From our private database of 14,100+ case briefs...
Valu Engineering, Inc. v. Rexnord Corp.
United States Court of Appeals for the Federal Circuit
278 F.3d 1268 (2002)
Valu Engineering, Inc. (Valu) (plaintiff) manufactured guide rails for conveyors that were primarily used in bottling and canning plants. Valu’s guide rails helped products stay on the moving conveyors in plant areas that were frequently washed and sanitized, sometimes referred to as wet areas. Wet areas required parts made of corrosion-resistant materials, like steel or plastic. Valu’s promotional materials described the functional advantages of its guide rails. Valu also applied for a patent for the guide rails that described their usefulness, but Valu abandoned the patent application. Valu later applied for a trademark for three of its guide-rail designs. Valu’s trademark application was approved by the examining attorney. Examining attorneys are individual attorneys who handle the initial examination of trademark applications. Rexnord Corporation (Rexnord) (defendant) then filed an opposition to Valu’s trademark application. Rexnord argued that Valu’s designs for guide rails could not be registered as trademarks because they were functional. The Trademark Trial and Appeal Board (Board) sustained Rexnord’s opposition. The Board found that Valu’s guide-rail designs had utilitarian advantages in the wet areas of bottling plants. This functionality made Valu’s designs ineligible for trademark protection. Specifically, the Board found that the following evidence showed that Valu’s designs were primarily functional: (1) Valu’s prior patent application, (2) Valu’s advertising materials, (3) Valu’s limited range of designs, and (4) the economic benefits to customers of using Valu’s guide rails. Valu appealed, arguing that the Board improperly assessed only the wet-area uses rather than assessing all possible uses of Valu’s guide-rail designs.
Rule of Law
Holding and Reasoning (Dyk, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 221,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,100 briefs, keyed to 189 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.