Laureate Education, Inc. v. Laureate Learning Center, Inc., 1:15-cv-01756

Laureate Education, Inc. owns registered LAUREATE trademarks and sued Laureate Learning Center, Laureate Medical Institute, and Carla B. Jones for trademark infringement and alter-ego liability.
Plaintiff obtained a default judgment and injunction against LLC and LMI in SDNY; case was later transferred to the Northern District of Georgia.
After transfer, Plaintiff added Jones as a defendant and served discovery; Defendants repeatedly failed to respond to discovery, subpoenas, and a deposition.
Court granted motions to compel and for sanctions, awarding Plaintiff $24,811.50 in attorney’s fees and $586.28 in expenses and holding Jones jointly and severally liable.
Jones filed for Chapter 13 bankruptcy the day fees were due, temporarily staying collection; the stay expired and Defendants still did not pay.
Plaintiff moved for default judgment; the court found repeated discovery violations and willful noncompliance, struck Defendants’ answer, entered default judgment, and issued a permanent injunction prohibiting use of LAUREATE/LAUREATTE and related confusingly similar marks.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether default judgment and striking the answer are appropriate sanctions for discovery violations	Laureate argued repeated refusals to comply with discovery and prior orders justify default as a last-resort sanction	Defendants did not offer a valid excuse for noncompliance (bankruptcy by Jones temporarily stayed enforcement but did not excuse other defendants)	Court held default judgment appropriate; answer stricken due to pervasive noncompliance
Whether lesser sanctions could ensure compliance	Laureate argued prior lesser sanctions (fee awards) were ignored; default is necessary	Defendants offered no effective alternative or compliance efforts	Court found lesser sanctions insufficient and imposed default
Whether a permanent injunction should issue against defendants	Laureate sought permanent injunctive relief to stop confusing use of LAUREATE/LAUREATTE	Defendants did not contest injunctive relief on the record	Court entered a permanent injunction barring use of LAUREATE/LAUREATTE and related confusingly similar marks
Whether further monetary damages beyond fees should be awarded	Laureate asked for enforcement of prior fee award and possibly further relief	Defendants failed to pay but offered no justification	Court ordered defendants to pay the earlier awarded fees and expenses but denied any additional damages

Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (federal courts have inherent power to sanction abuses of the judicial process)
Malautea v. Suzuki Motor Co., Ltd., 987 F.2d 1536 (11th Cir. 1993) (district court discretion under Rule 37 is guided by judicial interpretation)