Spartan Food Systems, Inc. v. HFS Corp.

In 1976, Spartan Food Systems, Inc. (Spartan) (plaintiff) started using the mark Quincy’s for restaurant services in interstate commerce. Eventually, Spartan’s use of its Quincy’s service mark extended to several southeastern states. In August 1984, Spartan obtained a federal registration for its Quincy’s service mark. In November 1985, Spartan’s use of its mark extended to certain cites in Virginia, namely Newport News, Hampton, and Martinsville. Since 1979, however, HFS Corporation (HFS) (defendant) had also used Quincy’s for restaurant services, in certain northern Virginia areas, namely Arlington and McLean. In 1982, HFS obtained a state registration for its Quincy’s mark. Spartan brought a declaratory judgment action against HFS in the United States District Court for the Eastern District of Virginia, asking the court to declare that, as a federal registrant, Spartan had superior rights to the Quincy’s mark over HFS for the entire state of Virginia, except for Arlington and McLean. HFS counterclaimed for service-mark infringement under Virginia statutory law and common law. HFS contended that under Virginia law, it had superior rights to use Quincy’s throughout the entire state of Virginia. The district court dismissed Spartan’s complaint and enjoined Spartan from using its Quincy’s mark anywhere in Virginia. Spartan appealed.