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Steele v. Bulova Watch Co.
United States Supreme Court
344 U.S. 280 (1952)
Bulova Watch Co. (plaintiff) was an American company that manufactured and sold watches under the registered trademark “Bulova.” Steele (defendant) was a United States citizen who conducted a watch business in Mexico that produced and sold watches in that country marked with the “Bulova” name, with the purpose of deceiving consumers as to the true origin of the watches being sold. Steele purchased some of the watch parts used by his company in the United States, and the fraudulent watches often appeared back across the border in the United States. Steele had initially registered the mark in Mexico, but the Mexican Supreme Court upheld an administrative ruling that had nullified that registration. Bulova sued Steele in United States federal court for trademark infringement and requested injunctive and monetary relief. The district court judge held that the court lacked jurisdiction over the matter. The appeals court reversed the lower court’s ruling, finding that there was a cause of action under the Lanham Act. The Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Clark, J.)
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