Toyota Motor Sales, U.S.A., Inc. v. Allen Interchange LLC
- Katherine Menendez
- 0:22-cv-01681
- U.S. District Court · District of Minnesota
- 5
In Toyota v. Allen, Magistrate Judge Docherty denied Toyota permission to seek reconsideration of two discovery rulings because one was appealed and Toyota showed no compelling circumstances.
Toyota Motor Sales, U.S.A., Inc. and Toyota Motor North America, Inc. were denied permission to seek reconsideration of two discovery rulings; Allen Interchange LLC opposed the request.
What was alleged
The complaint alleges that the defendants imported and sold automotive parts bearing Toyota trademarks that were manufactured for sale outside the United States and were not authorized for sale in the United States — what the complaint calls 'gray market goods.' The complaint claims these parts have material differences from genuine Toyota parts sold domestically, including differences in warranty coverage and packaging standards. The complaint seeks disgorgement of profits and injunctive relief — a court order to stop the alleged conduct — for claimed violations of the federal Lanham Act (covering trademarks and false advertising) and related state and common-law claims. The complaint also alleges that, despite prior cease-and-desist demands, the defendants continued to import and sell these parts.
What happened
Toyota Motor Sales, U.S.A., Inc. v. Allen Interchange LLC concerned Toyota’s request for permission to ask the court to reconsider two discovery decisions from February 11, 2025. One decision involved documents about counterfeit parts; the other required Toyota to produce Dealer Contact Reports for 250 dealers.
The court said the counterfeit-parts issue was already being reviewed by District Judge Menendez, so it would not consider reconsideration of the same issue at the same time. For the Dealer Contact Reports, Toyota did not identify new evidence or other compelling circumstances, and the court said Toyota’s request was untimely because Toyota had not included that issue in its appeal.
Magistrate Judge Docherty denied Toyota’s request for permission to file a motion for reconsideration. The order did not itself resolve the parties’ underlying claims.
The detailed version
- Toyota Motor Sales, U.S.A., Inc. v. Allen Interchange LLC · No. 0:22-cv-01681
- Katherine Menendez
- Apr. 2, 2025
Background
The court had previously entered a February 11, 2025 order addressing discovery disputes. Toyota asked for permission under District of Minnesota Local Rule 7.1(j) to file a motion for reconsideration of two parts of that order. That rule requires a party to obtain the court’s permission before filing such a motion and to show compelling circumstances.
The Two Discovery Issues
First, Toyota wanted to seek reconsideration of the decision barring it from obtaining documents about whether Allen had received counterfeit parts. The court said that issue was already on appeal to District Judge Katherine M. Menendez. It also explained that whether Allen had possessed counterfeit parts was irrelevant to whether Toyota had made general statements that gray-market distributors might mix counterfeit parts with gray-market parts to interfere unlawfully with the automotive-parts market. Because the issue was already on appeal, the court declined to consider reconsideration of it.
Second, Toyota wanted to challenge the order requiring it to produce Dealer Contact Reports for 250 Toyota dealers. Allen sought the reports to develop its claims that Toyota had used dealer contacts to intimidate dealers into stopping purchases from gray-market distributors. The court acknowledged that producing the reports would impose a significant burden, but had previously determined that the discovery was relevant and proportionate to the needs of the case under Federal Rule of Civil Procedure 26(b)(1).
Court’s Reasoning
The court concluded that Toyota had not identified information supporting reconsideration that was not already presented during the original discovery dispute. Toyota referred generally to newly discovered evidence but did not identify what that evidence was. The court therefore found no compelling circumstances supporting permission to seek reconsideration.
The court also found the request concerning the Dealer Contact Reports untimely. Toyota had 14 days to object to the discovery order and had appealed several other decisions, but it had not included the Dealer Contact Reports issue in that appeal. Allen had begun identifying the dealers for which it would seek reports. The court stated that, even if Toyota had shown compelling circumstances, reconsideration would be inappropriate because Toyota had not timely appealed that issue.
Disposition
Magistrate Judge John F. Docherty denied Plaintiffs’ Request for Leave to File a Motion for Reconsideration, Docket No. 373. The order denied permission to file the reconsideration motion; it did not itself decide the parties’ underlying claims.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.