Lifetime Well LLC v. Mouzn, LLC, and Does 1-10

Background

Lifetime Well LLC asserted copyright, trademark, and other claims against Mouzn, LLC, based on Mouzn’s operation of the website mouzn.com. Lifetime Well moved for a default judgment, damages, and attorneys’ fees and costs. The amended complaint also named unknown operators of the website as Doe defendants after Lifetime Well could not locate Mouzn at its purported headquarters and learned that Mouzn was not registered to do business in New York.

Personal-jurisdiction issue

Before entering a default judgment, the court must determine that it has personal jurisdiction—the legal authority to bind the defendant in the case. That jurisdiction must satisfy both New York law and the federal Constitution.

Lifetime Well argued that jurisdiction existed because Mouzn represented that it was a New York limited liability company headquartered in New York. The court explained that New York’s long-arm statute does not establish jurisdiction based only on such a representation. The court also concluded that Lifetime Well had not adequately pleaded either general jurisdiction, based on where Mouzn was domiciled, organized, or principally based, or specific jurisdiction, based on Mouzn’s purposeful contacts with New York that were connected to Lifetime Well’s claims.

The court noted that Lifetime Well had not specifically alleged that Mouzn’s website was accessible in New York, that it was interactive and allowed sales, that Mouzn shipped products to New York, or that the hearing aids at issue had been shipped there. Lifetime Well’s allegation that Mouzn caused consumer confusion in New York suggested a possible New York market, but the court found that allegation too conclusory to show the nature of Mouzn’s New York contacts.

Ruling

The court found that Lifetime Well had not provided sufficient evidence concerning personal jurisdiction over Mouzn. It granted Lifetime Well an opportunity to supplement the record and ordered a further submission explaining the basis for jurisdiction over the defendants by July 30, 2026. The order did not grant or deny the default-judgment motion, and it did not decide the underlying infringement claims.