Reported / Citable
Background
Pro se plaintiff Victor Quinteros brought trademark-infringement and unfair-competition claims against Danny Nguyen, Danny Nguyen Couture, and Hloyal Management & PR. He alleged ownership and registration of the “Houston Fashion Week” mark and alleged that defendants used the similar phrase “Fashion Week Houston.”
On June 26, 2026, Quinteros moved ex parte for a temporary restraining order and preliminary injunction under Rule 65(b). He sought to bar defendants, their marketing networks, and venue partners from using “Fashion Week Houston” or “Houston Fashion Week” during a five-night runway production scheduled for June 24 through June 28, 2026.
The Court’s Holding
Magistrate Judge Richard W. Bennett recommended that the motion be denied as moot. By the time of the recommendation, the June 24–28 event had already occurred, so the court could no longer grant the emergency, date-limited relief Quinteros requested.
The recommendation explained that Article III requires a live case or controversy and that a request becomes moot when intervening events make effective relief impossible. The magistrate judge also concluded that Quinteros had not shown entitlement to a preliminary injunction.
Key Takeaways
- A request to enjoin a completed, specifically dated event may be moot once the event has passed.
- Rule 65 emergency relief still requires a live controversy and the showing required for preliminary injunctive relief.
- The ruling is a memorandum and recommendation; the parties had fourteen days after receipt to file written objections.
Why It Matters
Trademark plaintiffs seeking emergency relief tied to a scheduled event must move early enough for a court to provide meaningful relief. Once the challenged event concludes, an injunction limited to that event generally cannot remedy the alleged harm.
The recommendation addresses only the requested emergency relief, not the ultimate merits of Quinteros’s trademark and unfair-competition claims.