TOWN & COUNTRY LINEN CORP. and TOWN & COUNTRY HOLDINGS v. INGENIOUS DESIGNS LLC
TOWN & COUNTRY LINEN CORP. and TOWN & COUNTRY HOLDINGS, INC. v. INGENIOUS DESIGNS LLC
- Lewis Liman
- 1:18-cv-05075
- U.S. District Court · Southern District of New York
- 3
In TOWN & COUNTRY LINEN CORP. v. INGENIOUS DESIGNS LLC, Judge Schofield granted reconsideration and reinstated part of the dismissed claim.
The plaintiffs’ Count V misappropriation-of-ideas claim concerning the Aramid Fiber Luggage Project was no longer dismissed. The order affected the plaintiffs and the defendants in the case but did not finally resolve the claim’s merits.
What happened
TOWN & COUNTRY LINEN CORP. and TOWN & COUNTRY HOLDINGS, INC. sued INGENIOUS DESIGNS LLC and others. The court had previously dismissed Count V, which alleged that the defendants misappropriated ideas under New York common law, including ideas concerning an Aramid Fiber Luggage Project.
The plaintiffs asked the court to reconsider the dismissal as it applied to the Aramid Fiber Luggage Project ideas. They argued that their allegations described specific, concrete ideas implemented in prototypes, involving a proprietary weaving pattern and fabric that was not commercially available or off-the-shelf.
Judge Lorna G. Schofield granted the motion for reconsideration and vacated the dismissal of Count V as to the Aramid Fiber Luggage Project claim. The order did not state that the plaintiffs had ultimately won that claim.
The detailed version
- TOWN & COUNTRY LINEN CORP. and TOWN & COUNTRY HOLDINGS v. INGENIOUS DESIGNS LLC · No. 1:18-cv-05075
- Lewis Liman
- Mar. 2, 2020
Background
The court had earlier granted in part and denied in part the defendants’ motion to dismiss the plaintiffs’ Second Amended Complaint. That earlier order dismissed Count V, a New York common-law claim for misappropriation of ideas. A later opinion explained that ruling.
The plaintiffs moved for reconsideration of the dismissal as to ideas related to the Aramid Fiber Luggage Project. Reconsideration is an unusual request asking a court to correct an overlooked controlling decision or data, consider new evidence, or correct a clear error or prevent serious unfairness. It is not intended to allow a party to relitigate old issues.
Court’s analysis
Judge Schofield found that the plaintiffs had shown enough error to warrant reconsideration. The court said the earlier opinion should have considered the ideas’ specificity and their commercial availability. The complaint described a particular Oxford fabric weave using aramid fibers only in the weft for luggage products, specified an aramid-fiber percentage range, and described spacing between the fibers. It also alleged that the ideas were implemented in working prototypes, involved a proprietary weaving pattern, and concerned fabric that was not commercially available or off-the-shelf.
At the motion-to-dismiss stage, the court accepted the complaint’s factual allegations as true and drew reasonable inferences in the plaintiffs’ favor. The court concluded that the identified patents did not establish a lack of novelty because their descriptions did not reflect the specific features alleged by the plaintiffs, and they did not show that similar products were commercially available before the alleged misappropriation.
Disposition
The court ordered that the plaintiffs’ motion for reconsideration was GRANTED. It vacated the dismissal of Count V as to the claim involving the Aramid Fiber Luggage Project. The order did not decide the ultimate merits of that claim. The court also directed the Clerk to close the reconsideration motion and reinstate the reassignment of the case to Judge Lewis J. Liman.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.