/us/539/0023-01

Coverage and quality

3 annotation blocks; 1 merits instance blocks; 1 distinct cases with counted merits instances; 2 excluded blocks.

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Counting rules and source integrity

Counted instances require applied citation role, merits scope, and a reached holding. Procedural, not-reached, comparator, and other context remains visible but is excluded from counts.

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Database snapshot SHA-256: b8882353247abdd6e20d4e22922c166d68ccb8e2da50e13e0162a35c316318f8. 3301 source quotations verified across this snapshot.

Supreme Court of the United States · 2003-06-02

Original case on neochart.com

Case and law context

15 U.S.C. § 1125(a)

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:

Instances and excluded annotation blocks

Annotation blocks, including explicitly excluded context
Case	Element	Holding and scope	Variant	Exact source quotations
/us/539/0023-01 — Supreme Court of the United States · 2003	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.	origin-of-goods/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`. Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged) 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`. Evidence kind: fact; polarity: cuts-against; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged) 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`. Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged) 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`. Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)
/us/539/0023-01 — Supreme Court of the United States · 2003	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`. Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)
/us/539/0023-01 — Supreme Court of the United States · 2003	Remedy-specific proof	not_reached Excluded from merits counts applied / procedural The reserved remedy question is not an element of base liability and does not establish either entitlement or ineligibility for profits in other cases.	profits/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`. Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations recorded from this case