Younker v. Nationwide Mutual Ins.

175 Ohio St. (N.S.) 1
CourtOhio Supreme Court
DecidedJune 5, 1963
DocketNo. 37522
StatusPublished

This text of 175 Ohio St. (N.S.) 1 (Younker v. Nationwide Mutual Ins.) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Younker v. Nationwide Mutual Ins., 175 Ohio St. (N.S.) 1 (Ohio 1963).

Opinions

Griffith, J.

This case involves a consideration of the law relating to trade names, trademarks and service marks.

A trade name, the broadest of these terms, is descriptive of the identity of the owner of the business. It identifies the source of the product or services, the business itself and need not be affixed to the product, although it may serve to identify not only the business but also the product. Katz Drug Co. v. Katz, 240 Mo. App., 739, 217 S. W. (2d), 286; Gordy v. Dunwody, 209 Ga., 627, 74 S. E. (2d), 886; and Mary Muffet, Inc., v. Smelansky, 158 S. W. (2d), 168.

A trademark is a sign, word or device affixed to a product which identifies the goods of a particular seller or manufacturer and distinguishes them from the goods sold or produced by another. Application of McIlhenny Co., 278 F. (2d), 953.

A service mark, which is comparatively new in the law, is in effect a trademark which relates to a service rather than a product. It is a mark used in the advertising and sale of services of one person or firm to distinguish them from the services of another. Toulman, Trade Mark Handbook, 302. Such service marks may include titles, designations, slogans and char[6]*6acter names. 4 Callman, Unfair Competition and Trade-Marks (2 Ed.), 2129; and Section 1329.54, Revised Code.

Although trade names, trademarks and service marks are used differently, they all serve the same basic purposes, viz., to identify a business and its products or services, to create a consumer demand therefor, and to protect any goodwill which one may create as to his goods or services.

The fundamental purpose of the laws protecting interests in a trade name, trademark and service mark is twofold. First, it is to protect the public. Present day consumer purchasing is based frequently on name buying. Consequently, such name must be protected to assure the purchaser that he gets the goods from the source on which he relies. Second, it is to protect the interest of the owner of the name or mark in the goodwill he has created, by keeping another merchandiser or producer from infringing on the goodwill created as to the name or mark. In part, the legal protection afforded is to prevent one from reaping where one has not sown.

The basic principles governing trademarks and trade names are the same. Neva-Wet Corporation of America, Inc., v. Neva-Wet Processing Corp., 277 N. Y., 163, 13 N. E. (2d), 755. Service marks being primarily trademarks relating to services, the law relating to trademarks is equally applicable to service marks. Yandenburgh, Trademark Law and Procedure, 31.

The rights in trademarks, trade names and service marks are acquired by actual user and not by registration. Such rights belong to the one who first actually adopts and uses the name or mark in connection with his business. Johnson v. Glassley, 118 Ind. App., 704, 83 N. E. (2d), 488; Englander v. Mc-Kesson-Roeber-Kuebler Co., 120 N. J. Eq., 480, 187 A., 917; Dell Publishing Co., Inc., v. Stanley Publications, Inc., 9 N. Y. (2d), 126, 172 N. E. (2d), 656; Foss v. Culbertson, 17 Wash. (2d), 610, 136 P. (2d), 711; Hanover Star Milling Co. v. Metcalf, 240 U. S., 403, 60 L. Ed., 713, 36 S. Ct., 357; Faciane v. Starner, 230 F. (2d), 732; and Radio Shack Corp. v. Radio Shack, Inc., 180 F. (2d), 200. The qualified property rights in such names and marks and the right to protection thereof arise as a matter of common law, not as a matter of statute. The registration statutes merely implement the common-law rights and create [7]*7certain procedural advantages. United States v. Steffens, 100 U. S., 82, 25 L. Ed., 550; Southern Scrap Material Co., Ltd., v. Smith, 253 Ala., 356, 44 So. (2d), 754; Faciane v. Starner, supra; and 4 Callman, Unfair Competition and Trade-Marks (2 Ed.), 2066 and 2087, Sections 97.3 et seq. and 97.4.

It is the actual use of the trade name, trademark or service mark in connection with the business and not the duration of such use which gives rise to legal rights. Axton-Fisher Tobacco Co. v. Fortune Tobacco Co., 82 F. (2d), 295; and Foss v. Culbertson, 136 P. (2d), 711. Thus, one who adopts and uses a name in connection with his business or products acquires the right to the use thereof over one who subsequently registers such name or mark. Womble v. Parker, 208 Ga., 378, 67 S. E. (2d), 133; Tillman & Bendel, Inc., v. California Packing Corp., 63 F. (2d), 498; and 4 Callman, Unfair Competition and Trade-Marks (2 Ed.), 2066 and 2087, Sections 97.3 et seq. and 97.4.

Although theoretically a trade name indentifies a business or source of a commodity, a trademark identifies the commodity, and the service mark is a trademark which identifies services. There are many instances where a trademark serves to identify the business just as much as the trade name and instances where the trade name has become so identified with the product that it is equivalent to a trademark. Thus a trade name also may be a trademark or service mark. Children’s Bootery v. Sutker, 91 Fla., 60, 107 So., 345; A. & H. Transportation, Inc., v. Save Way Stations, Inc., 214 Md., 325, 135 A. (2d), 289; and 4 Callman, Unfair Competition and Trade-Marks (2 Ed.), 2138, Section 98.4 (e). The same may well be true of a corporate name. For example, if a corporate name has actually become identified with a product or a service, equity will enjoin the use by another of such name as a trademark or trade name. American Steel Foundries v. Robertson, Commr., 269 U. S., 372, 70 L. Ed., 317, 46 S. Ct., 160.

The controlling question in cases of this nature is whether one has used a name, word, symbol or other means of identification in connection with his business in such manner that the public associates such name, etc., with a particular business or commodity so that the use by another is likely to create confusion in the mind of the public. Consequently, one having a [8]*8prior use of such name, etc., is entitled to the use of such name, etc., to the exclusion of all others who wish to adopt it. The question here then is whether plaintiff has used the word, “Securance,” in its business so that its use by another might create confusion in the mind of the public. If through use and advertising plaintiff has created an image in the mind of the public which relates the word, ‘ ‘ Securance, ’ ’ to its business, then it has gained a property right in such name.

This brings us to a consideration of the case presently before us. In 1956, some four years before defendant determined to use the word, “Securance,” as an advertising feature or service mark, plaintiff had incorporated under the name, “Securance Service, Inc.” Since the date of incorporation in 1956 the word, “Securance,” has been used in the promotion of plaintiff’s business through different media of advertising. At least to a limited extent plaintiff used the word, ‘ ‘ Securance, ’ ’ alone in its advertising.

The dominant word in the corporate name of plaintiff is “Securance.” Although it is a dictionary word, both parties have attempted to give it a- secondary meaning by relating it to the insurance business.

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Related

United States v. Steffens
100 U.S. 82 (Supreme Court, 1879)
Hanover Star Milling Co. v. Metcalf
240 U.S. 403 (Supreme Court, 1916)
American Steel Foundries v. Robertson
269 U.S. 372 (Supreme Court, 1926)
Gordy v. Dunwody
74 S.E.2d 886 (Supreme Court of Georgia, 1953)
Womble v. Parker
67 S.E.2d 133 (Supreme Court of Georgia, 1951)
Jacobs v. Iodent Chemical Co.
41 F.2d 637 (Third Circuit, 1930)
A. & H. Transportation, Inc. v. Save Way Stations, Inc.
135 A.2d 289 (Court of Appeals of Maryland, 1957)
The Children's Bootery v. Sutker
107 So. 345 (Supreme Court of Florida, 1926)
Johnson v. Glassley
83 N.E.2d 488 (Indiana Court of Appeals, 1949)
Katz Drug Co. v. Katz
217 S.W.2d 286 (Missouri Court of Appeals, 1949)
Neva-Wet Corp. of America, Inc. v. Never Wet Processing Corp.
13 N.E.2d 755 (New York Court of Appeals, 1938)
Foss v. Culbertson
136 P.2d 711 (Washington Supreme Court, 1943)
Southern Scrap Material Co. v. Smith
44 So. 2d 754 (Supreme Court of Alabama, 1950)
Food Fair Stores, Inc. v. Square Deal Market Co.
109 F. Supp. 637 (District of Columbia, 1952)
Federal Glass Co. v. Loshin
126 F. Supp. 737 (D. Connecticut, 1954)
Forzly v. American Distilling Co.
142 F. Supp. 210 (E.D. New York, 1956)

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Bluebook (online)
175 Ohio St. (N.S.) 1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/younker-v-nationwide-mutual-ins-ohio-1963.