Summary
The United States District Court for the Central District of California granted Minjie Zheng’s motion to remand the action to Los Angeles County Superior Court. The court held that the First Amended Complaint did not clearly assert a federal antitrust claim, and that ambiguity was insufficient to establish federal-question jurisdiction under the well-pleaded complaint rule. The court denied the defendant’s motion to dismiss and the plaintiff’s motion for leave to amend as moot.
Topics
Practice areas
Questions Presented
- Whether the first amended complaint presented a federal question on its face sufficient to support removal jurisdiction.
- Whether an ambiguous reference to U.S. antitrust law and Plaintiff's filing of a similar federal action established federal-question jurisdiction.
- Whether the defendant's motion to dismiss and Plaintiff's motion for leave to amend remained justiciable after remand was granted.
Holdings
- The first amended complaint did not present a federal-law claim on its face because its antitrust claim did not identify a federal statute and the complaint could fairly be read as asserting only state-law claims.
- Ambiguity in the complaint must be resolved in favor of remand when the removing party cannot establish federal subject-matter jurisdiction.
Key quotations
“There is a “strong presumption” against removal jurisdiction, and “[f]ederal jurisdiction must be rejected if there is any doubt as to the right of removal in the first instance.”” (at 3)
“The Court concludes that no federal law claim appears on the face of Plaintiff’s FAC.” (at 5)
“Because the FAC could fairly be read to raise only state law claims, the Court GRANTS Plaintiff's Motion to Remand.” (at 6)
Factual background
Plaintiff, a Chinese citizen, alleged that ICANN and Verisign improperly reserved and registered certain one- and two-character .COM domain names. After domain-name applications were denied, Plaintiff pursued antitrust litigation in China and later challenged the registration and reservation practices involving names such as cm.com and o.com. The first amended complaint asserted antitrust violations, declaratory relief, breach of contract, and unfair business practices, seeking domain-name registrations, declarations, and $35,000 in compensation.
Procedural history
Plaintiff filed the action in Los Angeles County Superior Court on May 20, 2025, and filed a first amended complaint on May 27, 2025. Verisign removed the action to federal court on July 7, 2025. Plaintiff filed multiple requests to remand, with the court recognizing the operative consolidated motion to remand. The court granted remand and denied the pending motions as moot.
Remand instructions
The action was remanded to Los Angeles County Superior Court, and the federal case was closed.