Ashley Furniture Industries v. SanGiacomo N.A.

187 F.3d 363 (1999)

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Ashley Furniture Industries v. SanGiacomo N.A.

United States Court of Appeals for the Fourth Circuit
187 F.3d 363 (1999)

Facts

Ashley Furniture Industries, Inc. (Ashley) (plaintiff) and SanGiacomo N.A. Ltd. (defendant) were competitors in the business of manufacturing and marketing mid-priced furniture. In March 1996, Ashley began selling a neoclassical-style bedroom suite under the trade name Sommerset. The Sommerset suite consisted of a headboard, two nightstands, an armoire, and a dresser with a mirror, all with a modern, high-gloss polyester appearance and classical details, including a faux marble finish, fluted columns, arches, and entablatures. The Sommerset suite retailed for approximately $2,500 and was considered by those in the industry to be unique and distinct from other bedroom sets on the market. Less than a year after Ashley introduced the Sommerset line, SanGiacomo started selling a bedroom suite under the trade name La Dolce Vita. That suite also consisted of a headboard, two nightstands, an armoire, and a dresser with a mirror but retailed for approximately $1,800. Like the Sommerset, the La Dolce Vita suite also featured a high-gloss, marble-like finish, fluted columns, arches, and entablatures. Ashley sued SanGiacomo, alleging that the La Dolce Vita design infringed Ashley’s rights in the Sommerset design. The parties filed cross-motions for summary judgment. The district court concluded that Ashley had not offered sufficient evidence to support a finding that the Sommerset design was inherently distinctive and granted SanGiacomo’s motion. Ashley appealed.

Rule of Law

Issue

Holding and Reasoning (Motz, J.)

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