Amazon.com Inc v. Does 1-20

United States District Court, Western District of Washington · July 7, 2025 · No. 2:23-cv-01879

Summary

This district court order denies pro se defendant Domantas Radeckas's motion to set aside a default judgment entered against him for failing to answer an amended complaint in Amazon's trademark infringement lawsuit. The court found that Radeckas's failure to respond constituted culpable conduct and that he failed to demonstrate a meritorious defense or extraordinary circumstances justifying relief under Federal Rules of Civil Procedure 60(b)(1) and 60(b)(6).

Court
United States District Court, Western District of Washington
Writing for the Court
James L. Robart
Jurisdiction
United States District Court, Western District of Washington
Decision date
July 7, 2025
Docket number
2:23-cv-01879
Procedural posture
Defendant's motion to set aside default judgment under Fed. R. Civ. P. 60(b)
Standard of review
de novo
Precedential value
nonprecedential
Disposition
other

Topics

default judgmentcivil procedure

Practice areas

civil procedureintellectual property

Questions Presented

  1. Whether the court should set aside the default judgment under Fed. R. Civ. P. 60(b)(1) based on alleged mistake, inadvertence, surprise, or excusable neglect
  2. Whether the court should set aside the default judgment under Fed. R. Civ. P. 60(b)(6) based on extraordinary circumstances

Holdings

  1. The court denied relief under Rule 60(b)(1) because the defendant was culpable and failed to demonstrate a meritorious defense.
  2. The court denied relief under Rule 60(b)(6) because the defendant's arrest was not an extraordinary circumstance that prevented him from prosecuting the case.

Key quotations

Rule 60(b)(1) provides that a final judgment may be set aside for “mistake, inadvertence, surprise, or excusable neglect.”
The court, however, agrees with Amazon that Mr. Radeckas’s conduct was culpable.

Factual background

Amazon sued multiple defendants for alleged large‑scale refund fraud. A default judgment of $2,000,000 and a permanent injunction were entered against Defendant Domantas Radeckas on February 25, 2025. Radeckas was arrested in Lithuania in December 2024, claimed lack of access to counsel, and later filed a motion to set aside the default judgment.

Procedural history

The court entered a default judgment against Defendant on February 25, 2025. Defendant filed a motion on June 4, 2025 to vacate the judgment under Rule 60(b)(1) and (b)(6). The court considered the motion and denied it.

Court Document

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