PRL USA Holdings, Inc. v. United States Polo Association, Inc.
United States Court of Appeals for the Second Circuit
520 F.3d 109 (2d Cir. 2008)
PRL USA Holdings, Inc. (Ralph Lauren) (plaintiff) held a trademark for its clothing logo, which consisted of a polo player with a raised mallet. The United States Polo Association (USPA) (defendant), a different clothing company, used four similar logos on its clothing. Ralph Lauren brought suit against USPA for trademark infringement in the United States District Court for the Southern District of New York. USPA claimed that Ralph Lauren was estopped from asserting trademark infringement because Ralph Lauren had acquiesced to USPA’s use of its logos. USPA introduced the testimony of Merle Jenkins, a USPA employee, to establish that Ralph Lauren had consented during settlement negotiations to USPA using a certain version of the logo, and that this version was not offensive to Ralph Lauren. USPA claimed that, after being told this particular logo was not offensive to Ralph Lauren, USPA had spent significant money to roll out the logo on its clothing. Ralph Lauren objected to this testimony on the ground that it was part of a settlement negotiation and thus prohibited under Federal Rule of Evidence (FRE) 408. The district court overruled Ralph Lauren’s objection and found that three of USPA’s four logos did not infringe upon Ralph Lauren’s trademark. Ralph Lauren appealed.
Rule of Law
Holding and Reasoning (Leval, J.)
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