In the Trademark Counterfeiting Act of 1984 (the Act), Congress made it a crime to knowingly use a counterfeit mark in connection with the sale of goods or services. Baker (defendant) was charged under the Act with dealing in counterfeit “Rolex” watches. At his trial in federal district court, Baker admitted that he knew the watches he sold were counterfeit but argued that he did not know dealing in counterfeit watches was a crime. The district court refused to instruct the jury that Baker could not be convicted if he did not intend to violate the law. Baker was convicted and appealed to the United States Court of Appeals for the Fifth Circuit.