Supreme Court of the United States · 2003-06-02
15usc1125: author: Astra2 · not independently reviewed
Case and law context
Role: applied; posture: Review of summary judgment imposing reverse-passing-off liability; judgment reversed and remanded, with copyright issue separately unresolved.; result: claimant-lost; claim:
Uncertainty
None recorded
Misfit
None recorded
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 17
| Case | Statutory person including state entities and officials | Judicial domestic infringing-use limit | Use in commerce connected with goods or services | Enforceable source-identifying mark or trade dress | Likely consumer confusion about source or sponsorship | Entitlement to sue and protected commercial interest |
|---|---|---|---|---|---|---|
| Dastar Corp. v. Twentieth Century Fox Film Corp. — 539 U.S. 23 (2003) · Supreme Court of the United States · 2003 (15usc1125: author: Astra2 · not independently reviewed) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 7–12 of 17
| Case | Good-faith descriptive use other than as a mark | State sovereign immunity unless a valid route permits suit | Misleading affiliation approval or sponsorship | Claimant proves nonfunctionality | Commercial advertising or promotion | False or misleading factual representation |
|---|---|---|---|---|---|---|
| Dastar Corp. v. Twentieth Century Fox Film Corp. — 539 U.S. 23 (2003) · Supreme Court of the United States · 2003 (15usc1125: author: Astra2 · not independently reviewed) | · not addressed | · not addressed | · not addressed | · not addressed | ○ not reached · basis not recordedNot counted: rule-announced/hypothetical |
Elements 13–17 of 17
| Case | Judicial actual-deception or tendency-to-deceive requirement | Judicial materiality requirement for purchasing decisions | Judicial zone-of-interests limit to commercial injury | Judicial proximate-causation requirement | Remedy-specific proof |
|---|---|---|---|---|---|
| Dastar Corp. v. Twentieth Century Fox Film Corp. — 539 U.S. 23 (2003) · Supreme Court of the United States · 2003 (15usc1125: author: Astra2 · not independently reviewed) | · not addressed | · not addressed | · not addressed | · not addressed | ○ not reached · basis not recordedNot counted: applied/procedural |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| Dastar Corp. v. Twentieth Century Fox Film Corp. — 539 U.S. 23 (2003) · Supreme Court of the United States · 2003 — not · law (15usc1125: author: Astra2 · not independently reviewed) | Misleading affiliation approval or sponsorship | not Counted merits instance applied / merits basis: law; theory: Reverse passing off based on unattributed authorship; subject: theory=Reverse passing off based on unattributed authorship Authorship copying supports the alleged theory but is legally insufficient; tangible-product origin is Dastar. No ruling about ordinary source confusion, false endorsement, or product qualities is inferred. | public-domain-video-copying | To make Campaigns, Dastar purchased eight beta cam tapes of the original version of the Crusade television series, which is in the public domain, copied them, and then edited the series.Source: docroot/ir/caselaw/us_539.jsonl#/us/539/0023-01; Unicode character offsets [2270:2456] (end exclusive); SHA-256 e8c626d208ead599409c58268cc104a002fcb2cf5fa4a70d95bd12040f9b1242.Dastar manufactured and sold the Campaigns video set as its own product.Source: docroot/ir/caselaw/us_539.jsonl#/us/539/0023-01; Unicode character offsets [2992:3064] (end exclusive); SHA-256 e8c626d208ead599409c58268cc104a002fcb2cf5fa4a70d95bd12040f9b1242.In sum, reading the phrase “origin of goods” in the Lan-ham Act in accordance with the Act’s common-law foundations (which were not designed to protect originality or creativity), and in light of the copyright and patent laws (which were), we conclude that the phrase refers to the producer of the tangible goods that are offered for sale, and not to the author of any idea, concept, or communication embodied in those goods.Source: docroot/ir/caselaw/us_539.jsonl#/us/539/0023-01; Unicode character offsets [21169:21594] (end exclusive); SHA-256 e8c626d208ead599409c58268cc104a002fcb2cf5fa4a70d95bd12040f9b1242.Because we conclude that Dastar was the “origin” of the products it sold as its own, respondents cannot prevail on their Lanham Act claim.Source: docroot/ir/caselaw/us_539.jsonl#/us/539/0023-01; Unicode character offsets [23135:23273] (end exclusive); SHA-256 e8c626d208ead599409c58268cc104a002fcb2cf5fa4a70d95bd12040f9b1242. |
| Dastar Corp. v. Twentieth Century Fox Film Corp. — 539 U.S. 23 (2003) · Supreme Court of the United States · 2003 — not reached (15usc1125: author: Astra2 · not independently reviewed) | False or misleading factual representation | not_reached Excluded from merits counts rule-announced / hypothetical theory: Possible subsection (B) misrepresentation distinct from pleaded subsection (A) claim; subject: theory=Possible subsection (B) misrepresentation distinct from pleaded subsection (A) claim The Court identifies a different hypothetical advertising claim; it neither finds the relevant advertisement nor decides liability on that theory. | hypothetical-advertising/claimed-difference-from-copied-video | If, moreover, the producer of a video that substantially copied the Crusade series were, in advertising or promotion, to give purchasers the impression that the video was quite different from that series, then one or more of the respondents might have a cause of action — not for reverse passing off under the “confusion ... as to the origin” provision of § 43(a)(1)(A), but for misrepresentation under the “misrepresents the nature, characteristics [or] qualities” provision of § 43(a)(1)(B).Source: docroot/ir/caselaw/us_539.jsonl#/us/539/0023-01; Unicode character offsets [22531:23024] (end exclusive); SHA-256 e8c626d208ead599409c58268cc104a002fcb2cf5fa4a70d95bd12040f9b1242. |
| Dastar Corp. v. Twentieth Century Fox Film Corp. — 539 U.S. 23 (2003) · Supreme Court of the United States · 2003 — not reached (15usc1125: author: Astra2 · not independently reviewed) | Remedy-specific proof | not_reached Excluded from merits counts applied / proceduralThe reserved remedy question is not an element of base liability and does not establish either entitlement or ineligibility for profits in other cases. | doubling-to-deter | We thus have no occasion to consider whether the Lanham Act permitted an award of double petitioner’s profits.Source: docroot/ir/caselaw/us_539.jsonl#/us/539/0023-01; Unicode character offsets [23274:23384] (end exclusive); SHA-256 e8c626d208ead599409c58268cc104a002fcb2cf5fa4a70d95bd12040f9b1242. |