Simpson Strong-Tie Company Inc. v. MiTek Inc.

I. BACKGROUND

26 Simpson is a California corporation that designs, manufacturers, and sells structural 27 connectors for use in building construction. Dkt. No. 1 ¶¶ 2, 9-10. Simpson assigns individual alphanumeric product names for each of its products. Id. ¶¶ 12-13. Each product name includes a “part name” consisting of a letter or combination of letters designating the product line, and a “model number” consisting of additional numbers and letters appended to the part name to distinguish between various models of a particular part with different attributes. Id. According to Simpson, it invests considerable time and effort in creating part names and model numbers. Id. ¶ 14. Simpson uses its product names on its website and product packaging, as well as in catalogs, publications, and other advertising materials, including its Wood Construction Connectors Catalog. Id. ¶¶ 16-20, 22. The Wood Construction Connectors Catalog contains an alphabetical product index and various charts specifying various attributes of Simpson’s products, listed by product names. Id. ¶¶ 19-20. Simpson has registered copyrights in the Wood Construction…