The Federal Circuit held that a false claim that a product feature is 'patented' can support a Lanham Act false-advertising claim — provided it misleads consumers about the nature, characteristics, or qualities of the goods, not merely their authorship.
The Ninth Circuit recognized that imitating a celebrity's distinctive voice to imply sponsorship can be a false-endorsement violation of Section 43(a) of the Lanham Act.
The Supreme Court replaced three competing circuit tests with a single rule — a false-advertising plaintiff must fall within the Lanham Act's zone of interests and show proximate cause.
The Supreme Court held that 'origin of goods' in the Lanham Act means the producer of the tangible product sold, not the author of the ideas it embodies — sharply narrowing reverse passing off.
