The U.S. District Court for the Western District of New York is no stranger to clashes in the crowded beauty pageant arena, and this quarter U.S. Senior District Judge David G. Larimer applied the well-known preliminary injunction standards to determine whether a loss of social media followers amounts to irreparable harm. In addition, he had occasion to re-visit a case reported on last quarter in the environmental arena. This time he addressed a motion for leave to file an amended complaint, or in the alternative, for an order entering final judgment on claims that were previously dismissed.

Pageant Background

In Mrs. United States Natl. Pageant v. Williams, 353 F. Supp. 3d 213 (W.D.N.Y. 2019), Mrs. United States National Pageant (plaintiff), sued its former licensee Stephanie L. Williams and two businesses she operated, Crown Garland (collectively, Williams and Crown Garland are referred to as defendants) and Cosmos International Pageants (Cosmos) alleging trademark infringement, misappropriation of trademarks, breach of contract, and tortious interference with business relations.