Hatami v. Jeld-Wen
- Jon Tigar
- 4:26-cv-04217
- U.S. District Court · Northern District of California
- 3
In Farzin Hatami v. Jeld-Wen, Judge Tigar granted Jeld-Wen’s motion to dismiss the fraud and punitive-damages claims, allowing 21 days to amend.
The ruling affects the plaintiffs’ fraud and punitive-damages claims against Jeld-Wen, Inc. The plaintiffs may amend those claims within 21 days to address the identified deficiencies; otherwise, those claims against Jeld-Wen will be dismissed with prejudice.
What happened
In Farzin Hatami, et al. v. Jeld-Wen, Inc., et al., the plaintiffs claimed that Jeld-Wen represented that its product would meet their needs and would be suitable for installation by an approved installer. Jeld-Wen asked the court to dismiss the fraud claim and request for punitive damages.
The court ruled that the complaint did not provide enough specific information about the alleged misrepresentation, such as who made it, when it was made, or whether it was spoken or written. The court also said the plaintiffs did not allege that Jeld-Wen knew about a defect when it sold the door, which was necessary for a fraud claim.
Judge Jon S. Tigar granted Jeld-Wen’s motion to dismiss and allowed the plaintiffs 21 days to amend only to fix the problems identified in the order. If they do not timely amend, the fraud and punitive-damages claims against Jeld-Wen will be dismissed with prejudice.
The detailed version
- Hatami v. Jeld-Wen · No. 4:26-cv-04217
- Jon Tigar
- Sept. 8, 2026
Background
The court considered Jeld-Wen’s motion to dismiss the plaintiffs’ fraud claim and their request for punitive damages. The complaint alleged that Jeld-Wen represented that its product would meet the plaintiffs’ needs and would be appropriate when installed by an installer identified as approved, vetted, or trained by Jeld-Wen.
Fraud Claim
The court applied Federal Rule of Civil Procedure 9(b), which requires fraud to be pleaded with particularity. In practical terms, the complaint must provide enough detail about the alleged misconduct—including who made the statement, what was said, when and where it was said, and how it was misleading—to give the defendant notice of the specific claim.
The court held that the complaint did not identify who made the alleged representation, when it was made, whether it was verbal or written, or other circumstances surrounding it. The court also held that the plaintiffs did not allege that Jeld-Wen knew the door system was defective when it sold the door. The court explained that selling a defective product without knowing about the defect might support a design-defect products-liability claim, but it did not establish fraud under the allegations presented.
Punitive Damages
The court granted the motion to dismiss the punitive-damages claim for two reasons. First, the fraud claim was dismissed, and the court identified that claim as the only claim in the complaint that could support punitive damages against Jeld-Wen. Second, the plaintiffs did not identify an officer, director, or managing agent of Jeld-Wen who committed an act of oppression, fraud, or malice. The court stated that, for a corporate defendant, the required advance knowledge, conscious disregard, authorization, ratification, or wrongful act must be attributable to such a corporate agent.
Disposition
The court granted Jeld-Wen’s motion to dismiss. It granted the plaintiffs leave to amend solely to cure the deficiencies identified in the order, and required an amended complaint within 21 days of the order. If no timely amended complaint is filed, the fraud and punitive-damages claims against Jeld-Wen will be dismissed with prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.