Takeaway: The Ninth Circuit ruled that plaintiffs can recover substantial damages and attorney fees in default judgments even without specifying exact amounts in their complaint, highlighting that general requests for relief "to be proven at trial" satisfy Rule 54(c) — a key takeaway for litigants seeking full remedies after defaults.

The Ninth Circuit recently issued an important ruling in AirDoctor LLC v. Xiamen Qichuang Trade Co. Ltd., reviving AirDoctor’s claim for $2.5 million in damages and $50,000 in attorney(s)' fees following a default judgment against a competitor in a trademark and unfair competition case. The case is particularly interesting because it clarifies how much money and attorney(s)' fees can be awarded in default judgments when those amounts were not specifically pled in the initial complaint. A lower court had denied the damages request under Rule 54(c) of the Federal Rules of Civil Procedure, arguing that default judgments cannot exceed what is demanded in the pleadings. But the Ninth Circuit reversed, finding that AirDoctor’s general request for damages “to be proven at trial” met the rule’s requirements. The court emphasized that plaintiffs are not required to list exact damage amounts in their complaint to later recover them in default, as long as the type of relief sought is consistent. The decision adds clarity to the scope of recoverable damages and attorney(s)' fees in default judgment cases within the Ninth Circuit.