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American Association for Justice a/k/a Association of Trial Lawyers of America v. The American Trial Lawyers Assoc., Inc.: US District Court : CIVIL PROCEEDURE - personal jurisdiction per letters soliciting Minnesota lawyers; also over individual 'driver,' signer

1
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
American Association for Justice
a/k/a Association of Trial Lawyers of
America,
Plaintiff,
v. Civ. No. 07-4626 (JNE/JJG)
ORDER
The American Trial Lawyers
Association, Inc. a/k/a THE ATLA,
and J. Keith Givens,
Defendants.
______________________________________________________________________________
Christopher K. Larus, Esq., and Busola A. Akinwale, Esq., Robins, Kaplan, Miller & Ciresi
L.L.P., appeared on behalf of Plaintiff American Association for Justice a/k/a Association of
Trial Lawyers of America.
Marshall H. Tanick, Esq., Mansfield, Tanick & Cohen, P.A., and James E. Robertson, Jr., Esq.,
James E. Robertson, Jr. LLC, appeared on behalf of Defendants The American Trial Lawyers
Association, Inc. a/k/a THE ATLA, and J. Keith Givens.
______________________________________________________________________________
American Association for Justice a/k/a Association of Trial Lawyers of America (AAJ)
brings this actions against The American Trial Lawyers Association, Inc. a/k/a THE ATLA and
J. Keith Givens (collectively Defendants). AAJ asserts claims of trademark infringement,
unfair competition, and deceptive trade practices against Defendants. The case is before the
Court on Defendants Motion and Amended Motion to Dismiss, or in the Alternative, to Transfer
Venue to the Middle District of Alabama, Southern Division. Because this Court has specific
jurisdiction over Defendants and transfer is unwarranted, Defendants motion and amended
motion are denied.
2
I. BACKGROUND
AAJ is a worldwide nonprofit corporation headquartered in Washington, D.C. It is an
association of trial attorneys with over 56,000 members, including more than 500 members in
Minnesota. AAJ operated under the name Association of Trial Lawyers of America until it
changed its name to American Association for Justice in December 2006. Since 1976, AAJ has
owned federally protected rights to the trademark ATLA, which stands for Association of
Trial Lawyers of America. AAJ used the ATLA mark to indicate membership in the
association and in connection with the promotion and sale of its educational seminars and
conferences.
Givens is an attorney who resides in Alabama. In late 2006, Givens and his two sons,
John and Chase, conceived of an organization that would provide selected trial attorneys across
the country with practical recognition and networking and educational opportunities. In 2007,
The American Trial Lawyers Association (Association) was incorporated in Alabama, and the
Association began using the terms THE ATLA and THEALTA to promote and sell
membership in the Association and to promote its services. John and Chase Givens are the
Associations sole directors. Keith Givens is an original member of the Associations Executive
Committee. He also directs the legal matters of the Association and serves as its agent for
service of process. In March 2007, Keith Givens, acting on behalf of the Association, applied to
the United States Patent and Trademark Office (PTO) to register marks that incorporated the
term ATLA. In June 2007, the PTO refused to register one of the marks because of the
likelihood of confusion with AAJs existing marks. Defendants abandoned another application
after the PTO refused to register that mark.
3
In November 2007, as part of its national membership solicitation efforts, the Association
mailed up to 100 membership solicitation letters to selected attorneys in Minnesota. The letters
identified the Association as The ATLA and promoted the Association as an elite
organization that sought to offer practical recognition, networking and educational
opportunities, educational programs, and legal publications to trial attorneys. The letters invited
recipients to join the Association by returning an enclosed membership form and a 0
membership fee, indicated that membership would extend through the year 2008, and stated
that [u]pon receipt of your enclosed information sheet and membership dues, a formal
acceptance package with a certificate of membership into The ATLA and the Top 100 Trial
Lawyers will be mailed to you. Eight Minnesota residents responded by returning a
membership form and the 0 membership fee to a New York address identified in the letter. It
is the Associations practice to send membership certificates and promotional materials to its
members after their enrollment. AAJ subsequently brought this action seeking to protect its
rights in the ATLA mark.
II. DISCUSSION
A. Personal Jurisdiction
Defendants argue they do not have sufficient minimum contacts with Minnesota to
establish personal jurisdiction in this forum. Specifically, Defendants assert that they have no
physical presence in Minnesota and that the membership solicitation letters sent to Minnesota
residents are insufficient to support this Courts assertion of personal jurisdiction over them.
In order to defeat a motion to dismiss for lack of personal jurisdiction, the nonmoving
party must make a prima facie showing of personal jurisdiction over the defendant. Fed. R. Civ.
P. 12(b)(2); Romak USA, Inc. v Rich, 384 F.3d 979, 983 (8th Cir. 2004). When considering
4
whether the nonmoving party has met this burden, a court considers not only the pleadings, but
also the affidavits and exhibits presented for and against the motion. Dever v. Hentzen Coatings,
Inc., 380 F.3d 1070, 1072-73 (8th Cir. 2004). For the purposes of a prima facie showing, a court
must view the evidence in the light most favorable to the nonmoving party and resolve all factual
conflicts in its favor. See Digi-Tel Holdings, Inc. v. Proteq Telecomms., Ltd., 89 F.3d 519, 522
(8th Cir. 1996).
Two prerequisites must be met to establish personal jurisdiction over a nonresident
defendant. The forum states long arm statute must be satisfied and the Due Process Clause must
not be violated. St. Jude Med., Inc. v. Lifecare Intl, Inc., 250 F.3d 587, 591 (8th Cir. 2001).
Because Minnesota long arm statutes extend jurisdiction to the maximum limit consistent with
due process, the Court need only evaluate whether the assertion of personal jurisdiction over
Defendants satisfies the requirements of the Due Process Clause. See id.
Due process requires that a defendant have sufficient minimum contacts with the forum
state such that summoning the defendant would not offend traditional notions of fair play and
substantial justice. Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985); Intl Shoe Co. v.
Washington, 326 U.S. 310, 316 (1945). The nonresident defendants conduct and connection to
the forum state must be such that he should reasonably anticipate being haled into court there.
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980); Johnson v. Woodcock,
444 F.3d 953, 955 (8th Cir. 2006). This requirement is satisfied if the defendant has
purposefully directed his activities at residents of the forum and the litigation results from
alleged injuries that arise out of or relate to those activities. Burger King, 471 U.S. at 472-73
(citations omitted).
5
The Eighth Circuit Court of Appeals has established a five factor test to determine
whether minimum contacts exist sufficient to meet due process considerations: (1) the nature
and quality of the contacts with the forum state; (2) the quantity of contacts with the forum state;
(3) the relation of the cause of action to the contacts; (4) the forum states interest in the
litigation; and (5) the convenience of the parties. Johnson, 444 F.3d at 956; Pecoraro v. Sky
Ranch for Boys, Inc., 340 F.3d 558, 562 (8th Cir. 2003). Because the first three factors are
closely intertwined, they may be considered together. See Northrup King Co. v. Compania
Productora Semillas Algodoneras Selectas S.A., 51 F.3d 1383, 1388 (8th Cir. 1995). The last
two factors carry less weight and are not dispositive. Johnson, 444 F.3d at 956; see Pecoraro,
340 F.3d at 562.
1. The Association
Through the affidavit submitted by one of its Directors in support of Defendants motion,
the Association asserts that a form letter sent in November 2007 inviting a Minnesota resident to
join the Association is insufficient to establish minimum contacts between the Association and
Minnesota. The affidavit also states that the Association does not have a physical presence in
Minnesota and that, aside from the single form-letter solicitation for members, the Association
has not called on anyone in Minnesota.
Following jurisdictional discovery, it is undisputed that the Associations contacts with
Minnesota consist of up to 100 membership solicitation letters sent to Minnesota residents in
2007, as well as follow-up membership and promotional materials sent to the eight Minnesota
residents who responded to the letters. It is also undisputed that each membership solicitation
letter sent to a Minnesota resident identified the Association as The ATLA. The letters invited
recipients to join the Association by returning an enclosed membership form and a 0
6
membership fee and described various benefits and terms of membership in the Association.
The membership certificate sent to attorneys who joined the Association included the
Associations seal, which contains the words The ATLA.
Defendants correctly point out that ordinarily, contact with a forum state by mail or
phone, without more, is insufficient to justify the exercise of personal jurisdiction under the Due
Process Clause. Johnson, 444 F.3d at 955; Digi-Tel, 89 F.3d at 523 (finding letters and faxes
sent into forum insufficient by themselves to establish jurisdiction). However, it is wellestablished
that mail or phone communications may justify the exercise of personal jurisdiction
when the communications themselves give rise to the cause of action. See Oriental Trading, Inc.
v. Firetti, 236 F.3d 938, 943 (8th Cir. 2001). In its Complaint, AAJ alleges the Associations
membership mailings, including those directed to Minnesota residents, contained content that
infringes on AAJ rights in the ATLA mark, intentionally confuses the consuming public as to
the source of the membership and services offered by the Association, and falsely designates the
origin of the Associations products. Thus, AAJs causes of action against the Association arise
directly out of the mailings sent to up to 100 Minnesota residents. This Courts assertion of
specific personal jurisdiction over the Association is, therefore, supported. See Multi-Tech Sys.,
Inc. v. VocalTec Commcns, Inc., 122 F. Supp. 2d 1046, 1051-52 (D. Minn. 2000) (stating in the
patent infringement context that [s]pecific personal jurisdiction depends on the nature and
quality of the defendants contacts with the forum, so obviously a case in which the contact itself
is the wrong is a stronger case for jurisdiction than one in which the contact merely relates to the
wrong.); 3M Co. v. Icuiti Corp., Civ. No. 05-2945, 2006 WL 1579816, at * 3 (D. Minn. June 1,
2006) (Because in a trademark infringement action, the cause of action is directly related to the
contacts between Defendants and the forum, personal jurisdiction is supported.)
7
An examination of the quality and nature of the Associations contacts with Minnesota
further reveals that the Association purposefully directed communications and materials to
individual residents of Minnesota in an attempt to cultivate membership relationships with them.
In actively pursuing such business relationships with Minnesota residents, the Association should
reasonably have anticipated being haled into a court in Minnesota to answer for its conduct. See
St. Jude Med., 250 F.3d at 591-92; Northrup, 51 F.3d at 1388-89. Viewing the record in light
favorable to AAJ, the Court concludes that the first three factors support the exercise of personal
jurisdiction over the Association. See Johnson, 444 F.3d at 956; Pecoraro, 340 F.3d at 562.
The Court further concludes that the fourth and fifth factors are neutral or slightly favor a
finding of personal jurisdiction over the Association. While AAJ is not itself a resident of
Minnesota, over 500 of its members reside in Minnesota and the Association targeted
membership solicitation letters towards Minnesota residents. As for the convenience of the
parties, as discussed below, this factor favors neither party. Thus, these secondary factors do not
require a different jurisdictional determination. Accordingly, the Court concludes that AAJ has
met its burden of making a prima facie showing that the Court has specific personal jurisdiction
over the Association.
2. J. Keith Givens
The Court next considers the propriety of its assertion of personal jurisdiction over
Givens. In his affidavit submitted in support of Defendants motion, Givens states that he is not
a shareholder or officer of the Association and that the extent of his formal legal connection to
the Association is as the designated agent for service of process. He also states that he has never
been to Minnesota or, to his knowledge, transacted any business in Minnesota on behalf of the
Association or otherwise. Givens admits general involvement with the Association but contends
8
that he is not a driving participant in its activities as alleged by AAJ. He asserts that there are
insufficient minimum contacts to support this Courts assertion of personal jurisdiction over him.
Although the Complaint alleges that Givens is a shareholder and officer of the
Association, there is no support for this assertion in the record. Moreover, the Court
acknowledges that a corporate officers contacts with a forum state are not judged according to
the corporations activities there. See Minn. Mining & Mfg. Co. v Rauh Rubber, Inc., 943 F.
Supp. 1117, 1122 (D. Minn. 1996), affd, 130 F.3d 1305 (8th Cir. 1997). The Court assesses the
contacts between Givens and Minnesota on an individual basis. See Calder v. Jones, 465 U.S.
783, 790 (1984). The key inquiry is whether he was a primary participant[] in an alleged
wrongdoing intentionally directed at a resident [of the forum state]. Alternative Pioneering
Sys., Inc. v. Direct Innovative Prod., Inc., Civ. No. 4-92-78, 1992 WL 510190, at *2 (D. Minn.
Aug. 20, 1992) (citing Calder, 465 U.S. at 790 ).
During jurisdictional discovery, Givens testified as the Associations Rule 30(b)(6)
designee. His deposition testimony revealed that he and his two college-aged sons conceived of
and formed the Association together. The elder son, John, testified that his fathers position as
an Alabama attorney provided him and his brother with access to the legal community that led to
the creation of the Association. Givens recruited the original members of the Associations
Executive Committee, of which he was a member, and the Associations Executive Director is
the wife of one of his law partners. The Association has enjoyed the use of office space
controlled by his law firm and in buildings in which Givens has a financial interest without
paying rent for that use (rent has accrued, but has not been paid). Although he could not recall
whether he actually provided funding to the Association, Givens testified that he would have
made his own personal funds available to the Association if he had been asked to do so.
9
Collectively, this evidence reveals Givens to be more than just an agent for service of process or
a casual participant in the business activities of the Association.
As for direct participation by Givens in the infringing activities alleged by AAJ in this
lawsuit, the Associations responses to discovery interrogatories specifically indicate that Givens
was personally involved in the Associations decisions regarding the solicitations of membership
to the Association, including directing solicitations to Minnesota residents. As previously
discussed, mail communications may justify the exercise of personal jurisdiction when the
communications themselves give rise to the cause of action. See Oriental Trading, 236 F.3d at
943. Givens testified that he personally signed some of the membership solicitation letters sent
by the Association to prospective members, and he does not dispute that some of these letters
were sent directly to Minnesota residents. By his own testimony, Givens establishes that he was
an active participant in the planning and decision-making process that culminated in the creation
and distribution of the solicitation letters to Minnesota residents. AAJ submits affidavits
establishing that Givens had knowledge of AAJs rights in the ATLA mark at the time the
membership solicitation letters were sent. There is no dispute that these letters identified the
Association as The ATLA and promoted the Association as an elite organization that sought
to offer practical recognition, networking opportunities, educational programs, and legal
publications to trial attorneys.
Because a single contact with a forum state can be sufficient to establish specific personal
jurisdiction, Fulton v. Chicago, Rock Island & P.R. Co., 481 F.2d 326, 334-36 (8th Cir. 1978),
the exact number of letters Keith Givens sent to Minnesota residents is not particularly relevant.
See Lakin v. Prudential Secs., Inc., 348 F.3d 704, 711 n. 10 (8th Cir. 2003) (indicating that when
specific jurisdiction is being alleged, the quantity of contacts is not determinative). By
10
personally and intentionally directing allegedly infringing activity toward Minnesota residents,
Givens should reasonably have anticipated being called to court in Minnesota to answer for his
conduct. See Calder, 465 U.S. at 790-91. The Court concludes that AAJ has met its burden of
making a prima facie showing that the Givens purposefully directed infringing activities at the
residents of Minnesota, and showing that the nature and quality, and quantity of these contacts
are sufficient to subject him to the specific personal jurisdiction of this Court.
In sum, the Court concludes that AAJ has met its burden of making a prima facie
showing of specific personal jurisdiction over the Association and Givens. Defendants have not
demonstrated that litigation in this forum would be unfair or unreasonable. Accordingly,
Defendants request for dismissal due to a lack of personal jurisdiction is denied.
B. Transfer to the Middle District of Alabama
Defendants move alternatively to transfer venue of this action to the Middle District of
Alabama, Southern Division, pursuant to 28 U.S.C. 1406(a), 1404(a) (2000). Defendants
argue proper venue lies in Alabama and not in Minnesota.
1. 28 U.S.C. 1406(a)
Section 1406(a) directs that a court in which is filed a case laying venue in the wrong
division or district shall dismiss, or if it be in the interest of justice, transfer such case to any
district or division in which the case could have been brought. 28 U.S.C. 1406(a) (2000). In
a civil action where jurisdiction is not founded solely on diversity, venue is proper in a judicial
district in which a substantial part of the events or omissions giving rise to the claim occurred, or
a substantial part of property that is the subject of the action is situated. 28 U.S.C.
1391(b)(2)(2000).
11
Plaintiffs argue that a substantial part of the events giving rise to their claimsnamely
the directing of up to 100 membership solicitation letters that infringed on AAJs marks
occurred in Minnesota. There is no dispute that Defendants sent similar solicitation letters to
other states or that the Association has successfully recruited members from other states,
including Alabama, in larger numbers than in Minnesota. However, to determine whether venue
is proper, a court does not ask which district among potential forums is the best venue.
Pecoraro, 340 F.3d at 562; Setco Enters., Corp. v. Robbins, 19 F.3d 1278, 1281 (8th Cir. 1994).
Instead, a court asks whether the district selected by the plaintiff had a substantial connection to
the claim, without regard to whether other forums had greater contacts. Pecoraro, 340 F.3d at
562; Setco Enters., 19 F.3d at 1281.
Viewed in light favorable to AAJ, the record reveals that Minnesota has substantial
connection to the claims AAJ asserts. As discussed above, the Association and Givens sent
membership solicitation letters into Minnesota for the purpose of inducing Minnesota residents
to join the Association. The Association admits that it sent follow-up membership materials to
Minnesota residents who responded. AAJ alleges that these communications infringed on its
trademark rights and sought to falsely trade on the substantial goodwill established by AAJ in its
marks. Consequently, if harm occurred in Minnesota, a substantial part of the events giving rise
to AAJs claims occurred in Minnesota. See Woodke v. Dahm, 70 F.3d 983, 985 (8th Cir. 1995)
(Lanham Act case indicating that the place where the alleged passing off occurred provides
an obviously correct venue); see also Pilates, Inc. v. Pilates Institute, Inc., 891 F. Supp. 175,
182 (S.D.N.Y.1995) (noting that [a]lmost all cases that have addressed the language of 1391(b)
have construed it to mean that venue may be proper in more than one district and that in
trademark infringement claims, courts have held that venue may be proper in each jurisdiction
12
where infringement is properly alleged to have occurred). Under these circumstances, although
Defendants solicitation activities in another state may have been more substantial, the Court
concludes that Minnesota has a substantial connection to the claims asserted by AAJ such that
venue is proper here. Therefore, transfer under section 1406(a) for improper venue is
unavailable.
2. 28 U.S.C. 1404(a)
Defendants also seek transfer to the District of Alabama pursuant to 28 U.S.C. 1404(a),
which provides [f]or the convenience of the parties and witnesses, in the interest of justice, a
district court may transfer any civil action to any other district or division where it might have
been brought. The party seeking a transfer ordinarily bears the burden of establishing that a
transfer is warranted. Terra Intl, Inc. v. Miss. Chem. Corp., 119 F.3d 688, 695 (8th Cir. 1997).
A motion to transfer an action to another district should be denied unless the balance of factors
strongly favors the moving party. See Graff v. Qwest Commcns Corp., 33 F. Supp. 2d 1117,
1121 (D. Minn. 1999). The decision whether to transfer an action lies within the discretion of
the district court. Everett v. St. Ansgar Hosp., 974 F.2d 77, 79 (8th Cir. 1992).
In support of its motion to transfer, Defendants contend that the convenience of the
parties and witnesses weighs heavily in favor of transfer of venue in this case. Defendants note
that they are residents of Alabama and claim that virtually all of the witnesses for this case reside
in Alabama. Defendants assert that the Associations documents are located there as well.
Defendants further contend that none of the factors favor Minnesota as a forum and claim that
the only basis for AAJs maintaining this case in Minnesota is that its current president and a
small percentage of its lawyer members reside in Minnesota.
13
After considering the factors outlined in Terra International and the relevant
circumstances in this case, the Court concludes that Defendants have not made the required
strong showing to support transfer of venue. AAJ is a District of Columbia organization that is
run by volunteers and conducts its business in locations convenient to its leadership and
members. AAJs current president and over 500 of its members are residents of Minnesota. As
many as 100 Minnesota residents received Defendants allegedly infringing mailings. Eight
Minnesota residents responded to the solicitations by sending membership forms and dues to the
Association. On the other hand, Defendants are in Alabama and witnesses and records relating
to the Associations activities and the membership forms and dues sent by Minnesota residents in
response to the solicitations are located in Alabama and possibly New York.
Under these circumstances, the Court concludes that the convenience factor does not
weigh in favor of either party because some level of inconvenience is inevitable in this case
wherever the venue. While Defendants raise several points that would make the District of
Alabama more convenient for them, they have not persuaded the Court that a transfer would
result in any more than a shift of the inconvenience from Defendants to AAJ. Transfer is
unwarranted under these circumstances. See Janel Russell Designs, Inc. v. Mendelson &
Assocs., Inc., 114 F. Supp. 2d 856, 862 (D. Minn. 2000).
Defendants also argue that transfer will serve the interest of justice. Examination of the
interest of justice can include considerations of judicial economy, obstacles to a fair trial, conflict
of law problems, and advantages of having a local court determine local law. Nelson v. Soo Line
R. R. Co., 58 F. Supp. 2d 1023, 1027 (D. Minn. 1999). Defendants focus their argument on
considerations of judicial economy asserting that transfer would allow this case to be joined with
14
an already existing parallel case between the Association and the American College of Trial
Lawyers currently pending in the District of Alabama. The Court is not persuaded.
A review of Defendants supporting exhibits reveals the lawsuit currently pending
between the Association and the American College of Trial Lawyers is a declaratory judgment
involving the mark AMERICAN COLLEGE OF TRIAL LAWYERS and the Associations
use of the name The American Trial Lawyers Association. The marks and infringing
activities in the already pending Alabama case are different from the marks and infringement
allegations in the instant lawsuit. The Court concludes that Defendants have failed to
sufficiently substantiate their claim of parallel cases or demonstrate that the two cases involve
substantial overlap. Thus, Defendants have not demonstrated that the interest of justice
strongly favors transfer. Because Defendants have failed to meet their burden of establishing
that a transfer is warranted under section 1404(a), the Court denies their alternative motion to
transfer venue.
III. CONCLUSION
Based on the files, records, and proceedings herein, and for the reasons stated above, IT
IS ORDERED THAT:
1. Defendants Motion to Dismiss, or in the Alternative, to Transfer Venue to the
Middle District of Alabama, Southern Division [Docket No. 6] and Amended
Motion to Dismiss, or in the Alternative, to Transfer Venue to the Middle District
of Alabama, Southern Division [Docket No. 11] are DENIED.
Dated: July 1, 2008
s/ Joan N. Ericksen
JOAN N. ERICKSEN
United States District Judge
 

 
 
 

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