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tOSU trademark issues with BP

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Alan should be able to smooth this over by getting the right person's ear. Buckeyeplanet has done nothing wrong and will be fine as long as we don't challenge tOSU to a fight. The T-shirt could just go away. I'm not sure what the point in pursuing it right now would be with a changed design or for charity or whatever.

As far as the website itself and it's logo:
The Buckeye leaf is from the state tree.
The football is pretty generic.
The color is not quite scarlet (not that it matters).
OSU football is discussed here, but so is Ohio high school and pro football.
It is obviously not for profit.
It doesn't sell ANYTHING (it would probably be a good idea to keep this true).
It is clearly stated that this site is not affiliated with tOSU in any way.
It has a legitimate long-term use and as such is not "cybersquatting".

As soon as all of the above can be proven to someone at OSU this all goes away. If you put it in your response to some eager legal-eagle who didn't even bother to check out the site, they will equally not read your response. Wait for Alan. If he can't get the right ears in the next two days, then formulate a SIMPLE response. Something like:

Buckeyeplanet.com has existed and continues to exist as a not-for-profit fan website for football fans from the state of Ohio. Since you obviously are not willing to officially license shirts for the purpose of raising funds for the non-profit organization we will not make or sell any T-shirts or any other product.

To date, we have made 0 products. We have sold 0 products. We have made 0 dollars. In the future we do not expect to make or sell any product.

Thank you for your assistance in this matter.
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I think we've got a pretty beautiful setup with Alan to go into the ring for us. I have a feeling that this individual does not represent tOSU's general feeling towards a site like BP but rather towards a sleazy for-profit gimmick site.

In the meantime, Oh8ch nailed it: we must all relax until then (still debating whether that's possible for me). Heck, if I can agree to try and let this work itself out for a few days (with me being a very emotional person and being very heavily invested in this), I think the rest of us can try too. :wink:

Thanks for all of your input guys. By all means continue to post stuff regarding the incident, just do so in a researching manner rather than a reactive mannner (which admittedly I started with the sentiment of my first post).
 
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Here is a FAQ about receiving cease and desist letters:
http://www.chillingeffects.org/trademark/faq.cgi

Some relevant excerpts from that page:

Question: I have an unsettling feeling in the pit of my stomach about the tone of the C&D I received. Does the tone of the c & d mean I am going to lose this dispute? Answer: "Gorilla Chest Thumping" refers to the tone of most C&Ds: it’s nasty. The first thing to do is take a deep breath. The second thing to do is to acknowledge that the tone of the letter is a function of the letter writer’s perception that aggression is the best defense: do not take it personally. The third thing to do is ignore the tone and focus on the facts. You may eventually choose to respond aggressively yourself, but do not do so because your opponent has egged you into a useless game of whose gorilla is bigger. Take a tip from Ani Di Franco: "If you play their game, girl, you’re never gonna win." Face Up and Sing, Out of Range, Righteous Babe Records (1994).


Question: What is the bare minimum of trademark law that I have to understand to decipher this C&D? Answer: Your opponent should say that your mark is causing consumer confusion or is likely to cause consumer confusion. Or it should mention it's famousness and complain of dilution or tarnishment. (If the C&D does not say this, then no trademark claim may actually exist, and you can rest assured that your opponent is engaging in scare tactics or has hired a highly incompetent attorney).

Functioning in a quasi-magical talisman-like capacity, trademarks designate the source or quality of goods or services. For this reason, the law protects against confusion in the market place by ensuring that marks on the same or similar products or services are sufficiently different. The law also protects famous marks against dilution of value and tarnishment of the reputation of the goods or services on which it appears or the source of those products.

You can roughly assess the validity of your opponent’s claim of confusion by classifying the marks involved. A trademark can fall into one of 5 categories. It can be: (1) fanciful; (2) arbitrary; (3) suggestive; (4) descriptive; or (5) generic. Not all of these varieties of marks are entitled to the same level, or indeed any level, of trademark protection.

A fanciful mark is a mark someone made up; examples include KODAK or HÄAGEN-DAZS. An arbitrary mark is a known term applied to a completely unrelated product or service; for instance, AMAZON.com for an online book-store cum one-stop shopping site or APPLE for computers. Fanciful and arbitrary marks are considered strong marks and garner substantial trademark protection.

A suggestive mark is one that hints at the product, but which requires an act of imagination to make the connection: COPPERTONE for sun tan lotion or PENGUIN for coolers or refrigerators are examples. Suggestive marks are also strong marks and receive protection.

A descriptive mark, predictably, describes the product: HOLIDAY INN describes a vacation hotel and FISH-FRI describes batter for frying fish. Descriptive marks do not receive any trademark protection unless their user has used them in commerce and has built up secondary meaning. "Secondary meaning" occurs when consumers identify the goods or services on which the descriptive term appears with a single source. In other words, if consumers know that HOLIDAY INN hotels are all affiliated with a single source, then the mark has secondary meaning and receives trademark protection.

Finally, generic marks simply designate the variety of goods involved: for example, "cola" used on soft drinks and "perfume" on perfume are both generic terms. Generic marks never receive any trademark protection; they are free for everybody to use. (Keep in mind, though, that "Cola" on a nightclub is arbitrary, and therefore receives protection).

If your opponent is complaining that you have used the word "bakery" for a bake shop or "car" for a car repair shop, then you can safely guess that the c & d is baseless. On the other hand, if your opponent is concerned about the fact that both of you use of the term "Sweet Pickles" on alpaca sweaters, then the c & d may have some merit.



Question: I do not know what these cases or statutes cited in the C&D mean.

Answer: If your opponent has cited cases and statutes in the C&D, do not freak out. The fact that your opponent can include some legal authority in the C&D does not mean that the law is on its side. If you can, go look up the cases and statutes to see what they say. You can go to the nearest law school's law library for help, or you can try a free legal resource web site like Findlaw. Many of them are accessible on the Internet by keyword search using the full case name or it's citation (the numbers and abbreviations that follow the names of the parties).

If your opponent is relying on federal law, it will probably cite one or more of the following sections of the Lanham Act:
(1) section 32 (also known as section 1114);
(2) section 43(a) [a/k/a section 1125(a)]; or
(3) section 43(c) [a/k/a section 1125(c)]. (The smaller numbers indicate how the statutory sections were numbered when the law was a bill in Congress; the larger numbers indicate how the statutory sections were re-numbered when the law was codified in the U.S. Code. Under either numbering system, the laws say the same thing). An additional statute, the Anti-cybersquatting Consumer Protection Act (ACPA) [a/k/a section 1125(d) relates specifically to domain names.

Section 32 (codified as 15 U.S.C. 1114) is the basic statute governing trademark infringement of registered marks. If you use a mark in commerce that is confusingly similar to a registered trademark, you may be civilly liable under section 32. This section describes how to determine infringement, what the remedies are, and what defenses are available.

Section 43(a) [codified as 15 U.S.C. 1125(a)] is the "false designation of origin" statute. If you use a mark in commerce that is likely to cause confusion or deception as to affiliation, association, origin, or sponsorship with another trademark, you may be civilly liable under section 43(a). Section 43(a) does not require that any of the marks be registered.

Section 43(c)[codified as 15 U.S.C. 1125(c)] is the "anti-dilution" provision. This section allows the owner of a famous trademark to prevent use of the mark by junior users whose use “dilutes” the distinctive quality of the famous trademark. In other words, if someone tries to sell "KODAK pianos," KODAK could stop the person -- even if consumers were not confused -- because KODAK is a famous mark, and its use on products other than film and film-printing accessories (or other products on which Eastman Kodak places the mark) dilutes its uniqueness.

The ACPA [codified as 15 USC 1125(d) prohibits "cybersquatting" and lists the elements and defenses to a civil claim against a domain name holder.

If you identify the statutory provisions on which your opponent relies, you can begin to get a feel for whether the C&D has merit. For instance, if your opponent relies on section 32, but does not disclose a registration number, your first question is: does your opponent have a registered mark? If not, it has no claim under section 32.



Question: What is this laundry list of things the C&D says will happen if I don't obey?

Answer: Your opponent may describe a parade of horribles to demonstrate with exquisite detail what it will do to you unless you capitulate. This list generally includes, but is not limited to:
(1) ceasing use of the allegedly infringing mark or surrendering the domain name;
(2) rendering an accounting;
(3) posting corrective advertising;
(4) obtaining an injunction;
(5) recovering costs and fees.

Though these things sound awful, they are not medieval tortures (although that may be a function of the fact that Torquemada never thought of them).

Ceasing use of the mark is self-explanatory: your opponent wants you to stop using the mark. Your opponent might also ask you to surrender your domain name if they believe the domain name causes (or is likely to cause) confusion with their trademark. For example, under ICANN rules (the UDRP), you may have to surrender your domain name if the following three conditions are satisfied:
(1) your domain name is identical or confusingly similar to your opponent’s;
(2) you have no legitimate right or interest in the name (in other words, you are not using the name to conduct a bona fide business or for non-commercial fair use purposes); and
(3) your name is registered and used in bad faith.

An accounting basically means that you disclose the following information to your opponent:
(1) the date you began using the allegedly infringing mark;
(2) the names of individuals who knew of the use when it began;
(3) the amount of traffic at your web site or business at your store; and
(4) your profits and revenues during the time you used the allegedly infringing mark.

Corrective advertising means you give notice to the public that you were using a mark confusingly similar to your opponent’s, and that you are not affiliated with your opponent.

An injunction is a judicial order to do something. An injunction can prevent you from using the allegedly infringing trademark.

Some provisions of the Lanham Act permit a trademark holder to recover attorney’s fees and court costs from an infringer.

That your opponent has listed these various remedies does not mean that it is entitled to them; do not confuse the smorgasbord of legal options with your opponent’s right to inflict any of them on you.



Question: What is the Anti-Cybersquatting Consumer Protection Act (ACPA)?

Answer: The ACPA [codified as 15 USC 1125(d)] is aimed at people who register a domain name with the intention of taking financial advantage of another's trademark. For instance, if BURGER KING did not have a web site, and you registered www.BURGERKING.com with the intent of selling the site to BURGER KING for a royal ransom, you could be liable under ACPA.

ACPA applies to people who:
(1) have a bad faith intent to profit from a domain name; and
(2) register, use or traffic in a domain name;
(3) that is identical, confusingly similar, or dilutive of certain trademarks. The trademark does not have to be registered.

ACPA provides that cyberpirates can be fined between $1,000 and $100,000 per domain name for which they are found liable, as well as being forced to transfer the domain name.

Somewhat more broadly, the Act is meant to reduce consumers' confusion about the source and sponsorship of Internet web pages. The idea is to provide customers with a measure of reliability, so that when they visit www.burgerking.com, they will be able to find actual Burger King products, not something entirely different. It also protects mark owners from loss of customer goodwill that might occur if others used the trademark to market disreputable goods or services.

See the module on ACPA to find out more about bad faith and legitimate defenses.




Question: What implication does alleged confusion have on claims of trademark infringement?

Answer: A mark that is confusingly similar so closely resembles a registered trademark that it is likely to confuse consumers as to the source of the product or service. Consumers could be likely to believe that the product with the confusingly similar mark is produced by the organization that holds the registered mark. Someone who holds a confusingly similar mark benefits from the good will associated with the registered mark and can lure customers to his/her product or service instead. Infringement is determined by whether your mark is confusingly similar to a registered mark. The factors that determine infringement include:



  • proof of actual confusion
  • strength of the established mark
  • proximity of the goods in the marketplace
  • similarity of the marks’ sound
  • appearance and meaning
  • how the goods are marketed
  • type of product and how discerning the customer is
  • intent behind selecting the mark
  • likelihood of expansion in the market of the goods
Question: What are the limits of trademark rights? Answer: There are many limits, including:


  • Fair Use

    There are two situations where the doctrine of fair use prevents infringement:
    1. The term is a way to describe another good or service, using its descriptive term and not its secondary meaning. The idea behind this fair use is that a trademark holder does not have the exclusive right to use a word that is merely descriptive, since this decreases the words available to describe. If the term is not used to label any particular goods or services at all, but is perhaps used in a literary fashion as part of a narrative, then this is a non-commercial use even if the narrative is commercially sold.
    2. Nominative fair use

      This is when a potential infringer (or defendant) uses the registered trademark to identify the registrant’s product or service in conjunction with his or her own. To invoke this defense, the defendant must prove the following elements:
      • his/her product or service cannot be readily identified without pointing to the registrant’s mark
      • he/she only uses as much of the mark as is necessary to identify the goods or services
      • he/she does nothing with the mark to suggest that the registrant has given his approval to the defendant
  • Parody Use
    Parodies of trademarked products have traditionally been permitted in print and other media publications. A parody must convey two simultaneous -- and contradictory -- messages: that it is the original, but also that it is not the original and is instead a parody.
  • Non-commercial Use
    If no income is solicited or earned by using someone else's mark, this use is not normally infringement. Trademark rights protect consumers from purchasing inferior goods because of false labeling. If no goods or services are being offered, or the goods would not be confused with those of the mark owner, or if the term is being used in a literary sense, but not to label or otherwise identify the origin of other goods or services, then the term is not being used commercially.
  • Product Comparison and News Reporting
    Even in a commercial use, you can refer to someone else’s goods by their trademarked name when comparing them to other products. News reporting is also exempt.
  • Geographic Limitations
    A trademark is protected only within the geographic area where the mark is used and its reputation is established. For federally registered marks, protection is nationwide. For other marks, geographical use must be considered. For example, if John Doe owns the mark Timothy’s Bakery in Boston, there is no infringement if Jane Roe uses Timothy’s Bakery to describe a bakery in Los Angeles.
Question: What are the limits on dilution? Answer: The Federal Trademark Dilution Act of 1995 (FTDA, 15 U.S.C. 1125) prohibits the commercial use of a famous mark if such use causes dilution of the distinctive quality of the mark.

A mark may be diluted either by "tarnishment" or "blurring." Tarnishment occurs when someone uses a mark on inferior or unwholesome goods or services. For example a court found that a sexually explicit web site using the domain name "candyland.com" diluted by tarnishment the famous trademark "CANDY LAND" owned by Hasbro, Inc. for its board games.

Blurring occurs when a famous mark or a mark similar to it is used without permission on other goods and services. The unique and distinctive character of the famous mark to identify one source is weakened by the additional use even though it may not cause confusion to the consumer.

The following uses of a famous mark are specifically permitted under the Act:

1) Fair use in comparative advertising to identify the goods or services of the owner of the mark.
2) Noncommercial uses of a mark.
3) All forms of news reporting and news commentary.

In addition, the courts have differed as to what constitutes a "famous" mark under the FTDA. In some cases the courts have said that the famousness requirement limits the Act to a very small number of very widely known marks. Other courts, however, have accepted lesser-known marks as PANAVISION, WAWA and EBONY as being famous and yet others have said that merely being famous in one's product line is sufficient.

Many states also have antidilution laws protecting mark owners.



Question: What does it mean to take all reasonable steps to protect a trademark?

Answer: If a trademark owner fails to police his or her mark, the owner may be deemed to have abandoned the mark or acquiesced in its misuse. A trademark is only protected while it serves to identify the source of goods or services.

If a trademark owner believes someone is infringing his or her trademark, the first thing the owner is likely to do is to write a "cease-and-desist" letter which asks the accused infringer to stop using the trademark. If the accused infringer refuses to comply, the owner may file a lawsuit in Federal or state court. The court may grant the plaintiff a preliminary injunction on use of the mark -- tell the infringer to stop using the trademark pending trial.

If the owner successfully proves trademark infringement in court, the court has the power to: order a permanent injunction; order monetary payment for profit the plaintiff can prove it would have made but for defendant's use of the mark; possibly increase this payment; possibly award a monetary payment of profits the defendant made while using the mark; and possibly order the defendant to pay the plaintiff's attorney fees in egregious cases of infringement.



Question: What defenses are there to trademark infringement or dilution?

Answer: Defendants in a trademark infringement or dilution claim can assert basically two types of affirmative defense: fair use or parody.

Fair use occurs when a descriptive mark is used in good faith for its primary, rather than secondary (trademark), meaning, and no consumer confusion is likely to result. So, for example, a cereal manufacturer may be able to describe its cereal as consisting of "all bran," without infringing upon Kelloggs' rights in the mark "All Bran." Such a use is purely descriptive, and does not invoke the secondary meaning of the mark. Similarly, in one case, a court held that the defendant's use of "fish fry" to describe a batter coating for fish was fair use and did not infringe upon the plaintiff's mark "Fish-Fri." Zatarain's, Inc. v. Oak Grove Smokehouse, Inc., 698 F.2d 786 (5th Cir. 1983). Such uses are privileged because they use the terms only in their purely descriptive sense.

Some courts have recognized a somewhat different, but closely-related, fair-use defense, called nominative use. Nominative use occurs when use of a term is necessary for purposes of identifying another producer's product, not the user's own product. For example, in a recent case, the newspaper USA Today ran a telephone poll, asking its readers to vote for their favorite member of the music group New Kids on the Block. The New Kids on the Block sued USA Today for trademark infringement. The court held that the use of the trademark "New Kids on the Block" was a privileged nominative use because: (1) the group was not readily identifiable without using the mark; (2) USA Today used only so much of the mark as reasonably necessary to identify it; and (3) there was no suggestion of endorsement or sponsorship by the group. The basic idea is that use of a trademark is sometimes necessary to identify and talk about another party's products and services. When the above conditions are met, such a use will be privileged. New Kids on the Block v. News America Publishing, Inc., 971 F.2d 302 (9th Cir. 1992).

Finally, certain parodies of or using trademarks may be permissible if they are not too directly tied to commercial use. The basic idea here is that artistic and editorial parodies of trademarks serve a valuable critical function, and that this critical function is entitled to some degree of First Amendment protection. The courts have adopted different ways of incorporating such First Amendment interests into the analysis. For example, some courts have applied the general "likelihood of confusion" analysis, using the First Amendment as a factor in the analysis. Other courts have expressly balanced First Amendment considerations against the degree of likely confusion. Still other courts have held that the First Amendment effectively trumps trademark law, under certain circumstances. In general, however, the courts appear to be more sympathetic to the extent that parodies are less commercial, and less sympathetic to the extent that parodies involve commercial use of the mark.

So, for example, a risqué parody of an L.L. Bean magazine advertisement (L.L. Beam's "Back to School Sex Catalog") was found not to constitute infringement. L.L. Bean, Inc. v. Drake Publishers, Inc., 811 F.2d 26, 28 (1st Cir. 1987). Similarly, the use of a pig-like character named "Spa'am" in a Muppet movie was found not to violate Hormel's rights in the trademark "Spam." Hormel Foods Corp. v. Jim Henson Prods., 73 F.3d 497 (2d Cir. 1996). On the other hand, "Gucchie Goo" diaper bags were found not to be protected under the parody defense, Gucci Shops, Inc. v. R.H. Macy & Co., 446 F. Supp. 838 (S.D.N.Y. 1977). Similarly, posters bearing the logo "Enjoy Cocaine" were found to violate the rights of Coca-Cola in the slogan "Enjoy Coca-Cola", Coca-Cola Co. v. Gemini Rising, Inc., 346 F. Supp. 1183 (E.D.N.Y. 1972). In short -- although the courts recognize a parody defense, the precise contours of that defense are difficult to outline with any precision.



Question: What is non-commercial use of a trademark? Is non-commercial use infringment of a trademark?

Answer: Non-commercial use of a trademark is generally that use which is not related to the sale of goods or services. If no income is solicited or earned by using someone else's mark, this use is not normally infringement.

Trademark rights protect consumers from purchasing inferior goods because of false labeling. If no goods or services are being offered, or the goods would not be confused with those of the mark owner, or if the term is being used in a literary sense, but not to label or otherwise identify the origin of other goods or services, then the term is not being used commercially.
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Guys and Gals,

Man, this has just ruined my night. I am apologizing to the Planet as a whole because I had/have a large part in this whole thing. The last thing that I wanted to happen was to have OSU's goons threaten Clarity and this site. I am however not giving up on this "project" and am in it for the long haul and will do whatever it takes for this to be resolved fairly and peacefully.

Additionally, Alan I do trust you and have never doubted you. Please work your magic, I know you can make this go away.

Again, if anything bad comes out of this I apologize.
 
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I gotta agree with Mili on this one.

MililaniBuckeye said:
Then they'd better take action against Bucknuts.com, too...I'd like to see them take action against me for having my "www.mililanibuckeye.net" site. Besides, your T-shirts had nothing resembling any OSU logo. Fuck 'em.
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First, I've received no such warning. Not by mail, not by fax, not by email. All of those means of contact are readily available to anyone who goes looking for them. This doesn't mean that I don't believe some boilerplate C&D was sent, just that it hasn't yet arrived here. I see "March 1", and see "via FedEx", so I'll look forward to getting something.

Secondly, the website won't be changing name or URL. We don't use OSU logos in the masthead, we don't sell anything, we don't charge anything, we gain nothing but interaction with like-minded people. They can't block us from that.

Finally, while they can reject an application to sell shirts on campus (and probably would), they can say nothing about off campus. Again, this comes back to the shirts not having any of their intellectual property on them. "Buckeye" is by no means exclusive to Ohio State. There are no players or depictions of players on the shirts, none of the school seals or logos are on it, not even the school name. You're not selling them, you're giving them away during a new server fundraiser for the site.

I think it's great that Alan is looking into this, I just ask that if it comes down to to some sort of situation where the site has to be directly represented, positional statements made, that someone pass all the relevant info off to [email protected] so that I can be brought up to speed and deal with it.

This smells like an overzealous (and rather ignorant - at least in terms of what BP.com is) lawyer in the system hearing "Buckeyes", "t-shirts", "sell", assuming that we're improperly selling shirts with their property involved, thereby violating the collegiate licensing agreements already in place, and generally causing problems and overstepping our bounds. None of the above is true, obviously.

In regards to go-bucks.net, I remember John saying he was being forced to give that doman up to the university. Look at it now though. Owned by a third party who has some free email thing there. At least the last time I looked.

Anyway, worry not. This is a non-issue. If he chooses to make it one, then it will be dealt with, and I will genuinely enjoy dealing with it. Either way, not something to be particularly concerned about.
 
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Hey Clarity, good to hear from you and I wish you well

CoosMeister said:
I am really unclear about what OSUs beef is...

When they mentioned the anti-squatting laws I am convinced they messed up. It doesn't make sense because you were asking them to buy anything.
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I think they're just listing a lot of stuff as a scare tactic knowing that some or all of it has no merit.
 
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What a blessing it is to have Clarity back tonight to restore order to the ranks. His post is authoritative, thoughtful, and to the point. I was not too worried after hearing back from many of you but he has erased all doubts in my mind.

I guess what we've gathered from all of this is that there will be no excess t-shirt sales at the spring game. However it seems we have pretty good ground to stand on for producing t-shirts independently and giving them away to BP members (it goes without saying that you are heavily encouraged to make a donation).
 
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Clarity said:
This smells like an overzealous (and rather ignorant) lawyer in the system hearing "Buckeyes", "t-shirts", "sell", assuming that we're improperly selling shirts and thereby violating the collegiate licensing agreements already in place, and generally causing problems and overstepping our bounds.
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thats exactly what i was going to say. the response was far to generic to have been thoroughly researched. id imagine alan will point someone at tOSU to this site, they will actually take a look at it for longer than 3 seconds and realize there is no threat here. end result will likely be all of this will go away and 50/50 on the ok for the shirts.

*shrug* im not a lawyer though so i promise nothing.

i think tOSU realizes that free sites like this greatly increase revenue generated by tOSU rather than hindering it.
 
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Already got the mannaise jar marked donations ready to go. I am sure that after you hand the members their complimentary t-shirt they will be happy to donate some arbitrary amount depending on whether or not the shirt is long or short sleeve. :sneaky:

BuckeyeFROMscUM said:
What a blessing it is to have Clarity back tonight to restore order to the ranks. His post is authoritative, thoughtful, and to the point. I was not too worried after hearing back from many of you but he has erased all doubts in my mind.

I guess what we've gathered from all of this is that there will be no excess t-shirt sales at the spring game. However it seems we have pretty good ground to stand on for producing t-shirts independently and giving them away to BP members (it goes without saying that you are heavily encouraged to make a donation).
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