Deere & Company v. MTD Products, Inc.

41 F.3d 39 (1994)

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Deere & Company v. MTD Products, Inc.

United States Court of Appeals for the Second Circuit
41 F.3d 39 (1994)

Facts

Deere & Company (Deere) (plaintiff), a supplier of agricultural equipment, trademarked its logo. The Deere logo depicted a deer and was used on its various products. MTD Products, Inc. (MTD) (defendant) manufactured and sold lawn tractors. MTD’s advertising agency wanted to produce an advertisement comparing the two companies’ tractors. MTD used the Deere logo, but changed the proportions of the deer and removed the name “John Deere” from the logo. In the advertisement, the deer in the logo was also animated so that it would run from an MTD tractor. Deere sued MTD for trademark dilution and filed for a preliminary injunction and temporary restraining order to prevent the airing of the commercial. The district court denied the temporary restraining order but granted the preliminary injunction within the state of New York. MTD appealed the court’s decision on the dilution claim, and Deere appealed the court’s decision that restricted the injunction to New York.

Rule of Law

Issue

Holding and Reasoning (Newman, J.)

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