Mastercrafters Clock & Radio Co. v. Vacheron & Constantin-Le Coultre Watches, Inc.
United States Court of Appeals for the Second Circuit
221 F.2d 464 (1955)
Vacheron & Constantin-Le Coultre Watches, Inc. (defendant) imported a Swiss-made cordless luxury clock called the Atmos. The Atmos’s design was well-known, unique, and had a prestigious reputation. The clock retailed for $175. Mastercrafters Clock & Radio Company (plaintiff) manufactured a “Model 308” clock. The Model 308 looked similar to the Atmos, although it used an electrical cord and had Mastercrafters’s name on it. The Model 308 retailed for $30-$40. Mastercrafters filed suit seeking a declaratory injunction that its clock did not unfairly compete with Vacheron. Vacheron filed a counterclaim seeking to enjoin Mastercrafters from selling the Model 308. Vacheron argued that the Model 308 harmed the reputation of the Atmos and, as a result, its sales. Vacheron presented as evidence customer statements about the clocks, including a statement that a customer “could get a clock for $30 or $40 just like the Atmos,” and references to “the lower-priced Atmos.” The district court ruled in favor of Mastercrafters. The court did not find unfair competition in part due to Mastercrafters’s name appearing on the Model 308. Vacheron appealed.
Rule of Law
Holding and Reasoning (Frank, J.)
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