The U.S. District Court for the District of New Jersey granted Mitsubishi Motors North America, Inc.’s motion for a preliminary injunction and denied the cross-motion seeking reinstatement of its dealership agreement brought by Saliba Investment LLC d/b/a J&S Mitsubishi (J&S), holding that Mitsubishi lawfully terminated the dealership for good cause under the New Jersey Franchise Practices Act (NJFPA). Saliba Inv. LLC d/b/a J&S Mitsubishi v. Mitsubishi Motors N. Am., Inc., 2026 WL 1960846 (D.N.J. July 7, 2026). Following the termination, J&S continued to use Mitsubishi’s trademarks and held itself out as an authorized dealer in breach of the dealership agreement. The court concluded that Mitsubishi was likely to succeed on its trademark infringement claim under the Lanham Act because the dealership agreement had been validly terminated.
The court found that J&S was not entitled to the Act’s automatic stay provision because it filed suit after the termination became effective and failed to establish equitable estoppel. Rejecting J&S’s argument that a subsequent notice of breach superseded the notice of termination, the court held that Mitsubishi had established good cause for termination based on J&S’s material breach of the dealership agreement. Although J&S claimed it had cured the alleged deficiencies relating to staffing, training, and inventory requirements, Mitsubishi presented evidence that the employees hired to satisfy critical staffing and training obligations did not work in the required dealership roles at J&S and instead were employed at an affiliated business. The court concluded that the staffing deficiencies alone constituted a material breach, as outlined in the dealership agreement, and therefore provided good cause for termination under the NJFPA. Applying the preliminary injunction factors, the court found that Mitsubishi was likely to succeed on the merits of its trademark infringement claim, was entitled to a presumption of irreparable harm under the Lanham Act, faced equities that favored relief because J&S’s injuries were self-inflicted, and demonstrated that the public interest favored preventing consumer confusion arising from J&S’s continued use of Mitsubishi’s marks.