Coach, Inc. v. Goodfellow

Coach, Inc. (plaintiff) designed, marketed, and sold handbags, briefcases, leather goods, eyewear, and footwear using its large assortment of trademarks. Coach sent a letter to Goodfellow (defendant), the owner and operator of a flea market, to warn Goodfellow that flea-market vendors were selling counterfeit Coach products that infringed the trademarks. Goodfellow knew that the flea-market vendors continued to sell counterfeit Coach products but did not inspect the vendors’ goods nor ask if the goods were counterfeit. The county district attorney general’s office sent a letter notifying Goodfellow that the flea-market vendors were continuing to sell counterfeit Coach products and that Goodfellow was in willful disregard of the law. Goodfellow did not prevent the flea-market vendors from continuing to sell counterfeit Coach products. Law-enforcement officers raided the flea market and seized the counterfeit Coach products stored in the rental booths and storage units provided by Goodfellow. Coach filed an action against Goodfellow and the vendors under the Lanham Act to demand an end to the sale of counterfeit Coach products at the flea market. Law-enforcement officers conducted two more raids over the following year, seized more than 4,600 counterfeit Coach products, and permanently closed the flea market. Coach filed a motion for summary judgment on liability, and Goodfellow failed to respond. The district court granted summary judgment to Coach on Goodfellow’s contributory liability for trademark infringement. Goodfellow appealed and argued that the Lanham Act did not provide for contributory liability based on indirect trademark infringement.