Bodum USA, Inc. v. A Top New Casting, Inc.

Federal 7th Circuit Court
Civil Court
Lanham Act
Citation
Case Number: 
No. 18-3020
Decision Date: 
June 12, 2019
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Record contained sufficient evidence to support jury’s $2 million verdict in favor of plaintiff in Lanham Act action, alleging that defendant’s French Press coffeemaker infringed in plaintiff’s unregistered trade dress found in plaintiff’s Chambord French press coffeemaker. Defendant did not dispute that it had copied appearance of plaintiff’s coffeemaker, and Ct. rejected defendant’s claim that certain elements of plaintiff’s coffeemaker that plaintiff claimed were protected trade dress, i.e., its curved feet, C-shaped handle and domed lid, could not be protected because they were necessary for use of French press coffeemaker. Ct. further noted that: (1) while said elements performed "a" function with respect to operation of plaintiff’s coffeemaker, said elements were still entitled to trade dress protection, since designs of said elements used by plaintiff were not necessary to make French press coffee; and (2) record contained evidence indicating that other designs of handles, lids and feet could produce French press coffee, and thus defendant was not required to use plaintiff’s designs in its French press coffeemaker.