Judicial zone-of-interests limit to commercial injury

AND · 15usc1125:commercial-injury

Lexmark’s zone-of-interests inquiry limits the statutory cause of action. A business suing only as a disappointed purchaser is like an ordinary consumer; commercial loss must fit the protected interest.

Exact element source

shall be liable in a civil action by any person who believes that he or she is or is likely to be damaged by such act.
Source: docroot/ir/usc/title15.jsonl#title15_sec1125; Unicode character offsets [870:988] (end exclusive); SHA-256 0a5680239d11ae3247a99abab2344db45177346d2d2e3050e95c82fb39f3aca7.

All variants

Recorded DB variant labels, including zero-count variants
VariantDescriptionMerits instance blocksDistinct casesExample cases (up to 3 per group)
zone-of-interests/reputation-and-sales1
Satisfied 1; not satisfied 0; excluded context 0
1/us/572/0118-01 — Supreme Court of the United States · 2014 — satisfied

How courts decided this element

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopeVariantExact source quotations
/us/572/0118-01 — Supreme Court of the United States · 2014Judicial zone-of-interests limit to commercial injurysatisfied
Counted merits instance
applied / merits

basis: pleaded; party: Static Control; subject: party=Static Control

Statutory protected commercial interest is adequately alleged; the holding does not establish damages or success on all advertising elements.
zone-of-interests/reputation-and-sales
We thus hold that to come within the zone of interests in a suit for false advertising under § 1125(a), a plaintiff must allege an injury to a commercial interest in reputation or sales.
Source: docroot/ir/caselaw/us_572.jsonl#/us/572/0118-01; Unicode character offsets [19861:20047] (end exclusive); SHA-256 925bbd2e7ac80af005ca0208b672687190e36af5f681de2bd2a157b522bc7810.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

It further maintained that Lexmark's misrepresentations had "proximately caused and [we]re likely to cause injury to [Static Control] by diverting sales from [Static Control] to Lexmark," and had "substantially injured [its] business reputation" by "leading consumers and others in the trade to believe that [Static Control] is engaged in illegal conduct."
Source: docroot/ir/caselaw/us_572.jsonl#/us/572/0118-01; Unicode character offsets [4895:5251] (end exclusive); SHA-256 925bbd2e7ac80af005ca0208b672687190e36af5f681de2bd2a157b522bc7810.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

To begin, Static Control's alleged injuries-lost sales and damage to its business reputation-are injuries to precisely the sorts of commercial interests the Act protects.
Source: docroot/ir/caselaw/us_572.jsonl#/us/572/0118-01; Unicode character offsets [30878:31048] (end exclusive); SHA-256 925bbd2e7ac80af005ca0208b672687190e36af5f681de2bd2a157b522bc7810.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations

interpretation

We thus hold that to come within the zone of interests in a suit for false advertising under § 1125(a), a plaintiff must allege an injury to a commercial interest in reputation or sales.

/us/572/0118-01 — Supreme Court of the United States · 2014

We thus hold that to come within the zone of interests in a suit for false advertising under § 1125(a), a plaintiff must allege an injury to a commercial interest in reputation or sales.
Source: docroot/ir/caselaw/us_572.jsonl#/us/572/0118-01; Unicode character offsets [19861:20047] (end exclusive); SHA-256 925bbd2e7ac80af005ca0208b672687190e36af5f681de2bd2a157b522bc7810.

Lexmark’s zone-of-interests inquiry limits the statutory cause of action. A business suing only as a disappointed purchaser is like an ordinary consumer; commercial loss must fit the protected interest.

not-required

Direct competition between plaintiff and defendant.

No source quotation recorded.