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Car-Freshner Corp. v. S.C. Johnson & Son, Inc.
United States District Court for the Second Circuit
70 F.3d 267 (1995)
Car-Freshner Corp. (Car-Freshner) (plaintiff) sold pine tree-shaped air fresheners for cars and established trademark rights in the shape of the product and in the name Little Tree used on the products. S. C. Johnson & Son, Inc. (Johnson) (defendant) sold air fresheners under the trademark name Glade. Because Johnson sold a pine-tree-shaped air freshener during the Christmas holiday season, Car-Freshner sued Johnson for trademark infringement. Although the district court rejected Johnson’s fair-use defense, the district court ultimately granted summary judgment to Johnson because the tree-shaped products were sufficiently dissimilar.
Rule of Law
Holding and Reasoning (Leval, J.)
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