Au New Haven, LLC v. YKK Corporation
- Gregory Woods
- 1:15-cv-03411
- U.S. District Court · Southern District of New York
- 4
In Au New Haven v. YKK Corporation, Judge Woods adjourned trial and allowed renewed summary-judgment briefing on issues raised before trial.
The plaintiffs and defendants were affected by the changed trial and pretrial-conference dates and by the defendants’ permission to file a renewed summary-judgment motion. The order also affected the planned jury trial.
What happened
Au New Haven, LLC v. YKK Corporation involves claims by the plaintiffs against YKK defendants, including claims under the Lanham Act and Connecticut’s Unfair Trade Practices Act. The opinion addressed scheduling and pretrial motions before trial.
The court decided that the defendants should be allowed to present certain issues through renewed summary-judgment motions, rather than through their pretrial motions. The court also allowed the defendants to raise arguments about whether those laws apply outside the United States.
Judge Gregory H. Woods adjourned the jury trial from January 13, 2020, to June 15, 2020, and moved the final pretrial conference to May 28, 2020. The order did not decide the underlying claims or the renewed summary-judgment arguments.
The detailed version
- Au New Haven, LLC v. YKK Corporation · No. 1:15-cv-03411
- Gregory Woods
- Dec. 20, 2019
Background
The case was scheduled for a jury trial beginning January 13, 2020. The defendants had filed Motion in Limine No. 10 and a motion under Federal Rule of Civil Procedure 16. During a December 19, 2019 telephone conference, the parties addressed issues concerning the claims and the plaintiffs’ damages theories.
The defendants had not raised these issues in their earlier summary-judgment briefing. The court stated that the issues developed from its summary-judgment decision and what might have been a change in the plaintiffs’ damages theory. The defendants also argued that the plaintiffs had not timely disclosed their damages theory for their Lanham Act and Connecticut Unfair Trade Practices Act claims, and that the inadequate disclosures prevented the defendants from filing summary-judgment motions addressing those claims.
Court’s reasoning
The court concluded that allowing additional summary-judgment briefing was a more appropriate way to address the claimed prejudice than excluding the plaintiffs’ damages evidence entirely. The court also noted that the defendants could potentially raise the issues in a motion for judgment after the evidence at trial, but it considered resolving issues that could substantially affect the trial before trial to be preferable.
The court held that a motion in limine or a Rule 16 motion was not the proper vehicle for deciding the issues because resolving them required reference to a factual record. The court identified a motion for summary judgment under Rule 56 as the proper mechanism for deciding them before trial.
Order
The court adjourned the jury trial to June 15, 2020, at 9:00 a.m., and adjourned the final pretrial conference to May 28, 2020, at 10:00 a.m. The defendants were granted leave to present the arguments from Motion in Limine No. 10 and the Rule 16 motion, along with arguments concerning the extraterritorial application of the Lanham Act or the Connecticut Unfair Trade Practices Act, in a renewed motion for summary judgment.
The renewed motion was due January 8, 2020. The plaintiffs’ opposition was due January 24, 2020, and the defendants’ reply was due January 31, 2020. The court required the motions to comply fully with the requirements for a standard Rule 56 motion and stated that it intended to decide the motion promptly. The order did not decide the merits of the claims or the issues to be presented in the renewed motion.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.