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Mead Data Central, Inc. v. Toyota Motor Sales, U.S.A., Inc.

875 F.2d 1026 (2d Cir. 1989)

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Mead Data Central, Inc. v. Toyota Motor Sales, U.S.A., Inc.

United States Court of Appeals for the Second Circuit

875 F.2d 1026 (2d Cir. 1989)

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Facts

Mead Data Central, Inc. (Mead) (plaintiff) operated a computer-based, legal-research service under the trademark Lexis. In 1987, Toyota Motor Corporation (Toyota) (defendant) announced that Toyota would manufacture and market a new line of luxury automobiles under the Lexus label. Prior to adopting Lexus as a trademark for its new vehicles, Toyota was counseled that no conflict existed between Toyota’s use of Lexus as a mark for vehicles and Mead’s existing use of Lexis as a mark for legal-research services. After Toyota ignored Mead’s cease-and-desist letters, Mead brought a trademark-infringement suit against Toyota, claiming that Toyota’s use of the Lexus mark would dilute the value of Mead’s Lexis mark as a source identifier. At trial, the district court accepted evidence that 76 percent of surveyed attorneys identified the term Lexis as a legal-research service provided by Mead and that only 1 percent of the general public made the same connection. Nevertheless, the district court held in favor of Mead, finding that there would be a likelihood of trademark dilution if Toyota was allowed to use Lexus in connection with its vehicles. Toyota appealed the decision.

Rule of Law

Issue

Holding and Reasoning (Van Graafeiland, J.)

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