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Presentation/PPT
27/08/2022
In the case of Lexmark International, Inc., sells the only style of toner cartridges that work with the company’s laser printers. Other businesses – remanufacturers – acquire and refurbish used Lexmark cartridges to sell in competition with the cartridges sold by Lexmark. Static Control Components, Inc., makes and sells components for the remanufactured cartridges, including microchips that mimic the chips in Lexmark’s cartridges. Lexmark released ads that claimed Static Control’s microchips illegally infringed Lexmark’s patents. Lexmark then filed a suit in a federal district court against Static Control, alleging violations of intellectual property law. Static Control counterclaimed, alleging that Lexmark engaged in false advertising in violation of the Lanham Act. The court dismissed the counterclaim. On Static Control’s appeal, the U.S. Court of Appeals for the Sixth Circuit reversed the dismissal. Lexmark appealed.
The United States Supreme Court affirmed the lower court’s ruling. The Supreme Court’s decision clarified that businesses do not need to be direct competitors to bring an action for false advertising under the act. A cause of action for false advertising under the Lanham Act extends to plaintiffs whose interests “fall within the zone of interests protected by the law.” To establish a claim, a plaintiff must allege an injury to a commercial interest in reputation or sales proximately caused by a violation of the statute. Static Control met this test.
Under the Court’s ruling in this case, is Static Control now entitled to relief? Explain your answer.
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