Yankee Candle Company, Inc. v. Bridgewater Candle Company, LLC

Yankee Candle Company (Yankee) (plaintiff) manufactured a line of scented candles that it named Housewarmer. Yankee displayed these candles in stores using what Yankee called the Vertical Design System, its method of shelving and displaying candles. Yankee also displayed its Housewarmer candles with labels and published a product catalog featuring Housewarmer candles. Yankee sued Bridgewater Candle Company (Bridgewater) (defendant) for trade-dress infringement, along with copyright-infringement and business-tort causes of action. Yankee’s claimed trade dress comprised a combination of several elements, namely, its Housewarmer series of labels, its choice of candle sizes and styles, its Vertical Design System, and its catalog layout. Yankee also asserted trade-dress rights as to the Housewarmer labels by themselves. Bridgewater moved for summary judgment on all claims, including Yankee’s trade dress claim. Yankee attempted to establish secondary meaning for its combination trade-dress claim by introducing evidence of commercial success and advertising strategy associated with Yankee’s trade dress. In ruling on Bridgewater’s motion, the district court found that: (1) the Vertical Design System was not protectable because it was conventional and functional; (2) both Yankee’s combination trade dress and the Housewarmer labels by themselves, were a “product design/configuration” and were thus legally incapable of possessing inherent distinctiveness; and (3) Yankee did not adduce sufficient proof of secondary meaning to sustain either of its trade-dress claims. As a result, the district court granted Bridgewater’s motion on Yankee’s trade-dress claim. Yankee appealed.