genR8TNext v. LV Institute, et al.

2005 DNH 077
CourtDistrict Court, D. New Hampshire
DecidedMay 5, 2005
Docket05-CV-129-SM
StatusPublished

This text of 2005 DNH 077 (genR8TNext v. LV Institute, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
genR8TNext v. LV Institute, et al., 2005 DNH 077 (D.N.H. 2005).

Opinion

genR8TNext v. LV Institute, et al. 05-CV-129-SM 05/05/05 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

genRSTNext, LLC, Plaintiff

v. Crvrl No. 05-CV-129-SM Opinion No. 2005 DNH 077 Las Vegas Institute for Advanced Dental Studies, Inc., International Academy of Comprehensive Aesthetics, LLC, and William Dickerson, Defendants

O R D E R

Plaintiff genRSTNext, LLC brings suit against defendant Las

Vegas Institute for Advanced Dental Studies, Inc., International

Academy of Comprehensive Aesthetics, LLC, and William Dickerson,

seeking redress for false designation of origin under 15 U.S.C. §

1125(a) and violations of the New Hampshire Consumer Protection

Act, N.H. R e v . S tat . A n n . § 358-A, claiming that defendant's name

"International Academy of Comprehensive Aesthetics" is

confusingly similar to plaintiff's "Academy of Comprehensive

Esthetics." Plaintiff moves this court to issue an ex parte temporary

restraining order ("TRO") pursuant to F e d . R. C i v . P. 65(b),

enjoining defendant from using its "International Academy of

Comprehensive Aesthetics" name in marketing its services. For

the reasons set forth below, plaintiff's motion is denied.

STANDARD OF REVIEW

"Traditionally, the test for a [temporary restraining order]

has four factors: 1) a likelihood of success on the merits, 2)

irreparable harm to the plaintiff should preliminary relief not

be granted, 3) whether the harm to the defendant from granting

preliminary relief exceeds the harm to the plaintiff from denying

it, and 4) the effect of the preliminary injunction on the public

interest." Rio Grande Cmty. Health Ctr., Inc. v. Rullan, 397

F.3d 56, 75 (citing Matrix Group, Ltd. v. Rawlings Sporting Goods

C o ., 378 F.3d 29, 33 (1st Cir. 2004) .

BACKGROUND

The facts, taken from the pleadings and accepted, for these

purposes, as true, are as follows. In or around April 2003,

plaintiff established the Academy of Comprehensive Esthetics,

2 which is, essentially, a professional organization that provides

education and credentialing services to dental professionals

practicing in the specific area of cosmetic (or aesthetic or

esthetic) dentistry. In or about February 2005, Defendant

Dickerson, who had been scheduled to deliver a keynote address at

one of plaintiff's events, launched an organization called the

International Academy of Comprehensive Aesthetics. Like

plaintiff's organization, defendant offers professional education

services and seminars, and markets those services through the

same or substantially similar channels as the plaintiff.

Although neither name is a federally registered trademark,

plaintiff filed an application for registration with the United

States Patent & Trademark Office on April 18, 2005.

Because attempts at amicably resolving the issue ultimately

failed, plaintiff brought this suit alleging false designation of

origin under 15 U.S.C. § 1125(a) and violations of the New

Hampshire Consumer Protection Act under N.H. R.S.A. 358-A.

3 DISCUSSION

Plaintiff moves for a temporary restraining order arguing

that it will suffer irreparable harm if defendants are permitted

to go forward with a planned advertising campaign. But while

plaintiff has noted the potential for irreparable harm should a

temporary restraining order fail to issue, it has failed to

demonstrate that it is likely to succeed on the merits.

As plaintiff notes in its complaint and its Motion for a

Temporary Restraining Order and a Preliminary Injunction, the

threshold inguiry in a trademark infringement case is whether the

alleged mark is, in fact, a protectible trademark. See, e.g.,

Boston Beer Co. v. Slesar Bros. Brewing Co., 9 F.3d 175, 180 (1st

Cir 1993).

"A court's inguiry into whether a term merits trademark

protection starts with the classification of that term along the

'spectrum of distinctiveness.'" Id. At one end of the spectrum

lie generic terms, that is, "terms that have passed into common

usage to identify a product." Id. Such terms are unprotectible

as trademarks. Id. (citing Two Pesos v. Taco Cabana, 505 U.S.

4 763 (1992); Miller Brewing Co. v. Falstaff Brewing Co., 655 F.2d

5 (1st Cir. 1981)). At the other end of the spectrum lie

suggestive, arbitrary, and fanciful marks, which are considered

"inherently descriptive" and thus entitled to trademark

protection. "A term is suggestive if it reguires imagination,

thought and perception to reach a conclusion as to the nature of

the goods. Eguine Techs., Inc. v. Eguitechnology, Inc. 68 F.3d

542, 544 (1st Cir. 1995) (citations omitted). "In the middle [of

the spectrum] there are so-called descriptive terms . . . which

can be protected, but only if [they] have acguired 'secondary

meaning' by which consumers associate it with a particular

producer or source."

_____ "Secondary meaning 'refers to a word's or sign's, ability to

tell the public that the word or sign serves a special trademark

function, namely, that it denotes a product or service.'" Id.

(guoting DeCosta v. Viacom Int'l, Inc., 981 F.2d 602, 606 (1st

Cir. 1992)). "Insofar as the public takes the word, or sign, to

refer to a product or service with a particular source . . . the

word, or sign, has 'secondary meaning.'" DeCosta, 981 F.2d at

606.

5 "In examining whether a plaintiff's advertising is enough to

establish secondary meaning, we look at the advertising's

'amount, nature and geographical scope' with an eye towards how

likely the advertising is to expose a large number of the

relevant consuming public to the use of the symbol as a trademark

or trade name." Japan Telecom, Inc. v. Japan Telecom Am., Inc.,

287 F.3d 866, 875 (9th Cir. 2002) (guoting Am. Scientific Chem.,

Inc. v. Am. Hosp. Supply Corp., 690 F.2d 791, 793 (1982)). Put

differently, [t]o take a descriptive term out of the public

domain, a plaintiff must demonstrate that the relevant buying

public accords it secondary meaning." Id.

Here, plaintiff first asserts that its mark is suggestive,

however it offers little evidence to suggest that a relevant

buyer must use "imagination, thought and perception" Eguine

Techs., 68 F.3d at 544, to determine the nature of the services

offered by the plaintiff. To the contrary, it appears that the

words "esthetic" and "aesthetic" (actually variants of the same

word) when used in the field of dentistry, are widely known as

referring to cosmetic dentistry.1 Absent any reguired

1 A casual internet search for "esthetic," for example, yields as the first result, the American Academy of Esthetic

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