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Hormel Foods Corp. v. Jim Henson Productions, Inc.

73 F.3d 497 (1993)

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Hormel Foods Corp. v. Jim Henson Productions, Inc.

United States District Court of Appeals for the Second Circuit

73 F.3d 497 (1993)

Facts

In 1996 the movie Muppet Treasure Island was released, featuring well-known Muppet characters such as Kermit the Frog and Miss Piggy. Jim Henson Productions, Inc. (defendant) added a new Muppet character, Spa’am, who was clearly meant to parody the well-known pork lunch meat known as SPAM made by Hormel Foods Corp. (plaintiff). Spa’am’s character was a wild boar and a high priest who worshipped Miss Piggy. Hormel Foods worried that the character could cause its customers to question the quality of SPAM and was concerned that customers would confuse the source of Spa’am on Muppet merchandise such as clothing with the source of SPAM. Hormel Foods sued for copyright infringement. A federal district court ruled in favor of Jim Henson Productions and found that neither the name nor likeness of Spa’am would create confusion with SPAM. Hormel Foods appealed.

Rule of Law

Issue

Holding and Reasoning (Van Graafeiland, J.)

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