Coach, Inc. v. 3d Designers Inspirations

The Sale of Counterfeit Items Bearing a Highly Distinctive Registered Trademark Constitutes Trademark Infringement.

Opinion (Darrow): Plaintiff Coach, Inc. (“Coach”) i sells high-end accessories such as handbags and watches. Defendant 3D Designers Inspirations (“3D”) sells similar types of accessories. Coach claimed that 3D infringed upon its trademark by selling counterfeit products bearing Coach trademarks. 3D did not obtain Coach’s authorization to place the trademarks on their accessories. According to the Lanham Act, “the use, without the registrant's consent, of a copy, counterfeit, or imitation of a registered trademark in connection with the advertising or sale of goods or services where such use "is likely to cause confusion, or cause mistake, or to deceive” is prohibited. The Court applied a two-prong test to determine whether or not 3D had committed trademark infringement. As to the first prong, Coach must show that “its marks are distinctive enough to be worthy of protection.” The second prong requires that " the defendant's use of those marks is likely to cause consumers to be confused as to the source of the product.” The Court determined that Coach’s trademarks are “registered and highly distinctive.” Due to the unique nature of Coach’s registered trademarks it is likely that a consumer would easily confuse the counterfeit items with genuine Coach accessories. Therefore, the motion for default judgment filed by the Plaintiff was GRANTED.