Bodum USA, Inc. v. A Top New Casting Inc.

In 1983, Bodum USA, Inc. (Bodum) (plaintiff), a seller of French-press coffeemakers, started to sell a distinctively designed French press called the Chambord. In 2014, A Top New Casting Inc. (A Top) (defendant) began distributing a French press with handle, lid, and metal-frame designs similar to the Chambord. Bodum filed suit under the Lanham Act against A Top for infringement of the Chambord’s unregistered trade dress. Bodum claimed Lanham Act protection for the overall appearance of the Chambord, including its lid, handle, and metal frame. Thus, at trial, Bodum’s expert opined on the handle, lid, and metal-frame designs as serving decorative rather than practical purposes. Bodum proffered evidence of advertising focusing on the aesthetic over the utilitarian aspects of the Chambord’s design. The court considered evidence of alternative, less complicated designs. In response, A Top argued that Bodum had failed to establish that these specific elements of the claimed trade dress were nonfunctional, as would be required for the trade dress to be protected under the Lanham Act. Additionally, the court excluded utility-patent evidence that A Top sought to introduce on grounds of a lack of reference to the design features. The jury ruled in Bodum’s favor. A Top appealed the conclusion regarding the non-functionality of the Chambord trade dress and the court’s exclusion of utility patents from evidence.