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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)
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
Holding and Reasoning (Van Graafeiland, J.)
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