In Meenaxi Enterprise, Inc. v. Coca-Cola Company, the U.S. Court of Appeals for the Federal Circuit reversed a decision of the Trademark Trial and Appeal Board (TTAB), which had previously canceled Coca-Cola’s U.S. trademark registrations for two Indian soft drink brands. The case focused on whether Coca-Cola misused the U.S. trademark system to interfere with a domestic competitor selling products under foreign brand names.
Background of the Trademark Challenge
Meenaxi Enterprise sold Indian-style soft drinks in the U.S. using the brands THUMS UP and LIMCA, both well-known in India. Coca-Cola, which acquired rights to those marks abroad, applied for and registered the marks in the United States despite not selling either product domestically. Meenaxi challenged the registrations, claiming that Coca-Cola engaged in conduct that misled U.S. consumers and blocked Meenaxi from selling its products.
The TTAB sided with Meenaxi and canceled Coca-Cola’s registrations, citing Section 14(3) of the Lanham Act. It concluded that Coca-Cola had no intent to use the marks in U.S. commerce and acted to harm a competitor, constituting misrepresentation of the source of goods.
Federal Circuit Overturns Cancellation
On appeal, the Federal Circuit reversed the TTAB's ruling. The court held that Meenaxi failed to establish that Coca-Cola’s use or registration of the marks misled a significant portion of U.S. consumers. The court emphasized that Section 14(3) requires a showing that the registrant misrepresented the source of goods in a way that affects consumers in the United States.
The court noted that THUMS UP and LIMCA were primarily recognized by consumers familiar with Indian markets, not by the broader U.S. public. It found that Meenaxi did not provide adequate evidence of consumer confusion or deception. Without proof of misleading conduct affecting the U.S. market, the court concluded that cancellation was improper.
Standing and Lanham Act Requirements
The court acknowledged Meenaxi’s interest as a competitor but stressed that harm to a business interest does not, by itself, meet the legal threshold for cancellation under the Lanham Act. The ruling clarified that Section 14(3) is focused on public impact rather than competitive disadvantage. Because Coca-Cola’s trademark registrations were not shown to mislead the public, the statutory requirements for cancellation were not met.
Trademark Dispute Evaluation
If your business is dealing with questions around foreign trademarks, misrepresentation, or the scope of Lanham Act protections, our team at Whitcomb, Selinsky, PC can review your situation and help determine how U.S. trademark law applies to your brand and market strategy.
Joe Whitcomb
