United States Golf Assn. v. Arroyo Software Corp

In United States Golf Assn. v. Arroyo Software Corp. (1999) 69 Cal.App.4th 607, the Court declined to give collateral estoppel effect to prior findings by a federal court relating to claims of misappropriation of service marks, because the prior action took place in a different legal context. (Id. at pp. 617-619.) There, the defendant sought to shield itself from the misappropriation claims, by arguing that the plaintiff's action was barred by an earlier Third Circuit decision. (Id. at pp. 610-611.) After noting the difference between California and New Jersey law on the issue of direct competition, we held the plaintiff's claims were not precluded because "the issues decided under New Jersey law in the federal case were not identical to those arising under California law. . . ." (Id. at pp. 618-619.)