Magic Foam Sales Corp. v. Mystic Foam Corp.

98 N.E.2d 439, 59 Ohio Law. Abs. 468, 89 U.S.P.Q. (BNA) 190, 44 Ohio Op. 185, 1950 Ohio Misc. LEXIS 321
CourtCuyahoga County Common Pleas Court
DecidedNovember 14, 1950
DocketNo. 595752
StatusPublished
Cited by1 cases

This text of 98 N.E.2d 439 (Magic Foam Sales Corp. v. Mystic Foam Corp.) is published on Counsel Stack Legal Research, covering Cuyahoga County Common Pleas Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Magic Foam Sales Corp. v. Mystic Foam Corp., 98 N.E.2d 439, 59 Ohio Law. Abs. 468, 89 U.S.P.Q. (BNA) 190, 44 Ohio Op. 185, 1950 Ohio Misc. LEXIS 321 (Ohio Super. Ct. 1950).

Opinion

OPINION

By KOVACHY, J:

The Magic Foam Sales Corporation, an Ohio corporation, located at Cincinnati, claims an infringement of its common law trademark “Magic Foam” by the Mystic Foam Corporation, an Ohio corporation of Cleveland.

Magic Foam, Inc., an immediate predecessor of plaintiff, was incorporated November 14, 1932, at which time it took over the upholstery cleaner business of a partnership and acquired at the same time the latter’s trade name “Magic Foam.” The plaintiff was organized on or about January 17, 1935.

The defendant was organized on or about March 8, 1934. Its immediate predecessor was a partnership which commenced using the trade-mark “Mystic Foam” around December 15, 1933, and obtained a United States registered trade-mark for it on October 8, 1935.

There is no question here that the public use of the expresión “Magic Foam” antedates that of “Mystic Foam.”

Plaintiff claims that the term “Mystic Foam” is confusingly similar to that of “Magic Foam” and asks that the defendant be enjoined from using the term “Mystic Foam” in its corporate name, as a trade-mark or on any of its labels or literature and that an accounting for profits and damages be awarded it against the defendant.

In the trial of this cause defendant made motions for judgment at the close of plaintiff’s case, in the midst of the presentation of its own case and at the close of all the evidence. These motions were taken under advisement by the Court. Inasmuch as the Court now has the benefit of the evidence presented by both sides in the cause it desires to make its rulings on the basis of all the evidence before it.

One of the grounds on which defendant bases its motions is that the plaintiff does not come into court with clean hands. [470]*470In its ruling herein the Court gives this claim its main consideration.

Labels (Defendant’s Exhibits 24 and 25) used by the plaintiff on its product carry the following expressions:

1. “Patent Pending.”

2. “Restores the natural oils usually lost with ordinary cleaners.”

3. “Won’t burn or explode.”

4. “Exterminates and acts as a protective agent against moths.”

5. “The sterilization action is fatal to disease and germs lurking in the fabric.”

6. “It does not harm the hands.”

Its advertisements carry the statement — “Magic Foam, the original Foam type cleaner.” (Defendant’s Exhibit 82)

Item No. 1 — Patent Pending — has been printed on the labels since the inception of the “Magic Foam” business in 1932 despite the fact that no patent had ever been applied for. It leads purchasers to believe that “Magic Foam” is made up of a compound which is novel and unique and possesses qualities which are unusual and unpossessed by other products on the market. It, also, deters others from selling a like product for fear of infringing upon the monopoly about to be granted. The use of this term on labels is a clear fraud upon the public and a badge of dishonesty in the conductance of plaintiff’s business.

In 11 House of Lords, page 542 (Leather Cloth Co. v. American Leather Cloth Co.) Lord Kingsdown says the following:

“If a trade mark represents an article as protected by a patent, when in fact it is not so protected, it seems to me that such a statement prima facie amounts to a misrepresentation of an important fact, which would disentitle the owner of the trade mark to relief in a Court of equity against anyone who pirated it.”

The Federal Circuit Court of Illinois, in Preservaline Mfg. Co. v. Haller Chemical Co. 118 Fed. Rep. 103, has the following to say in its syllabus:

“The use by the manufacturer of an article, for several years after a patent therefor had expired, of advertising circulars containing the word ‘patented’, or statements clearly implying that it was protected by a patent, which circulars were inclosed in the packages in which the article was sold, is such a fraud as will preclude relief in equity against unfair competition, although no such statements were made in connection with complainant’s trade-mark, or on the packages [471]*471themselves; it being impossible for the court to determine to what extent the value of complainant’s business, which it is asked to protect, is due to such fraudulent action.”

Item No. 2■ — Restores the natural oils usually lost with ordinary cleaners — . There is conclusive evidence that the formula used by “Magic Foam” contains nothing to restore any natural oil that may have been lost by the fabric.

Item No. 3 — Won’t burn or explode — . A quart can of Magic Foam when opened in the court room and a lighted match held over it produced a flame lasting a few seconds. Any one familiar with chemistry knows that ether burns and has a low boiling point.

Webster’s New International Dictionary has the following to say of Ether:

“A light, volatile, mobile, highly inflamable liquid — boiling point 94.3 degree F.”

The ether in this product would boil on a hot summer day and readily burn if near a fire or a flame. How then can a statement that it “won’t burn” be honestly made in respect of it? Moreover, the undisputed evidence is that “Magic Foam” because of its ether content is a dangerous solution and not acceptable as a fire-proof product.

Item No. 4 — Exterminates and acts as a protective agent against moths — . The evidence is that such statement is untrue and false.

Item No. 5 — The sterilization action is fatal to disease and germs lurking in the fabric. —Such statement likewise is untrue and false.

Item No. 6 — It does not harm the hands. —The testimony is uncontradieted that the ammonia and ether contained in this product “tenderizes” the hands of all women.

The representations delineated above are all untrue and false. They, moreover, state facts which are important and material because they enhance the value of the product to the purchaser. These misrepresentations about “Magic Foam” have been made to the public for 17 years. It is most difficult to determine the business attracted to the plaintiff or the harm inflicted upon the buying public by them. Certain it is that both are quite considerable.

The statement — Magic Foam, the original Foam type cleaner —the Court considers in the category of mere business puffing. As such it does not create the impression that “Magic Foam” is a superior product because of it to the buying public.

Equity restrains a business house from infringing upon the trade-mark of another to prevent the public from being mis[472]*472led. It decries the public being deceived by representations which give the goods a character and reputation which they do not possess or deserve so that the remedy granted is not based alone upon the property acquired by one owning symbols and names as trade marks but also on the broad principle that it will not permit fraud to be practiced upon the public nor upon private individuals.

See Pomeroy’s Equity Jurisprudence, 5th edition. Volume 3 Section 934 f, and Volume 4, Section 1354.

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98 N.E.2d 439, 59 Ohio Law. Abs. 468, 89 U.S.P.Q. (BNA) 190, 44 Ohio Op. 185, 1950 Ohio Misc. LEXIS 321, Counsel Stack Legal Research, https://law.counselstack.com/opinion/magic-foam-sales-corp-v-mystic-foam-corp-ohctcomplcuyaho-1950.