Source: cases/15usc1125/us-532-23-traffix-v-marketing-displays.case
Case source: https://www.neochart.com/catalog/cases/us/volume_532/0023_01/index.html
A utility patent is strong evidence that the features therein claimed are functional.
The rule we have explained bars the trade dress claim, for MDI did not, and cannot, cany the burden of overcoming the strong evidentiary inference of functionality based on the disclosure of the dual-spring design in the claims of the expired patents.
Functionality having been established, whether MDI’s dual-spring design has acquired secondary meaning need not be considered.
casedsl 1 case /us/532/0023-01 name Traffix Devices, Inc. v. Marketing Displays, Inc. cite 532 U.S. 23 (2001) court Supreme Court of the United States date 2001-03-20 url catalog/cases/us/volume_532/0023_01/index.html source ir/caselaw/us_532.jsonl sha1=ede8b5c7c96734c26b17d781baa9fb74f26bd9d7 chars=20895 law 15usc1125 role applied posture Supreme Court reviews reversal of summary judgment against trade-dress claimant; restores functionality bar and remands; separate trademark-name judgment not before Court. result claimant-lost element nonfunctional-dress : not-satisfied [no-evidence] variant utility-patent/dual-spring-road-sign theory Functional design claimed in expired utility patents rule @8727..8812 | A utility patent is strong evidence that the features therein claimed are functional. fact @11915..12127 [cuts-against] | The dual-spring design serves the important purpose of keeping the sign upright even in heavy wind conditions; and, as confirmed by the statements in the expired patents, it does so in a unique and useful manner. fact @13171..13357 [cuts-against] | The dual-spring design affects the cost of the device as well; it was acknowledged that the device “could use three springs but this would unnecessarily increase the cost of the device.” fact @18959..19061 [cuts-against absent] | MDI has pointed to nothing arbitrary about the components of its device or the way they are assembled. held @9620..9871 | The rule we have explained bars the trade dress claim, for MDI did not, and cannot, cany the burden of overcoming the strong evidentiary inference of functionality based on the disclosure of the dual-spring design in the claims of the expired patents. gloss No-evidence reflects inability to overcome functionality on the summary-judgment record, reinforced by a legal evidentiary rule. The Court does not create an absolute patent-expiration bar for ornamental features; cany is preserved OCR. element protected-mark : not-reached variant secondary-meaning/functional-design theory Source recognition does not cure functionality held @16826..16952 | Functionality having been established, whether MDI’s dual-spring design has acquired secondary meaning need not be considered. gloss Secondary meaning not resolved by this Court; the lower court decisions on it are not imported as appellate merits findings.