U.S. Polo Ass’n v. PRL USA Holdings

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USPA appealed from a contempt order finding USPA in violation of a permanent injunction. The district court held that USPA's Double Horsemen Mark on eyewear products was confusingly similar to the logo used by PRL. The district court concluded that the Fragrance Injunction barred use of the Double Horsemen Mark in every market but that for apparel. The court, however, agreed with USPA that the underlying injunction did not enjoin all uses of the mark. Because of the often unpredictable results of market-by-market analysis, a finding that the Double Horsemen Mark is, when used on eyewear, confusingly similar to PRL’s marks, while sufficient to find liability in an infringement proceeding, is not sufficient to support a contempt finding. The fact that the Apparel Litigation does not shield USPA’s use of a Double Horsemen Mark on eyeglasses from an infringement finding does not, without more, render it liable for infringement in that and all other markets save for apparel. Therefore, the court vacated the contempt order and remanded for further proceedings. View "U.S. Polo Ass'n v. PRL USA Holdings" on Justia Law