The Supreme Court holds the Lanham Act's core infringement provisions reach only conduct where the infringing use in commerce is domestic, vacating a $96 million judgment.
The Ninth Circuit revived Trader Joe's claims against a Canadian reseller, holding that the Lanham Act's foreign reach is a question on the merits — not federal jurisdiction — and that buying and harming a brand inside the U.S. can supply the needed domestic nexus.
The First Circuit's 2005 decision built a separate, tougher test for foreign defendants — demanding a substantial effect on U.S. commerce — and refused to let a Japanese-language website carry an American trademark claim across the Pacific.
The 1952 decision that first let an American trademark owner reach a U.S. citizen's infringing conduct abroad — and seeded seven decades of doctrinal fights over the foreign reach of the Lanham Act.
