Robert Half Inc. v. Robert Half Management Resources LLC
- Jeffrey Bryan
- 0:25-cv-01041
- U.S. District Court · District of Minnesota
- 5
In Robert Half Inc. v. Robert Half Management Resources LLC, Judge Jeffrey M. Bryan granted a default judgment against a company that had registered the name 'Robert Half Management Resources LLC' in Minnesota without authorization, permanently barring it from using the Robert Half trademarks, ordering it dissolved by the state, and requiring it to pay back any profits it made along with the plaintiff's attorney's fees.
Businesses or individuals who register company names that are identical or similar to established federally registered trademarks, particularly in the staffing or professional services industry; the ruling also directly affects the Minnesota Secretary of State, which is ordered to deregister the defendant entity.
What happened
In Robert Half Inc. v. Robert Half Management Resources LLC (Case No. 25-CV-1041), Robert Half Inc. (RHI), one of the world's largest staffing companies founded in 1948, sued a Minnesota limited liability company called Robert Half Management Resources LLC (RHMR LLC) for using its federally registered trademarks without permission. RHI alleged that in July 2024, a man named Lance Torbert registered RHMR LLC with the Minnesota Secretary of State using a name nearly identical to one of RHI's established brands. RHI never authorized this use, sent a cease-and-desist letter that received no response, and ultimately filed this lawsuit when RHMR LLC continued to ignore the matter.
Because RHMR LLC never responded to the lawsuit, the Clerk of Court entered a formal default against it on June 9, 2025. Under the rules governing default judgments, the factual allegations in RHI's complaint were treated as admitted. The court then evaluated whether a permanent injunction — a court order permanently prohibiting certain conduct — was appropriate by weighing four legal factors: RHI's likelihood of success on its claims, the risk of irreparable harm to RHI, the balance of harm between the parties, and the public interest. The court found all four factors favored RHI, noting that consumer confusion was nearly certain and that RHMR LLC had not offered any argument about harm it might suffer.
Judge Jeffrey M. Bryan granted the default judgment and issued several orders. RHMR LLC is permanently barred from using the 'ROBERT HALF' name or any mark likely to cause confusion with RHI's trademarks. It must immediately destroy all infringing materials and any means of producing them. The Minnesota Secretary of State is ordered to deregister RHMR LLC entirely. RHMR LLC must also provide RHI with an accounting of any profits it earned and pay those profits to RHI within ten days. Finally, because the court found the infringement willful and in bad faith, it declared the case 'exceptional' under the Lanham Act — the federal trademark law — making RHI eligible to recover its reasonable attorney's fees in an amount to be set after RHI submits billing records.
The detailed version
Case: Robert Half Inc. v. Robert Half Management Resources LLC, No. 25-CV-1041 (JMB/SGE), United States District Court, District of Minnesota. Decided September 18, 2025, by Judge Jeffrey M. Bryan.
Background Plaintiff Robert Half Inc. (RHI) is a specialty staffing company founded in 1948 and one of the largest of its kind worldwide. RHI holds multiple federal trademark registrations — registered with the United States Patent and Trademark Office — incorporating the phrase 'ROBERT HALF,' including Registration Nos. 1,156,612 and 6,622,283. RHI uses these marks extensively on its website, social media, job boards, and advertising materials.
In July 2024, Lance Torbert registered Defendant Robert Half Management Resources LLC (RHMR LLC) with the Minnesota Secretary of State and listed himself as the registered agent. RHI did not authorize this use. RHI learned of RHMR LLC in November 2024, sent a cease-and-desist letter, and received no response. RHI filed this lawsuit asserting claims under the Lanham Act (the federal trademark statute, 15 U.S.C. § 1051 et seq.), including trademark infringement, dilution of marks, unfair competition, unlawful trade practices, and a violation of the Minnesota Deceptive Trade Practices Act. Lance Torbert was individually dismissed from the case on May 23, 2025.
Procedural History RHMR LLC failed to respond to the lawsuit. On RHI's application, the Clerk of Court entered default against RHMR LLC on June 9, 2025, pursuant to Federal Rule of Civil Procedure 55(a), which requires the clerk to enter default when a party fails to plead or otherwise defend. RHI then moved for a default judgment under Rule 55(b)(2). A hearing was held on September 16, 2025; RHI appeared through counsel Christopher A. Young; RHMR LLC did not appear.
Legal Standard Upon entry of default, all well-pleaded factual allegations in the complaint are deemed admitted, except those relating to the amount of damages. The court must still determine whether the admitted facts support a legitimate legal cause of action, because a defaulting party does not admit conclusions of law. Murray v. Lene, 595 F.3d 868, 871 (8th Cir. 2010).
For permanent injunctive relief under the Lanham Act, 15 U.S.C. § 1116(a), the court applied the Eighth Circuit's Dataphase factors: (1) probability of success on the merits; (2) threat of irreparable harm to the movant; (3) balance of harm between the parties; and (4) the public interest. Dataphase Sys., Inc. v. C L Sys., Inc., 640 F.2d 109, 114 (8th Cir. 1981).
Analysis - Likelihood of success: The court found it reasonable to infer that RHMR LLC intended to benefit from RHI's reputation and cause consumers to believe an association existed between the two entities. - Irreparable harm: The court found consumer confusion was nearly certain, constituting irreparable harm to RHI. - Balance of harm: RHMR LLC submitted no argument about any harm it might suffer from an injunction. - Public interest: The court held that the public interest disfavors consumer confusion and trademark infringement, citing Anheuser-Busch, Inc. v. Balducci Publications, 28 F.3d 769, 776 (8th Cir. 1994).
Orders Entered Judge Bryan granted the motion for default judgment and entered the following relief:
- RHMR LLC is permanently enjoined from using the RHI Marks (including Registration Nos. 1,156,612 and 6,622,283) or any mark likely to cause confusion with or dilute the distinctiveness of the RHI Marks.
- RHMR LLC must immediately destroy all infringing advertising, promotional materials, merchandise, and any means of producing them.
- The Minnesota Secretary of State is ordered to immediately and permanently deregister Robert Half Management Resources LLC (File Number 148576500027) as a Minnesota domestic limited liability company.
- RHMR LLC must provide RHI with an accounting of all profits derived from its operations and disgorge (pay back) those profits to RHI within ten days.
- The court found the infringement willful, deliberate, and in bad faith, declaring the case 'exceptional' under the Lanham Act (15 U.S.C. § 1117). RHI is therefore entitled to recover reasonable attorney's fees; RHI must submit an affidavit with billing records within ten days, and a separate order will set the amount to be paid.
Reviewer note from the AI+
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