V.V.V. & Sons Edible Oils Limited v. Meenakshi Overseas LLC
2:14-cv-02961
E.D. Cal.Jun 20, 2025Background
- This is a trademark dispute between V.V.V. & Sons Edible Oils Limited (Plaintiff) and Meenakshi Overseas LLC (Defendant) over the use of the mark "IDHAYAM" for sesame oil.
- Defendant Meenakshi Overseas LLC owns a federal trademark registration for "IDHAYAM" and sells sesame oil under that mark in the U.S.
- Plaintiff claims it has priority use of the IDHAYAM mark and seeks cancellation of Defendant’s registration.
- Defendant moved to exclude the testimony of Plaintiff’s expert, Dr. Thomas J. Maronick (retained survey expert), and non-retained expert Janarthanan Rajaratnam (import/export industry witness).
- The hearing addressed the admissibility of these witnesses’ testimony under Rules 701 and 702 and associated disclosure rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Maronick’s expert survey testimony | Survey is relevant and reliably measures likelihood of confusion | Survey is irrelevant and unreliable due to sampling, no control, and methodology | Testimony admissible; issues go to weight, not bar. |
| Admissibility of Rajaratnam as an expert witness | Rajaratnam should testify about importation practices as an expert | Lacks qualifications, and inadequate disclosures under Rule 26 | Excluded as expert witness. |
| Admissibility of Rajaratnam as a lay/fact witness | Permitted as lay witness due to personal knowledge from business experience | Testimony as lay witness should be blocked due to failure to disclose properly | Permitted as lay witness under Rule 701. |
| Scope of Rajaratnam’s testimony at trial | Should cover import practices through personal experience | Should be strictly limited, defendant can object if it exceeds scope of Rule 701 | Scope limited to Rule 701; objections allowed. |
Key Cases Cited
- Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993) (establishes the trial court’s gatekeeping role for expert testimony).
- Primiano v. Cook, 598 F.3d 558 (9th Cir. 2010) (expert testimony must be based on reliable knowledge and methods).
- Cooper v. Brown, 510 F.3d 870 (9th Cir. 2007) (relevance of expert testimony turns on assistance to trier of fact).
- Guidroz-Brault v. Mo. Pac. R.R. Co., 254 F.3d 825 (9th Cir. 2001) (expert testimony must not be unsupported speculation).
- United States v. Lopez, 762 F.3d 852 (9th Cir. 2014) (lay witness personal knowledge requirement).