Judge: Gail Killefer, Case: 19STCV19669, Date: 2022-09-15 Tentative Ruling

Case Number: 19STCV19669    Hearing Date: September 15, 2022    Dept: 37

HEARING DATE:                 September 14, 2022

CASE NUMBER:                  19STCV19669

CASE NAME:                        Michael Eisenberg v. Chad McQueen, et al.

MOVING PARTY:                Cross-Defendant, Phillips Auctioneers, LLC.

RESPONDING PARTIES:    Defendants/Cross-Complainant, Chad McQueen and City National Bank, as Trustee of the Terry McQueen Testamentary Trust

TRIAL DATE:                        January 10, 2023

PROOF OF SERVICE:          OK      

                                                                                                                                                           

MOTION:                               Cross-Defendants’ Motion for Summary Judgment

 

OPPOSITION:                       August 31, 2022

 

REPLY:                                  September 9, 2022.  

                                                                                                                                                           

Tentative:                                Phillips’ motion is granted. Phillips is to give notice.  

 

                                               

                                                                                                                                                           

Background

This action arises out of a letter sent on June 5, 2018, on behalf of Defendant Chad McQueen (“McQueen”) and the Estate of actor Steve McQueen, disputing the origins of a Rolex watch. Michael Eisenberg (“Plaintiff”) alleges that he and non-party Phillips Auction (“Phillips”) entered into an agreement on or about August 2, 2017, wherein Phillips agreed to auction off a Rolex Submariner watch (the “Watch”) owned by Plaintiff which had allegedly been purchased by Steve McQueen, engraved, and given to his then stuntman, Loren James. Plaintiff alleges that Defendant’s letter challenged the provenance of the Watch and asserted that Steve McQueen never owned the watch and never gifted it to Loren Janes. The letter further requested that Phillips withdraw the Watch from auction.

 

Plaintiff alleges that Defendant’s conduct caused Phillips to eventually withdraw the Watch from auction, allegedly causing the Watch to be devalued and any potential sale to fall through.

Plaintiff filed the operative Complaint on June 5, 2019, alleging four causes of action: (1) tortious interference with contract; (2) intentional interference with economic advantage; (3) negligent interference with prospective economic advantage; and (4) trade libel.

 

On December 20, 2019, Defendant and Cross-Complainant McQueen filed a Cross-Complaint against Phillips Auctioneers, LLC (“Cross-Defendant” or “Phillips”).  According to the Cross-Complaint, Cross-Defendant negligently and recklessly began advertising the watch on August 2, 2017, without verification of the Watch’s provenance. The Cross-Complaint alleged five causes of action as follows: (1) equitable indemnity on a comparative fault basis; (2) total indemnity; (3) apportionment of fault; (4) declaratory relief; and (5) negligence.

On September 22, 2021, Cross-Complainants filed the Second Amended Cross-Complaint (“SACC”).  The SACC now includes City National Bank (“City”), as Trustee of the Terry McQueen Testamentary Trust as a Cross-Complainant. The SACC alleged the following causes of action by both Cross-Complainants: (1) equitable indemnity on a comparative fault basis; (2) total indemnity; (3) apportionment of fault; (4) declaratory relief; (5) negligence; (6) negligent misrepresentation; (7) intentional misrepresentation; (8) false advertisement; and (9) violation of Civil Code § 3344.1.

 

In December 2021, the Phillips’ demurrer to the SACC was sustained from the sixth to ninth causes of action.

 

On January 4, 2022, Cross-Complainant filed a Third Amended Cross-Complaint (TACC) and changed the sixth cause of action to false advertisement and the seventh cause of action to violation of Civil Code § 3344.1.

 

On April 6, 2022, Cross-Defendant’s demurrer to the sixth cause of action of the TACC was overruled and the seventh causes of action was sustained without leave to leave.

 

On August 11, 2022, the court denied McQueen Defendants’ motion for summary judgment as to Plaintiff’s claims (“August 11 Order”).

 

Phillips now move for summary judgment or, in the alternative, summary adjudication on all of the following issues:

 

1.      Cross-Complainant’s remaining six causes of action of the TACC are without merit because no triable issues of material fact exist. 

 

Phillips’ Notice in support of the motion for summary judgment is not proper under CCP § 437c(f)(1), which provides: “A party may move for summary adjudication as to one or more causes of action within an action, one or more affirmative defenses, one or more claims for damages, or one or more issues of duty.” The Notice is not delineated and addresses the six remaining causes of action of the TACC altogether. Thus, the court will address the parties’ arguments as to each cause of action.   

 

McQueen Defendants’ Objections

 

Overruled: 3-4, 8-10, 12, 14, 25

Sustained: All remaining objections.

 

Objection 1-2: sustained, hearsay without an exception.

Objection 3-4: overruled. Declarant has personal knowledge and foundation of his own observations.  

Objection 5: sustained, Declarant lacks personal knowledge and foundation for claims regarding Plaintiff’s reputation.

Objection 6: sustained, see objections 1-2.

Objection 7: sustained, see objection 5.

Objection 8-10: overruled, see objection 3-4.

Objection 11: sustained, hearsay without an exception; Declarant also lacks personal knowledge for these claims.

Objection 12: overruled, see objection 3-4.

Objection 13: sustained, see objection 1-2.

Objection 14: overruled, see objection 3-4.

Objection 15: sustained, see objection 11.

Objection 16: sustained, Declarant has not established personal knowledge of these claims.

Objection 17-22: sustained, see objection 1-2.   

 

Objections to Declaration of Robby S. Naoufal

Objection 23-24: sustained, see objection 1-2.

Objection 25: overruled, the objection is overbroad as Cross-Complainants do not point to where objections of lack of personal knowledge have been made in the deposition record and further fail to specify why Declarant had no personal knowledge of any of the claims made during his deposition.

 

Phillips’ Objections

 

Sustained: 1-29

 

Objection 1: sustained, Declarant lacks personal knowledge and foundation, speculative.

Objection 2: sustained, hearsay without an exception.

Objection 3-29: sustained, see objection 1.

 

Discussion

 

                   I.            Legal Authority 

 

“The purpose of the law of summary judgment is to provide courts with a mechanism to cut through the parties' pleadings in order to determine whether, despite their allegations, trial is in fact necessary to resolve their dispute.”  (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 843.)  CCP § 437c(a) provides: 

 

A party may move for summary judgment in any action or proceeding if it is contended that the action has no merit or that there is no defense to the action or proceeding.  The motion may be made at any time after 60 days have elapsed since the general appearance in the action or proceeding of each party against whom the motion is directed or at any earlier time after the general appearance that the court, with or without notice and upon good cause shown, may direct….  The motion shall be heard no later than 30 days before the date of trial, unless the court for good cause orders otherwise.  The filing of the motion shall not extend the time within which a party must otherwise file a responsive pleading. 

 

A motion for summary judgment may be granted “if all the papers submitted show that there is no triable issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”  (CCP § 437c(c).)   

 

“The motion shall be supported by affidavits, declarations, admissions, answers to interrogatories, depositions, and matters of which judicial notice shall or may be taken.  The supporting papers shall include a separate statement setting forth plainly and concisely all material facts that the moving party contends are undisputed.  Each of the material facts stated shall be followed by a reference to the supporting evidence.  The failure to comply with this requirement of a separate statement may in the court’s discretion constitute a sufficient ground for denial of the motion.”  (CCP § 437c(b)(1); see also Cal. Rules of Court, rule 3.1350(c)(2) & (d).)   

 

“A party may move for summary adjudication as to one or more causes of action within an action, one or more affirmative defenses, one or more claims for damages, or one or more issues of duty, if the party contends that the cause of action has no merit, that there is no affirmative defense to the cause of action, that there is no merit to an affirmative defense as to any cause of action, that there is no merit to a claim for damages, as specified in Section 3294 of the Civil Code, or that one or more defendants either owed or did not owe a duty to the plaintiff or plaintiffs.” (CCP § 437c(f)(1).) 

 

“Notwithstanding subdivision (f), a party may move for summary adjudication of a legal issue or a claim for damages other than punitive damages that does not completely dispose of a cause of action, affirmative defense, or issue of duty pursuant to this subdivision.” (CCP § 437c(t).) 

 

In analyzing motions for summary judgment, courts must apply a three-step analysis: “(1) identify the issues framed by the pleadings; (2) determine whether the moving party has negated the opponent's claims; and (3) determine whether the opposition has demonstrated the existence of a triable, material factual issue.”  (Hinesley v. Oakshade Town Center (2005) 135 Cal.App.4th 289, 294 (Hinesley).)  CCP § 437c(p)(2) provides: 

 

A defendant or cross-defendant has met his or her burden of showing that a cause of action has no merit if the party has shown that one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to the cause of action.  Once the defendant or cross-defendant has met that burden, the burden shifts to the plaintiff or cross-complainant to show that a triable issue of one or more material facts exists as to the cause of action or a defense thereto.  The plaintiff or cross-complainant shall not rely upon the allegations or denials of its pleadings to show that a triable issue of material fact exists but, instead, shall set forth the specific facts showing that a triable issue of material fact exists as to the cause of action or a defense thereto. 

 

The court must “view the evidence in the light most favorable to the opposing party and accept all inferences reasonably drawn therefrom.”  (Hinesley, 135 Cal.App.4th at p. 294; Dore v. Arnold Worldwide, Inc. (2006) 39 Cal.4th 384, 389 [Courts “liberally construe the evidence in support of the party opposing summary judgment and resolve doubts concerning the evidence in favor of that party.”].)  A motion for summary judgment must be denied where the moving party’s evidence does not prove all material facts, even in the absence of any opposition (Leyva v. Sup. Ct. (1985) 164 Cal.App.3d 462, 475) or where the opposition is weak (Salasguevara v. Wyeth Labs., Inc. (1990) 222 Cal.App.3d 379, 384, 387).   

 

                II.            Factual Summary

 

“As noted above, this matter regards an agreement to auction off the Watch, which was alleged to have been purchased by Steve McQueen and given to stuntman Loren Janes (“Janes”) with an inscription on the case back stating ‘TO LOREN, THE BEST DAMN STUNTMAN IN THE WORLD. STEVE.’ ... Plaintiff had purchased the Rolex from Loren Janes’ daughter, Erika Janes in 2017. ... On August 2, 2017, Plaintiff entered into a contract with Phillips to auction off the Watch.” (August 11 Order, 4.)

 

In the TACC, McQueen Defendants allege that Phillips is “responsible, in whole or in part, for the injuries, if any, suffered by [Eisenberg.]” (UMF 3.) The parties agree that the Watch was purchased from Erika Janes on March 6, 2017, but dispute the “supporting documentation” which purportedly supports the provenance of the Watch. (MF 4.)

 

The parties agree that on August 2, 2017, Phillips and Eisenberg entered into a written consignment agreement (“Agreement”), whereby Eisenberg agreed to consign the Watch to Phillips to offer at auction. (UMF 5.)  The parties do not dispute that on June 5, 2018, Arthur Barens, counsel representing the estate of Steve McQueen, sent Phillips correspondence stating the McQueen family “have confirmed that [Steve] McQueen never gifted the watch in question to Loren Janes,” whereby he demanded Phillips “cease and desist from this false advertising and misrepresentation of the subject watch.” (UMF 6.) The June 5, 2018 letter affirmed that the McQueen family had “confirmed” the history of the Watch though “comprehensive historic review of the watches that Steve McQueen may have presented to his friends” and that Phillips’ “failure to do so will damage the McQueen brand and perpetuate/disseminate this fraud on an unsuspecting buyer or member of the public to whom the watch may be auctioned.” (Id.)

 

After receiving the June 5, 2018 letter, Phillips sent correspondence to Barens on June 6, 2018, seeking to clarify the objections to the legacy of the Watch. (UMF 26.) On June 8, 2018, Barens sent further correspondence to Phillips describing Jake Ehrlich (“Ehrlich”) as having “done extensive research on the provenance of the watch which Phillips intend to market[.]” (UMF 27.) The parties dispute the nature of Phillips involvement with Ehrlich’s further research following this June 8, 2018 letter. (MF 28-31.)

 

On September 14, 2018, Phillips announced it would no longer offer the Watch for auction, but stated, “we remain confident Steve McQueen gave the watch to Loren Janes based on further evidence and testimonials from people close to Steve McQueen and Loren Janes.” (MF 7.)

 

McQueen Defendants allege Phillips proximately caused damages to the Defendants by failing to verify the provenance of the Watch before advertising for auction, and that the McQueen brand has suffered damages since they “expended time and resources to evaluate the provenance and advise Cross-Defendant, and by extension expected auction bidders, that the provenance... could not be confirmed...” (UMF 8.)

McQueen Defendants had not purchased the Watch or entered into an agreement with Phillips to auction the Watch on their behalf; McQueen Defendants did not stand to benefit in any way from the sale of the Watch/ (UMF 9-11.)

 

The parties further dispute the process of establishing the provenance of the Watch by Plaintiff, and Phillips’ conduct in establishing said legacy before putting the Watch for auction. (UMF 12-21.)

 

“When asked how he knows when Steve McQueen memorabilia is not authentic, Chad responded, ‘Because I know.’ When asked to clarify if ‘that [is] just based on your own personal recollection?’ Chad responded, ‘My knowledge.’” (MF 36.) When McQueen was asked for further support for his contention, McQueen stated “Well, I have seen gifts my dad has given to other people and how they appreciate what he did for them. And that was something you could feel. And I didn't get that sense at all on this. Nor does my mother.” When asked, “Is there anything else?” Chad testified, “No.”” (MF 37.)

 

McQueen Defendants dispute the analysis done by Phillips into the Watch’s history, which Phillips contends shows the watch to have an engraving on the back of the era, dated approximately to 1964, with parts of original Rolex manufacture and of the 1960s era. (MF 38-41.)  

 

Further, McQueen was asked, “at the time you learned of the auction, did you know for absolute certainty that the watch was not given by your father to Mr. Janes?” (MF 42.) In response, McQueen stated, “Yes. I had a deep feeling.” (Id.)  After the questioner clarified, “I'm not asking whether you had a deep feeling. I'm asking whether you knew with absolute certainty,” McQueen again responded, “I believed it. I believe that was not something my dad gave to him.” (Id.) McQueen went on to reaffirm, “Yeah. Just instinctually I know what feels right and what doesn't. That doesn't feel right. And my mom -- she doesn't buy it either.” (MF 43.)

 

             III.            Analysis 

 

a.      First through Fourth Causes of Action: Indemnity, Apportionment of Fault, Declaratory Relief

 

“‘The¿elements¿of¿a¿cause¿of¿action¿for [equitable]¿indemnity¿are¿(1)¿a¿showing¿of¿fault¿on the¿part¿of the¿indemnitor¿and (2)¿resulting¿damages¿to the¿indemnitee¿for which the¿indemnitor¿is¿...¿equitably¿responsible.’¿” [citation omitted] (C.W. Howe Partners Inc. v. Mooradian (2019) 43 Cal.App.5th 688, 700.)  

 

“The comparative fault doctrine “is designed to permit the trier of fact to consider all relevant criteria in apportioning liability. The doctrine ‘is a flexible, commonsense concept, under which a jury properly may consider and evaluate the relative responsibility of various parties for an injury (whether their responsibility for the injury rests on negligence, strict liability, or other theories of responsibility), in order to arrive at an “equitable apportionment or allocation of loss.” ’ [Citation omitted.]”¿(Pfeifer v. John Crane, Inc. (2013) 220 Cal.App.4th 1270, 1285.) 

 

California courts have recognized that “[t]he existence of an ‘actual controversy relating to the legal rights and duties of the respective parties,’ suffices to maintain an action for declaratory relief.”¿ (Ludgate Ins. Co. v. Lockheed Martin Corp.¿(2000) 82 Cal.App.4th 592, 605 (Ludgate).)¿

 

“Any person interested under a written instrument, ... or under a contract, or who desires a declaration of his or her rights or duties with respect to another, or in respect to, in, over or upon property,¿ ... may, in cases of actual controversy relating to the legal rights and duties of the respective parties, bring an original action or cross-complaint in the superior court ... for a declaration of his or her rights and duties in the premises, including a determination of any question of construction or validity arising under the instrument or contract."¿ (Ibid., quoting CCP § 1060.)¿¿¿¿ 

 

Phillips contend that in order to succeed on the first four causes of action, “Defendants must show that Eisenberg could prevail on these claims directly against Phillips.” (Motion, 6; citing Children’s Hosp. v. Sedgwick, (1996) 45 Cal. App. 4th 1780, 1787.) As such, Phillips contends that since “the evidence indisputably shows that Eisenberg could not prevail against Phillips on any of his claims that he asserts against Defendants, each of Defendants’ first four causes of action against Phillips fail as a matter of law.” (Motion, 7.) Because Eisenberg’s first three causes of action for the tort of interference cannot “lie against a party to the contract,” Phillips contends it is “equitably responsible for any damages Eisenberg may have suffered.” (Motion, 7; citing Applied Equip. Corp. v. Litton Saudi Arabia Ltd., (1994) 7 Cal.4th 503, 514; Woods v. Fox Broad. Sub., Inc., (2005) 129 Cal. App. 4th 344, 350.)

 

Phillips also contends it cannot be held to indemnify McQueen Defendants as to Eisenberg’s claims of trade libel since “[n]either Phillips nor any of its agents made the statements that form the basis of Eisenberg’s trade libel claim.” (Motion, 8.) As such, Phillips maintains it “cannot be held derivatively liable for this cause of action” as well. (Id.) Further, Phillips contends “ the record is devoid of any evidence that shows Phillips could be responsible for Eisenberg’s injuries...Eisenberg’s claims stem from Defendants’ decision to challenge the provenance of the [Watch]; Phillips played no role whatsoever in that decision and therefore cannot share any responsibility for it.” (Motion, 8-9.)

 

In opposition, McQueen Defendants first contend that “Phillips’ [sic], in satisfaction of the first element, bears fault for their June 4, 2018, Press Release falsely attributing a Loren Janes-owned Rolex Submariner to Steve McQueen.” (Opp., 5.) McQueen Defendants further assert “there are eight witnesses with personal knowledge who reject the provenance attributed to the [Watch] that Phillips’ published to advertise for public auction.” (Id.) However, as the personal knowledge and foundations of these statements is not a question the court can weigh at this junction, the court continues with McQueen Defendants’ contentions. McQueen Defendants further contend that “the result of Phillips’ wrongful conduct, that is making the Press Release containing false information public, directly gave rise to this litigation. But for the Press Release, there could not and would not have been the need for McQueen to dispute the alleged provenance.” (Id.) Defendants contend Phillips has “directly injured Plaintiff” by “permitting the public dissemination of a false provenance.” (Id.) However, McQueen Defendants fail to explain how the causal chain as they described satisfies the first element—namely, shows Phillips’ fault against any of Eisenberg’s claims.

 

McQueen Defendants also contend that, regarding the trade libel claims, Phillips published these false statements “with reckless disregard” for their truth or falsity, and the testimony, declarations, and “additional evidence by film historians disputing the provenance” of the Watch “unequivocally creates” a triable issue of material fact that should be left to a jury to decide. (Opp., 6.) McQueen Defendants contend Phillips had knowledge of the inaccurate provenance of the Watch, due to Erika Janes’ alleged writing of the legacy of the Watch after the history of the Watch was disputed. (Opp., 7.)

In reply, Phillips contends “Defendants’ indemnity claims appear to be based on the theory that Eisenberg has not been injured and will lose his case.” (Reply, 2.) As such, Phillips contends “[a]ssuming Defendants are correct and Phillips’ provenance research failed to uncover defects in the provenance provided by Eisenberg, Defendants will win against Eisenberg and thereby lose their ability to obtain indemnity from Phillips.” (Id.) “Defendants ignore the fact that in order to prevail on their indemnity claims, they must show that Phillips is at fault for the injuries Plaintiff Eisenberg asserts against Defendants, which they cannot do.” (Reply, 3.) Further, Phillips contend that by arguing Phillips is derivatively liable for publishing a false statement about the provenance of the Watch, McQueen Defendants presume “Eisenberg will lose on his claims, in which event Defendants have no right to indemnity.” (Reply, 4.) Phillips contends McQueen Defendants point to no evidence which “show Phillips’ statements were ‘disparaging the quality of [Eisenberg’s] property.’” (Id.) “Indeed, only Defendants’ statement disparaging the provenance of the [Watch] caused damage to Eisenberg.” (Id.) The court agrees.

 

Here, even though the parties again heavily dispute the sequence of events, the provenance of the watch, and the truth behind the statements made regarding the provenance of the Watch, McQueen Defendants incorrectly contend that since Phillips made such statements, in contract with Eisenberg, to sell the Watch at auction, Phillips should indemnify McQueen Defendants for damages they suffered, not whatever damages Eisenberg was caused to suffer. Defendants point to no supporting authorities for this interpretation of the equitable indemnity causes of action, and cannot, since the failure of Eisenberg’s claims against McQueen Defendants would necessarily mean the failure of McQueen Defendants’ indemnity claims against Phillips.  

 

Thus, even in viewing the evidence in a light most favorable to the nonmoving party, the court finds questions of law, here the application of indemnity claims and interference tort laws against contracting parties, necessarily decide McQueen Defendants’ claims to be without merit and without support in the law.

 

For these reasons, Phillips’ motion is granted with respect to the first four causes of action.

 

b.      Fifth Cause of Action: Negligence

 

Negligence consists of the following elements: (1) the defendant owed the plaintiff a duty of care, (2) the defendant breached that duty, and (3) the breach proximately caused the plaintiff’s damages or injuries.¿ (Lueras¿v. BAS Home Loan Servicing, LP¿(2013) 221 Cal.App.4th 49, 62 (Lueras).)¿ “The existence of a duty of care owed by a defendant to a plaintiff is a prerequisite to establishing a claim for negligence.”¿ (Nymark¿v. Heart Fed.¿Savs. & Loan¿Ass’n¿(1991) 231 Cal.App.3d 1089, 1095.)¿ “Whether a duty of care exists is a question of law to be determined on a case-by-case basis.”¿ (Lueras, 221 Cal.App.4th at p. 62.)¿ 

 

Here, Phillips contends it owed no actionable duty to McQueen Defendants in issuing its press release regarding the Watch, as McQueen Defendants were a third party to the contract between Phillips and Eisenberg and did not engage with Phillips to auction, sell, purchase or attempt to purchase the Watch. (Motion, 9-10.)

 

Phillips also contends it exercised due care in issuing the press release, relying on “the provenance of the [Watch] as represented to it by Eisenberg and as supported by extensive written records and its own expert review.” (Motion, 11.) Phillips details the steps it took to investigate and inspect the watch, affirming “Phillips also took steps to independent verify what Eisenberg and the documents he provided had represented regarding the provenance of the [Watch].” (Id.) Phillips further explains that even after McQueen Defendants’ counsel had referred Phillips to researcher Jake Ehrlich, “Phillips reviewed Ehrlich’s work, to which Barens had referred, and recognized Ehrlich’s skill and knowledge as an independent investigator, and therefore sought to aid in Ehrlich’s investigation,” where Ehrlich concluded that “there is an extremely high likelihood” that the Watch was gifted by Steve McQueen. (Motion, 12.) Phillips further contends that McQueen Defendants “have failed to provide any concrete evidence” to show any statements were negligently made, and when given several chances to provide such evidence, Chad McQueen failed to do so. (Motion, 12-13.)  

 

Lastly, Phillips contends McQueen Defendants have failed to show that they have suffered any damages proximately caused by Phillips’ conduct. (Motion, 14.) Phillips contends that McQueen Defendants have failed to show what damages the McQueen brand has suffered, and also contends McQueen Defendants has failed to show any damages, expended “time and resources,” caused by Phillips’ alleged actions. (Id.) Phillips contend that their statements regarding a future action of the Watch, and their subsequent withdrawal of the Watch, could have only caused nominal damages to McQueen Defendants. (Motion, 15-16.) Phillips contends that it complied with the letter sent by McQueen Defendants’ counsel and did exactly as was requested in withdrawing the Watch from watch, “thus discrediting any claim that an unsuspecting buyer or the McQueen brand was nonetheless harmed by a transitory press release regarding an auction that never took place.” (Motion, 16.)

 

In opposition, McQueen Defendants first contend that Phillips owed a “general duty to exercise due care in publicly publicizing a false provenance [to the Watch.]” (Opp., 9.) McQueen Defendants state that by making the “Press Release containing false information public,” Phillips “directly gave rise to this litigation.” (Id.) However, McQueen Defendants again fail to explain how a causal chain here can lead to the imposition of a duty of care.

 

McQueen Defendants contend that Phillips did not exercise due care in publicizing the Watch before auction, because as a “world leading” auction house, the “many glaring” “misrepresentation” of the Loren Janes letter should have been “obvious.” (Opp., 10.) However, McQueen Defendants fail to explain where such interpretations of industry practices can be applied, and fail to provide supporting authorities for any contentions of heightened standards of duty here.

 

McQueen Defendants also delve into the credibility behind the Loren Janes, but as the court again cannot weigh credibility of evidence at this junction, the court continues with its analysis. Instead, McQueen Defendants point to declarations and a lack of endorsement by Chad McQueen as “material facts,” when no such evidence is provided beyond declarations to substantiate that these are factual contentions and questions. (Opp., 11.)

 

In Reply, Phillips correctly contends that Civil Code § 1714 cannot hold for the imposition of a duty onto Phillips here when only “economic losses” have been suffered. (Reply, 4-5; citing S. Cal. Gas Leak Cases, 7 Cal.5th 391, 400 (2019).) Further, Phillips contends that the damages suffered regard a “disgorgement of profits realized by Phillip’s [sic] for false advertisement,” which constitutes an economic loss. (Id.; citing MF 53-54, 56-62.) Phillips further correctly identifies that the standard of care for negligence is determined only “after [the court] first has determined that a legal duty exists.” (Reply, 6.) Phillips reiterates that it owed no legal duty to McQueen Defendants. (Id.)

 

Further, Phillips contends any claims for a “disgorgement of profits” shows Defendants “have not asserted any theory that they, themselves, have suffered any harm or injury, nor is there any evidence in the record that shows that they have suffered any harm or injury.” (Reply, 7.)

 

Here, viewing the evidence in the light most favorable to the nonmoving party, the court finds no triable issues of material fact that any duty was owed to McQueen Defendants by Phillips, or that Phillips proximately caused any damages suffered by McQueen Defendants. McQueen Defendants have failed to show any factual issues regarding whether a duty existed to Defendants by Phillips, where Defendants were a third party to a contract between Eisenberg and Phillips, and have failed to show any factual questions regarding whether they suffered damages as a result of any alleged actions by Phillips. Because Phillips exercised due care, even in the absence of any cognizable duty, and complied exactly with McQueen Defendants’ requests, as delineated by their counsel in the letter sent to Phillips, McQueen Defendants’ claims of any damages are without merit. McQueen Defendants’ contentions ask this court to find damages caused by Phillips’ acquiescence of McQueen’s requests, a difficult contention with no supporting authorities provided.   

 

For these reasons, Phillips’ motion is granted as to the fifth cause of action.

 

c.       Sixth Cause of Action: False Advertisement

 

California’s False Advertising Law (FAL), is set forth in Business & Professions Code § 17500 as follows: 

 

“It is unlawful for any person, firm, corporation or association, or any employee thereof with intent directly or indirectly to dispose of real or personal property or to perform services, professional or otherwise, or anything of any nature whatsoever or to induce the public to enter into any obligation relating thereto, to make or disseminate or cause to be made or disseminated before the public in this state, or to make or disseminate or cause to be made or disseminated from this state before the public in any state, in any newspaper or other publication, or any advertising device, or by public outcry or proclamation, or in any other manner or means whatever, including over the Internet, any statement, concerning that real or personal property or those services, professional or otherwise, or concerning any circumstance or matter of fact connected with the proposed performance or disposition thereof, which is untrue or misleading, and which is known, or which by the exercise of reasonable care should be known, to be untrue or misleading, or for any person, firm, or corporation to so make or disseminate or cause to be so made or disseminated any such statement as part of a plan or scheme with the intent not to sell that personal property or those services, professional or otherwise, so advertised at the price stated therein, or as so advertised. Any violation of the provisions of this section is a misdemeanor punishable by imprisonment in the county jail not exceeding six months, or by a fine not exceeding two thousand five hundred dollars ($2,500), or by both that imprisonment and fine.” 

 

Business & Professions Code § 17500 provides that it is unlawful for a person or corporation to disseminate false or misleading advertisements. To establish a FAL cause of action, Plaintiff must demonstrate the advertisement was likely to deceive or mislead consumers. (See Brockey v. Moore (2003) 107 Cal.App.4th 86, 98-99.) 

 

As Cross-Defendants correctly contend, in order to succeed in showing a claim for false advertisement, “a party must now (1) establish a loss or deprivation of money or property sufficient to qualify as injury in fact, i.e., economic injury, and (2) show that that economic injury was the result of, i.e., caused by, the unfair business practice or false advertising that is the gravamen of the claim.” (Kwikset Corp. v. Superior Court, (2011) 51 Cal.4th 310, 322 (“Kwikset”).) Further, the Kwikset court provided necessary elaboration, stating:

 

“In 2004, the electorate substantially revised the UCL's standing requirement; where once private suits could be brought by ‘any person acting for the interests of itself, its members or the general public’ ... now private standing is limited to any ‘person who has suffered injury in fact and has lost money or property’ as a result of unfair competition.

...

The intent of this change was to confine standing to those actually injured by a defendant's business practices and to curtail the prior practice of filing suits on behalf of ‘ “clients who have not used the defendant's product or service, viewed the defendant's advertising, or had any other business dealing with the defendant....” (internal citations omitted) (Kwikset, supra, at 320-22; citing Californians for Disability Rights v. Mervyn's, LLC (2006) 39 Cal.4th 223, 227-8.)

 

Here, Phillips first contends that McQueen Defendants’ claims are without merit since they have not shown any evidence of any injuries they have suffered in this case. (Motion, 17.) Phillips further contends that McQueen Defendants have failed to show any evidence with regards to the second element, causation. (Id.) Phillips contends McQueen Defendants have not shown “that the economic injury was caused by Phillips’ allegedly false advertising.” (Id.) Phillips cites Shaeffer v. Califia Farms, LLC, (2020) 44 Cal. App. 5th 1125 for this contention. In Shaeffer, the court clarified: “To prove the second element of causation, the plaintiff must show that she ‘actual[ly] reli[ed]’ on the ‘allegedly deceptive or misleading statement’ and that it ‘was an immediate cause" of her injury.’” (Shaeffer v. Califia Farms, LLC, 44 Cal.App.5th 1125, 1137.) Here, Phillips contends McQueen Defendants “have admitted that they did not rely on the allegedly false statements in Phillips’ June 4, 2018 Press Release.” (Motion, 17; citing MF 47.) As such, Phillips contend McQueen Defendants have no standing to bring forth the FAL claim. (Id.)

 

Second, Phillips contends that the only remedies available for a FAL claim are “injunctive relief and restitution,” and McQueen Defendants are not entitled to restitution “because there is no evidence that Phillips gained anything from Defendants as a result of its allegedly false advertising.” (Motion, 18; citing Veera v. Banana Republic, LLC, (2016) 6 Cal. App. 5th 907, 915.) Phillips argues that McQueen Defendants’ pointing to 121 news publications of the potential auction of the Watch still fails “to identify any profits Phillips gained from online news articles covering a scandal-ridden wristwatch that was ultimately withdrawn from auction.” (Motion, 18.) Further, Phillips contends that McQueen Defendants to not have any ownership interest in any profits Phillips allegedly gained, and also do not have “any ownership right to newsworthy reporting on the McQueen name.” (Motion, 19.) “Lost business” or any “lost market share” are not restitutionary damages recoverable under the FAL here. (Id.; citing Lee v. Luxottica Retail N. Am., Inc., (2021) 65 Cal.App.5th 793, 806.) Lastly, Phillips contends that McQueen Defendants are further not entitled to any injunctive relief since Phillips “has made clear that it does not intend to offer [the Watch] for sale in the future.” (Motion, 19-20.)

 

In opposition, McQueen Defendants simply make the conclusory claim that they have standing to bring the FAL claim, as “California’s unfair competition law (“UCL”) protects both consumers and competitors by promoting fair competition in commercial markets for goods and services.” (Opp., 12; citing Bus. & Prof. Code § 17500.) However, McQueen Defendants’ do not address Phillips’ arguments of standing as necessitating a showing of injury to bring a claim.

 

Further, McQueen Defendants reiterate their earlier contentions that information published about the Watch by Phillips was untrue, and Phillips did not exercise reasonable care in publishing the allegedly false statements. (Opp., 12-13.) McQueen Defendants also argue in support of the first element, that “no one from the McQueen family endorsed the [Watch’s] alleged provenance.” (Opp.,13.) The McQueen Defendants fail to show, however, why an endorsement from the McQueen family would be the only way for Phillips to exercise due care, or confirm the Watch’s provenance, here. McQueen Defendants make conclusory allegations about the Watch but again fail to provide evidence that would create an issue of a material fact. (Opp., 13.) Further, McQueen Defendants suggest they are entitled to restitution since: (1) “Phillips’ Press Release necessitated a response by McQueen, whose father, Steve McQueen, was falsely associated with a Rolex Submariner watch advertised for future public auction;” (2) “said response by McQueen disputing the false provenance... conferred a benefit to the general public and/or the large class of persons and/or watch enthusiasts who may have sought to purchase the [Watch]...”; (3) the false provenance placed a burden on McQueen Defendants to dispute Phillips’ contentions. (Opp., 14-15.) However, McQueen Defendants fail to elaborate, or provide supporting authorities for, the contention that McQueen Defendants conferred any benefit to potential buyers of the Watch by disputing its provenance. 

 

In reply, Phillips correctly contends McQueen Defendants do not address that “there is no evidence that Defendants have suffered an economic injury that was caused by Phillips’ conduct.” (Reply, 8.) Further, Phillips again reiterates their contentions that Defendants have not suffered any injury. (Id.) Phillips further contends they have failed to satisfy the causation element of the FAL. (Id.)

 

Also, Phillips correctly points out that McQueen Defendants rely on caselaw and supporting authorities from before Proposition 64 and the 2004 revisions to the FAL. (Reply, 9.) Specifically, Phillips correctly points again to Lee and Kwikset as delineating the new limitations of the FAL to include only claims for damages where claimant has an ownership interest. (Id.) Phillips contends there is no public benefit to McQueen Defendants’ FAL claims. (Reply, 10.) “[B]ringing the FAL claim was wholly unnecessary because Phillips ceased the allegedly offending conduct long before this case was ever filed.” (Id.) The court agrees.

 

As this court has already granted summary adjudication as to the issue of any injuries suffered by McQueen Defendants, and as McQueen Defendants have failed to show any evidence to create a triable issue of material fact regarding their damages suffered and their reliance on Phillips’ conduct, this court finds McQueen Defendants to have no standing to bring this FAL claim against Phillips as a matter of law. Thus, in viewing the evidence in a light most favorable to the nonmoving party, McQueen Defendants’ sixth cause of action is void of merit. 

 

For these reasons, Phillips’ motion is granted as to the sixth cause of action.  

 

Conclusion 

 

Phillips’ motion is granted. Phillips is to give notice.