5th Cir.

Spectrum Laboratories, L.L.C. v. URZ Trendz, L.L.C.

July 15, 2026 ·25-20572 ·Per Curiam · By James Taylor

The United States Court of Appeals for the Fifth Circuit dismissed an appeal filed by URZ Trendz against a default judgment entered in a trademark infringement case. The court held that the district court had not yet finalized the damages calculation, meaning the judgment was not yet final for appellate purposes.

Listen to this decision 0:00 / 1:09

Background

Spectrum Laboratories, a manufacturer of synthetic urine, discovered counterfeit versions of its product and sued URZ Trendz, a wholesaler, for trademark infringement and counterfeiting. After URZ failed to comply with subpoenas and discovery orders, the district court entered a default judgment against URZ, striking its defenses and awarding injunctive relief. However, the district court noted that the exact amount of damages to be awarded had not yet been quantified. URZ filed an appeal before the damages were calculated.

The court’s reasoning

The court reiterated that federal appellate jurisdiction generally requires a final decision that ends the litigation on the merits. While a judgment without a damages award can be final if the calculation is purely ministerial, the court found that determining the profits URZ obtained and the losses Spectrum suffered was more than a mechanical task. The court also rejected the argument that the injunctive nature of the order provided jurisdiction under Section twelve ninety-two, noting that discovery sanctions are typically not appealable until a final judgment is entered.

What it means going forward

Parties cannot appeal default judgments in complex cases involving unquantified damages until the district court has completed the calculation of those damages.