Mighty Dreams LLC v. Shenzhen Beianen Automotive Supplies Co Ltd
2:24-cv-00793
| W.D. Wash. | Jun 9, 2025Background
- Mighty Dreams LLC, a seller of knife sharpening stones on Amazon, filed a false advertising suit against competitors Shenzhen Beianen Automotive Supplies Co., Ltd. and Shenzhen Changfuwei Furniture Co., Ltd., alleging unfair competition via Amazon seller accounts.
- Defendants allegedly manipulated the Amazon Buy Box and falsely advertised discounted prices that matched regular retail prices.
- Defendants did not appear or respond after service by email, so the court entered default against them.
- Mighty Dreams moved for default judgment, seeking monetary damages, injunctive relief, and an asset freeze.
- The Court examined whether Mighty Dreams’ factual allegations were sufficient to establish claims under the Lanham Act, the Washington Consumer Protection Act, and Washington common law.
- The Court denied default judgment without prejudice, citing insufficient pleading, and granted leave to amend the complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether having multiple seller accounts constitutes false advertising | Multiple seller accounts by Defendants manipulate Amazon’s Buy Box, misleading consumers | No appearance/argument | Insufficient pleading; no plausible link shown between multiple accounts and consumer deception |
| Whether Lightning Deals pricing constitutes false advertising | Defendants falsely represent normal prices as temporary discounts | No appearance/argument | Insufficient and inconsistent allegations as to what constitutes the “normal” price |
| Whether sufficient factual allegations were pleaded for Lanham Act & CPA claims | Factual details provided in complaint and exhibits are adequate | No appearance/argument | Allegations were inconsistent, vague, and did not establish required elements |
| Whether plaintiff is entitled to default judgment | Defendant’s default and sufficient claims entitle Mighty Dreams to relief | No appearance/argument | Default judgment denied; claims not adequately pleaded |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaints must state plausible, not just conceivable, claims)
- Eitel v. McCool, 782 F.2d 1470 (9th Cir. 1986) (factors for considering default judgment)
- Cripps v. Life Ins. Co. of N. Am., 980 F.2d 1261 (9th Cir. 1992) (well-pleaded facts are deemed true on default, but insufficient claims are not established)
- Southland Sod Farms v. Stover Seed Co., 108 F.3d 1134 (9th Cir. 1997) (defining falsity for Lanham Act false advertising claims)
- Dewitt Constr. Inc. v. Charter Oak Fire Ins. Co., 307 F.3d 1127 (9th Cir. 2002) (elements of the Washington Consumer Protection Act claim)