademark, alleges that various Australian entities—Wolverine Group Pty Ltd, Wild Wool Australia Pty Ltd, Wild Wool Productions Pty Ltd, Wild Wool Retail Pty Ltd—and their Managing Director, Todd Watts, infringed and diluted its UGG trademarks.
- Defendants are closely held, managed by Watts, and operate out of the same address; ownership and management are interwoven among Watts, his family trust, and the entities.
- Wolverine licensed Australian UGG trademarks to WWP and WWR, which manufacture and sell UGG-branded products, some of which are sold online and potentially in the U.S.
- Plaintiff seeks jurisdictional discovery to respond to defendants' motions to dismiss for lack of personal jurisdiction and to contest corporate independence.
- Defendants claim insufficient basis for jurisdictional discovery, asserting formal independence and U.S. non-involvement for some entities, and that requested discovery is burdensome or already addressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to jurisdictional discovery | Sufficient colorable claim for discovery on jurisdiction and alter ego/veil-piercing theories | Plaintiff hasn't shown enough to justify discovery; entities are independent | Granted in part; plaintiff gets targeted discovery |
| Production of license agreements | Needs all relevant License Deeds and related documents | Only produced recent documents, will produce others if found | Granted; must produce all responsive license documents |
| Production of facility and rental documents | Documents on facilities, lease agreements, and rental payments are relevant | No undue burden (no direct objection argued) | Granted where such documents exist, to be produced |
| Rule 30(b)(6) deposition | Watts is the best witness; deposition necessary for clarity | Deposition is unduly burdensome, especially travel to U.S. | Granted; deposition may proceed, but not necessarily in U.S. |
Key Cases Cited
- Cent. States, Se. & Sw. Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934 (7th Cir. 2000) (establishes standard for when jurisdictional discovery should be allowed; "colorable" showing of jurisdiction required)
- Judson Atkinson Candies, Inc. v. Latini-Hohberger Dhimantec, 529 F.3d 371 (7th Cir. 2008) (mere overlap in ownership/control is insufficient to pierce corporate veil)
- Purdue Research Found. v. Sanofi-Synthelabo, S.A., 338 F.3d 773 (7th Cir. 2003) (plaintiff must present evidence, not mere allegations, if jurisdiction is challenged with affidavits)