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Mead Data Central, Inc. v. Toyota Motor Sales, U.S.A., Inc. And Toyota Motor Corp.

Court of Appeals for the Second Circuit (1989) | 875 F.2d 1026; 10 U.S.P.Q. 2d (BNA) 1961; 1989 U.S. App. LEXIS 6644

4 min read

TL;DR: The owner of the "LEXIS" trademark for a legal research service sued Toyota over its new "LEXUS" luxury car brand. The Second Circuit reversed an injunction, finding no trademark dilution because the marks were not substantially similar and LEXIS lacked distinctiveness outside its niche market.

Legal Significance: This case established a high bar for trademark dilution claims under New York law, requiring substantial similarity between marks and that the senior mark possess a distinctive quality for the junior user's market, not just its own niche market. It also introduced the concepts of blurring and tarnishment.

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