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Bretford Manufacturing, Inc. v. Smith System Manufacturing Corp.

419 F.3d 576 (2005)

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Bretford Manufacturing, Inc. v. Smith System Manufacturing Corp.

United States Court of Appeals for the Seventh Circuit

419 F.3d 576 (2005)

Facts

Bretford Manufacturing, Inc. (plaintiff) manufactured computer tables that had one leg on each side. Each leg was attached to the tabletop with a V-shaped brace. From 1990 to 1997, Bretford was the only manufacturer of this type of table. Smith System Manufacturing Corporation (defendant) was a competitor of Bretford and decided to incorporate a similar brace into its tables. Smith met with the Dallas school system to discuss a bulk purchase of its tables. However, Dallas asked for a sample of the table, and Smith’s prototype was not ready. As a result, Smith made a sample using a tabletop manufactured by Smith and a leg assembly manufactured by Bretford. Bretford sued Smith for violating the Lanham Act. Bretford asserted that the V-shaped brace constituted Bretford’s trade dress and that Smith was guilty of “reverse passing off.” The district court ruled in favor of Smith. Bretford appealed.

Rule of Law

Issue

Holding and Reasoning (Easterbrook, J.)

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