Specialized Seating, Inc. v. Greenwich Industries, L.P.

Greenwich Industries, L.P. (defendant) had been making x-frame folding chairs for well over half a decade and held a federal trademark registration for a particular design of its x-frame chair, called the b-back design. After Greenwich’s general manager departed to join its competitor, Specialized Seating, Inc. (plaintiff), Specialized began selling an x-frame folding chair similar in design to that of Greenwich. A dispute arose, and Specialized sought a declaratory judgment that its design did not violate Greenwich’s rights under the Lanham Act. Greenwich, meanwhile, counterclaimed for an injunction. The district court ruled in Specialized’s favor after concluding that the x-frame folding-chair construction was functional and therefore unprotectable under the Lanham Act because it was designed to be an optimal balance between the chair’s weight (and thus its cost) and its strength. The district court found that the x-frame chair folded itself when knocked over, which was an important consideration for large auditoriums; that the chair’s edge was designed for attaching hooks to link the chairs together; that the front and back cross bars contributed strength; and that the b-back design allowed the chair to support greater vertical loads than Greenwich’s older a-back design. To this end, the district court pointed to the expired utility patents Greenwich held on its a-back design as evidence that the trademark b-back design was functional because it was an improvement over the older design. Greenwich appealed.