AutoRABIT Holding, Inc. v. Copado, Inc.

I. BACKGROUND

15 A. Factual Background 16 Plaintiff AutoRABIT Holding, Inc. is an international software company providing 17 development operations, backup, and recovery solutions specifically designed for the Salesforce 18 platform. ECF No. 1 ¶ 9. The company was established in 2015. Id. AutoRABIT owns and 19 operates a website at the URL www.autorabit.com. Id. ¶ 13. It also owns the AUTORABIT 20 trademark. Id. ¶ 8. 21 Defendant Copado Solutions, S.L. was a Spanish entity. ECF No. 38-1 at 8–10. On June 22 12, 2016, Copado Solutions, S.L. registered the domain name autorabbit.com which redirected 23 users to the website www.copado.com. ECF No. 1 ¶ 19. In July 2021, Copado Solutions, S.L. 24 changed its name and jurisdiction of incorporation. ECF No. 38-1 at 8. The company is now 25 called Copado Holdings, Inc. and is incorporated in the United States. Id. at 8–9. 26 Defendant Copado, Inc.—the party seeking dismissal—was formed in 2018. ECF No. 22- 27 1 ¶ 3. Copado, Inc. is registered in Delaware and headquartered in Chicago, Illinois. Id. Copado, 1 Inc. offers “online software services for cloud software optimization.” Id. ¶ 2. Copado, Inc. 2 asserts…