Trader Joe's Co. v. Hallatt, No. 14-35035 (9th Cir. 2016)
Annotate this CaseTrader Joe's filed suit against defendant for trademark infringement and unfair competition under the Lanham Act, 15 U.S.C. 1051 et seq., and Washington law after defendant purchased Trader Joe's-branded goods in Washington state and transported them to Canada for resell in a store defendant designed to mimic a Trader Joe's store. The district court dismissed the Lanham Act and state law claims for lack of subject matter jurisdiction. The court held, consistent with recent case law from the Supreme Court and this court, that the extraterritorial reach of the Lanham Act raises a question relating to the merits of a trademark claim, not to federal courts’ subject-matter jurisdiction. The court concluded, on the merits, that Trader Joe’s alleges a nexus between defendant's conduct and American commerce sufficient to warrant extraterritorial application of the Lanham Act. Therefore, the court reversed as to the Lanham Act claim. The court affirmed the dismissal of the state law claims because Trader Joe’s did not allege trademark dilution in Washington or harm to a Washington resident or business.
Court Description: Lanham Act / Extraterritorial Application. The panel affirmed in part and reversed in part the district court’s dismissal of trademark infringement and unfair competition claims for lack of subject-matter jurisdiction. Defendant Michael Norman Hallatt purchased Trader Joe’s-branded goods in Washington State, transported them to Canada, and resold them there in a store he designed to mimic a Trader Joe’s store. Trader Joe’s sued under the Lanham Act and Washington law. Reversing the dismissal of the Lanham Act claims, the panel held that the extraterritorial reach of the Lanham Act raises a question relating to the merits of a trademark claim, not to federal courts’ subject-matter jurisdiction. On the merits, the panel concluded that Trader Joe’s alleged a nexus between Hallett’s conduct and American commerce sufficient to warrant extraterritorial application of the Lanham Act. The panel affirmed the dismissal of the state law claims because Trader Joe’s did not allege trademark dilution in Washington or harm to a Washington resident or business. The panel remanded the case to the district court for further proceedings. TRADER JOE’S V. HALLATT 3
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.