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Guthrie Healthcare System v. ContextMedia, Inc.

United States Court of Appeals for the Second Circuit
826 F.3d 27 (2016)


Guthrie Healthcare System (Guthrie) (plaintiff) was a nonprofit healthcare corporation that operated numerous healthcare facilities in southwestern New York and northwestern Pennsylvania. Guthrie recruited medical professionals nationally and conducted research and fundraising beyond this geographic area. Guthrie used its registered trademark, which consisted of a logo of a stylized human figure on a shield shape next to the Guthrie name, prominently for all of its corporate communications, facilities, and internet presence. ContextMedia, Inc. (defendant) was a media provider that placed televisions displaying health-related content in physicians’ offices. ContextMedia used and registered as a trademark a logo that was nearly identical to Guthrie’s logo. Guthrie sued ContextMedia for trademark infringement. The district court held that there was a likelihood of confusion between the trademarks within Guthrie’s geographic service area, but no such likelihood outside that region. The court enjoined ContextMedia from using its trademark within that region but permitted its use in online content. Guthrie appealed the limited scope of the injunction, and ContextMedia appealed the finding of infringement.

Rule of Law


Holding and Reasoning (Leval, J.)

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