Ravin Crossbows, LLC v. Hunter's Manufacturing Company, Inc.
2:21-cv-02213-GMN-EJY
| D. Nev. | Mar 31, 2022Background
- Plaintiff Ravin Crossbows sued Hunter’s Manufacturing (d/b/a TenPoint) for patent infringement, alleging Hunter makes, imports, and sells crossbow models that infringe Ravin’s designs.
- Hunter moved to transfer venue to the Northern District of Ohio under 28 U.S.C. § 1404(a).
- Hunter also filed a motion to defer its deadline to file a responsive pleading until the Court decides the transfer motion, arguing efficiency and potential differences in discovery/local rules.
- Ravin opposed, noting a § 1404(a) motion does not automatically stay proceedings, asserting prejudice from delay given the parties are direct competitors, and contending Hunter offered no concrete analysis of differing local rules.
- The Court analyzed Rule 6(b) (good cause standard for extensions), its inherent docket-management power, and the Lockyer stay factors (possible damage, hardship, and whether a stay would simplify issues).
- The Court denied Hunter’s motion to defer, concluding delay would not benefit the parties, could risk information loss and continued infringement, and ordered Hunter to file a responsive pleading within 14 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should defer/extend the deadline for a responsive pleading pending a § 1404(a) transfer motion | A transfer motion does not automatically stay proceedings; deferral is prejudicial and Hunter shows no concrete rule differences | Deferral promotes efficiency and avoids triggering discovery obligations that may differ if transferred | Denied. Although Hunter was diligent, the court found no benefit to delaying the initial responsive pleading; ordered response within 14 days |
Key Cases Cited
- Landis v. N. Am. Co., 299 U.S. 248 (1936) (courts have inherent power to control their dockets and stay proceedings)
- Lockyer v. Mirant Corp., 398 F.3d 1098 (9th Cir. 2005) (stay analysis considers possible damage, hardship or inequity, and whether a stay will simplify issues)
- Johnson v. Mammoth Recreations, Inc., 975 F.2d 604 (9th Cir. 1992) (good cause for schedule extensions requires diligence by the movant)