Convenient Food Mart, Inc. v. 6-Twelve Convenient Mart, Inc.

690 F. Supp. 1457, 1988 WL 65700
CourtDistrict Court, D. Maryland
DecidedJuly 21, 1988
DocketCiv. Y-87-1020
StatusPublished
Cited by13 cases

This text of 690 F. Supp. 1457 (Convenient Food Mart, Inc. v. 6-Twelve Convenient Mart, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Convenient Food Mart, Inc. v. 6-Twelve Convenient Mart, Inc., 690 F. Supp. 1457, 1988 WL 65700 (D. Md. 1988).

Opinion

MEMORANDUM

JOSEPH H. YOUNG, Senior District Judge.

This suit raises an easily stated issue: is the term “convenient,” as used in the trade names of plaintiff and defendant food store chains, protected by the trademark laws for exclusive use by plaintiff, or is the term simply a common description of the particular type of retail service provided by plaintiff, defendants, and others? The Court finds that the term “convenient” as used in plaintiff’s trade name is generic and that plaintiff’s registered marks should be can-celled or modified.

BACKGROUND

Plaintiff Convenient Food Mart (“CFM”) filed this action on May 26, 1987, against 6-Twelve Convenient Mart and co-defendant brothers Aris and Armen Mardirossian, respectively president and vice-president of 6-Twelve (collectively “6-Twelve”), for *1459 trademark infringement and unfair competition. CFM asserted registration of its trade name and logotype since 1967 and 1982, respectively, as service marks on the Principal Register of the U.S. Patent and Trademark Office. Plaintiff also asserted similar registration of five trade marks for foodstuffs distributed through its stores, one of which first appeared on the Principal Register in 1975. 1 Plaintiff claimed that it has the incontestible and exclusive right to use “convenient” in its trade name and seeks injunctive relief and treble damages. 2 6-Twelve answered, raising the defense of fair use 3 and counterclaiming under federal and state law for cancellation of CFM’s registered marks.

“Incontestibility” of trade and service marks under the Lanham Act, 15 U.S.C. § 1051 et seq., is a status of conclusively presumptive validity which registered marks achieve under certain conditions, primarily the continuous use of the mark in commerce for five years. Section 1065 defines the prerequisites for “incontestibility” status. The conclusive presumption of validity, and exceptions thereto, are defined in § 1115(b). Defendants’ counterclaim for cancellation of plaintiff’s marks rests not on the defenses enumerated in § 1115(b) but rather contests the marks’ “incontestible” status at their incipiency: § 1065(4) provides that “no incontestible right shall be acquired in a mark which is the common descriptive name of any article or substance, patented or otherwise.” Similarly, a petition to cancel a registration may be filed under § 1064(c) if the term becomes commonly descriptive after registration or even after the recognition of “incontestibility” status. Thus, plaintiff’s claim that its marks are “incontestible” under § 1065 depends on whether they have become “commonly descriptive,” i.e., “generic.” See generally Park ’N Fly, Inc. v. Dollar Park and Fly, Inc., 469 U.S. 189, 105 S.Ct. 658, 83 L.Ed.2d 582 (1985); Dan Robbins & Associates, Inc. v. Questor Corp., 599 F.2d 1009, 1014 (C.C.P.A.1979); 1 Gilson, Trademark Protection and Practice §§ 2.02, 4.03[3] (1985); 1 McCarthy, Trademarks and Unfair Competition § 12.18(D) (2nd ed. 1984); 3 Callman, Unfair Competition, Trademarks and Monopolies § 18.25 (July, 1987).

Trademarks are classified “into four groups in an ascending order of strength or distinctiveness: 1. generic; 2. descriptive; 3. suggestive; and 4. arbitrary or fanciful.” Pizzeria Uno Corp. v. Temple, 747 F.2d 1522, 1527 (4th Cir.1984) (citing Abercrombie & Fitch Co. v. Hunting World, Inc., 537 F.2d 4, 9 (2nd Cir.1976)). *1460 See also Soweco, Inc. v. Shell Oil Co., 617 F.2d 1178 (5th Cir.1980), cert. denied, 450 U.S. 981, 101 S.Ct. 1516, 67 L.Ed.2d 816 (1981). The Supreme Court’s opinion in Park ’N Fly, supra, provides an overview of trademark protection analysis:

The provisions of the Lanham Act concerning registration and incontestibility distinguish a mark that is “the common descriptive name of an article or substance” from a mark that is “merely descriptive.” §§ 2(e), 14(c), 15 U.S.C. §§ 1052(e), 1064(c). Marks that constitute a common descriptive name are referred to as generic. A generic term is one that refers to the genus of which the particular product is a species. Abercrombie & Fitch Co. v. Hunting World, Inc., 537 F.2d 4, 9 (CA2 1976). Generic terms are not registrable, and a registered mark may be cancelled at any time on the grounds that it has become generic. See §§ 2, 14(c), 15 U.S.C. §§ 1052, 1064(c). A “merely descriptive” mark, in contrast, describes the qualities or characteristics of a good or service, and this type of mark may be registered only if the registrant shows that it has acquired secondary meaning, i.e., it “has become distinctive of the applicant’s goods in commerce.” §§ 2(e), (f), 15 U.S. C. §§ 1052(e), (f).

469 U.S. at 193-94, 105 S.Ct. at 661. Plaintiff asserts that its marks are not generic but -rather are descriptive and have acquired secondary meaning with the public, and that its two oldest marks have become incontestible by operation of law. Defendants argue that CFM’s registered marks are generic and therefore must be can-celled. Alternatively, defendants argue that 6-Twelve’s trade name use of “convenient mart” is a fair use of plaintiff’s merely descriptive mark.

Registration of a mark is “prima facie evidence of the registrant's exclusive right to use the mark in its business.” 15 U.S.C. § 1115(a). See McCarthy § 19:5. Because defendants’ counterclaim attacks the incontestibility status of plaintiff’s two oldest marks, plaintiff is accorded this prima facie presumption and not the conclusive presumption. See Park ’N Fly, supra, 469 U.S. at 199 n. 6, 105 S.Ct. at 664 n. 6. Defendants bear the burden of overcoming the presumption with a showing by a preponderance of the evidence that plaintiff’s marks are generic. Pizzeria Uno, supra, 747 F.2d at 1529 n. 4.

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690 F. Supp. 1457, 1988 WL 65700, Counsel Stack Legal Research, https://law.counselstack.com/opinion/convenient-food-mart-inc-v-6-twelve-convenient-mart-inc-mdd-1988.