Coinbase v. Honscha

Background

Coinbase, Inc. moved for default judgment against Tobias Honscha. Coinbase alleges that Honscha, a resident of Germany, is using the domain name “coinbase.de” in violation of an Affiliate Agreement with Coinbase and Coinbase’s trademark rights. The court had scheduled a hearing on the motion for September 30, 2026.

Additional jurisdiction and venue information

The court requested supplemental briefing and evidence concerning personal jurisdiction, meaning the court’s authority over Honscha, and venue, meaning whether this federal district is the proper place for the claims to be litigated. Coinbase asserted a cybersquatting claim under 15 U.S.C. § 1125(d)(1)(A) and a breach-of-contract claim based on the Affiliate Agreement. The court noted that Coinbase had not supplied the Affiliate Agreement or explained the basis for venue. It directed Coinbase to establish personal jurisdiction and proper venue for each claim separately.

Damages evidence

Coinbase requested $100,000 in statutory damages for use of the coinbase.de domain, the maximum amount identified in the order under 15 U.S.C. § 1117(d). The court stated that although allegations in the complaint are treated as true for deciding liability after a default, evidence is still needed to support a request for the maximum damages amount. The court found that Coinbase’s existing evidence—a declaration and a screenshot of a paid advertisement—did not provide information about the actual damage allegedly caused by Honscha’s use of the domain. Coinbase was directed to provide evidence supporting the requested amount and showing that it would not be a windfall.

Attorney-fee evidence

Coinbase requested $155,761.50 in attorney fees for work by partner Gina Durham, associate Jordan Chisek, and paralegal Michelle Burch. The court found that the existing evidence, primarily Durham’s statement that the listed rates were charged in the case, was insufficient because the rates appeared high. It requested additional evidence of prevailing rates in the Northern District of California, such as third-party rate surveys or declarations from people knowledgeable about current local rates. The court also requested billing records to evaluate whether the claimed 134.6 hours were reasonable given the limited litigation in the case. The order permitted Coinbase to redact specific confidential or privileged content and seek to seal unredacted records under the district’s procedures.

Ruling and next hearing

The court ordered Coinbase to provide the requested supplemental materials and continued the hearing to November 4, 2026, at 9:30 a.m. by Zoom. Judge Joseph C. Spero did not decide the default-judgment motion, Coinbase’s liability claims, damages, or attorney fees.