Traffix Devices, Inc. v. Marketing Displays, Inc.

532 U.S. 23 (2001) Supreme Court of the United States 2001-03-20

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)

Facts

  1. 5 Claimant proves nonfunctionality not no-evidence
    A utility patent is strong evidence that the features therein claimed are functional.
  2. 5 Claimant proves nonfunctionality not no-evidence
    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.
  3. 5 Claimant proves nonfunctionality not no-evidence
    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.
  4. 5 Claimant proves nonfunctionality not no-evidence
    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.”
  5. 5 Claimant proves nonfunctionality not no-evidence
    MDI has pointed to nothing arbitrary about the components of its device or the way they are assembled.