E-Z DOCK, INC.
v.
SNAP DOCK, LLC
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The court held that a motion for sanctions under Fed. R. Civ. P. 11 is premature when filed early in litigation and the claims are not patently frivolous.
E-Z Dock sued Snap Dock and Golden Manufacturing for trade dress and patent infringement. Defendants moved for sanctions under Rule 11, arguing the co…
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SNAP DOCK, LLC and GOLDEN MANUFACTURING, INC.,
Defendants. /
OPINION AND ORDER1
Before the Court is Defendants Snap Dock, LLC’s and Golden Manufacturing, Inc.’s Motion for Sanctions Pursuant to Fed. R. Civ. P. 11 (Doc. 22). This is a trade dress and patent case. In June 2021, E-Z Dock sued Defendants over its intellectual property rights to “dog bone” dock coupler products. Defendants argue the Complaint is objectively baseless and seek sanctions under Rule 11. They ask for costs, attorneys fees, and dismissal with
Rule 11 discourages frivolous claims, defenses, and motions by allowing courts to sanction parties who file (1) pleadings with no reasonable factual basis, (2) pleadings based on a legal theory with no reasonable chance of success or reasonable argument to change existing law, or (3) pleadings filed
in bad faith for an improper purpose. Worldwide Primates, Inc. v. McGreal, 87 F. 3d 1252, 1254 (11th Cir. 1996). Courts normally consider Rule 11 motions attacking pleadings at the end of litigation. Donaldson v. Clark, 819 F. 2d 1551, 1555 (11th Cir. 1987); see also
Lichtenstein v. Consol. Servs. Grp., Inc., 173 F. 3d 17, 23 (1st Cir. 1999) (“Courts should, and often do, defer consideration of certain kinds of sanctions motions until the end of trial to gain a full sense of the case and to avoid unnecessary delay of the disposition of the case on the merits. This is a sensible practice
where the thrust of the sanctions motion is that institution of the case itself was improper.”). The Court finds Defendants’ Motion premature. This action is in its infancy, and E-Z Dock’s claims are not so patently frivolous that the Court
should consider sanctions at this stage. The Court will thus deny Defendants’ Motion for now. Defendants may renew their request after adjudication of E- Z Dock’s claims, if appropriate. Accordingly, it is now ORDERED: Defendants Snap Dock, LLC’s and Golden Manufacturing, Inc.’s Motion for Sanctions Pursuant to Fed. R. Civ. P. 11 (Doc. 22) is DENIED without prejudice. DONE and ORDERED in Fort Myers, Florida on August 31, 2021.
, Lh platrathe 7
UNITED STATES DISTRICT JUDGE
Copies: All Parties of Record