Coach Leatherware Co. v. AnnTaylor, Inc.

Coach Leatherware Co. (Coach) (plaintiff) was the producer of high-quality leather handbags sold exclusively under its own label. Coach did not have registered trademarks for its handbag designs. On each handbag, Coach attached a distinctive leather tag embossed with “Coach Leatherware” and suspended by a beaded brass chain. Coach had a registered trademark for its tag design, which had become valuable as an upscale symbol. Coach learned that AnnTaylor, Inc. (AnnTaylor) (defendant), a chain of retail stores for professionals, was replicating and selling three of Coach’s classic handbag designs. The imitation handbags had leather tags attached by beaded brass chains; the tags were embossed with AnnTaylor’s name in a different typeface from the Coach tags. Coach brought suit against AnnTaylor in the district court and claimed trade-dress infringement in violation of the Lanham Trade-Mark Act. Coach moved for a preliminary injunction to prevent AnnTaylor from replicating Coach’s handbag designs. AnnTaylor moved for summary judgment and argued that the Coach handbag features had not acquired the secondary meaning required to support a claim for trade-dress infringement. The district court, on its own initiative, granted summary judgment in favor of Coach on the trade-dress-infringement claim. The district court determined that AnnTaylor’s handbags were similar to the Coach handbag designs and likely to cause consumer confusion. The district court found AnnTaylor liable for trade-dress infringement and permanently enjoined AnnTaylor from copying any of the Coach handbag designs.