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Zazu Designs v. L'Oreal, S.A.

United States Court of Appeals for the Seventh Circuit
979 F.2d 499 (7th Cir. 1992)


Zazu Hair Designs (ZHD) (plaintiff) was a hair salon outside of Chicago. In 1980, ZHD obtained a state service mark registration for “ZAZU.” L’Oreal, S.A. (L’Oreal) (defendant) manufactured a hair coloring product and wanted to call it ZAZU. Prior to marketing the product, L’Oreal learned of ZHD’s state service mark and contacted ZHD. ZHD stated that it did not sell its own hair products but that it intended to do so. In 1985, ZHD began working with chemists to develop its own hair products. ZHD began selling a few bottles of shampoo over the counter in its salon with its business card taped to the bottles. Between November 1985 and February 1986, ZHD privately sold a few bottles of shampoo to a friend in Texas and a hair stylist friend in Florida. ZHD had also ordered 25,000 bottles silkscreened with the name ZAZU. In April 1986, L’Oreal began selling its hair coloring product, ZAZU, nationally. In June 1986, L’Oreal registered the ZAZU trademark with the U.S. Patent and Trademark Office (PTO). ZHD brought a trademark infringement suit. The district court found that ZHD’s sales gave it the exclusive right to use the name ZAZU for hair products. L’Oreal appealed.

Rule of Law


Holding and Reasoning (Easterbrook, J.)

Dissent (Cudahy, C.J.)

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