Rimowa Distribution, Inc. v. Travelers Club Luggage, Inc., 1:15-cv-10330

Background

Rimowa Distribution, Inc. (Delaware corp., HQ in Texas; subsidiary of German Rimowa GmbH) sued Travelers Club Luggage, Inc. (California wholesaler) for trademark infringement, trade dress infringement, dilution, counterfeiting, and unfair competition under the Lanham Act and Massachusetts common law.
Rimowa’s asserted trade dress includes its distinctive uniformly spaced groove-and-ridge luggage pattern and registered U.S. trademarks.
Rimowa prefers the District of Massachusetts for litigation (trademark counsel located there; witnesses from Germany and Canada find Boston a convenient hub); annual Massachusetts sales exceed $1 million.
TCL sells luggage through national retailers (Amazon, Target, Bed Bath & Beyond, Sears) and maintains a website linking to retailer listings; it has no offices, warehouses, or employees in Massachusetts and does not directly sell to Massachusetts customers.
TCL moved to dismiss for lack of personal jurisdiction (Fed. R. Civ. P. 12(b)(2)) or, alternatively, to transfer the case to the Central District of California under 28 U.S.C. § 1404(a). The court denied both motions.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal jurisdiction—specific: whether TCL’s sales in MA support jurisdiction	Rimowa: TCL’s products were offered for sale in ~200 MA brick-and-mortar stores and TCL’s website directs customers to national retailers; those contacts are related to the trademark claims	TCL: No offices, employees, or direct sales in MA; contacts insufficient for jurisdiction	Held: Specific jurisdiction exists. Sales in MA satisfy relatedness and purposeful availment; exercising jurisdiction is reasonable.
Personal jurisdiction—general: whether TCL’s contacts with MA are continuous/systematic	Rimowa: Nationwide distribution through major retailers and website support general jurisdiction	TCL: Lack of physical presence and direct sales in MA preclude general jurisdiction	Held: Court addressed primarily specific jurisdiction; general jurisdiction not established on these facts.
Purposeful availment/stream of commerce: whether TCL targeted MA market	Rimowa: Directing website users to national retailers and widespread retail placement show intentional targeting and regular flow into MA	TCL: Sales into MA incidental/fortuitous and do not amount to targeting	Held: TCL’s intentional channels to national retailers and widespread retail presence in MA satisfy purposeful availment.
Transfer of venue under §1404(a): whether convenience and justice warrant transfer to Central District of California	Rimowa: Massachusetts is convenient for its counsel and witnesses; plaintiffs’ choice entitled to deference	TCL: California is more convenient for defendant and its witnesses; prefers Central District of California	Held: Transfer denied. Plaintiff’s forum choice carries presumption; convenience factors (witnesses, travel, case progress, court workloads) do not strongly favor transfer.

Key Cases Cited

Sawtelle v. Farrell, 70 F.3d 1381 (1st Cir. 1995) (plaintiff bears burden to establish jurisdiction; standards for prima facie showing)
United States v. Swiss Am. Bank, Ltd., 274 F.3d 610 (1st Cir. 2001) (prima facie standard where no evidentiary hearing on jurisdiction)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (due process protects against being haled into a forum without meaningful contacts)
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (stream-of-commerce and foreseeability principles; purposeful availment analysis)
McGee v. Int’l Life Ins. Co., 355 U.S. 220 (U.S. 1957) (national or international businesses may be subject to suit in fora where they purposefully direct activities)
Stewart Org., Inc. v. Ricoh Corp., 487 U.S. 22 (U.S. 1988) (§1404(a) transfer requires individualized, case-by-case consideration of convenience and fairness)
Gulf Oil Corp. v. Gilbert, 330 U.S. 501 (U.S. 1947) (strong presumption in favor of plaintiff’s choice of forum)