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Pro-Football, Inc. v. Harjo

United States Court of Appeals for the District of Columbia
415 F.3d 44 (2005)


Facts

Pro-Football, Inc. (PFI) (defendant) was the corporate owner of the Washington Redskins football team. PFI registered six trademarks that include the word Redskin. One mark was registered in 1967, three were registered in 1974, one more in 1978, and the most recent one was registered in 1990. The last trademark was for the word Redskinnettes. In 1992, seven Native Americans (plaintiffs) petitioned for cancellation of the registrations, alleging that the term Redskin disparaged Native Americans. One of the plaintiffs, Mateo Romero, was born in 1966. The plaintiffs prevailed before the Trademark Trial and Appeal Board, which cancelled the marks. PFI appealed to the trial court. The trial court granted summary judgment to PFI based on the doctrine of laches and a lack of substantial evidence to show disparagement. The trial court ruled that the time period for assessing laches began in 1967 for all seven plaintiffs. The plaintiffs appealed to the United States Court of Appeals for the District of Columbia.

Rule of Law

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Issue

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Holding and Reasoning (Per Curiam)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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