IN RE MIRACLE TUESDAY, LLC, 695 F.3d 1339

Summary

The applicant contended that its principal who designed the accessories was a French citizen who lived in Paris, France, before relocating to the United States, and that the principal's significant ties to Paris were sufficient to warrant the use of the term "Paris" in the applicant's trademark. The court held that the refusal to register the trademark was proper since a substantial portion of relevant consumers would be deceived into believing that the goods originated in Paris. It was undisputed that Paris was a well known source of fashion accessories, and the fact that the applicant's principal was formerly a Parisian did not overcome the fact that the accessories were designed and manufactured at a geographic location other than Paris, since the relevant inquiry was whether the accessories rather than the designer had a geographic connection to Paris. Further, the primary significance of Paris was a geographic location and, in view of the renown and reputation of fashion designs ...