Sixth Circuit: No likelihood of confusion between competing wines using same geographic term
In a decision last week, the Sixth Circuit affirmed a district court ruling that use of the mark "Chateau de Leelanau Vineyard and Winery" did not create a likelihood of confusion among consumers with the plaintiff's "Leelanau Cellars" federally-registered mark. "Leelanau" in both marks is a reference to a peninsula in Michigan where the wine is produced. While the district court erred by not affording the plaintiff's geographically descriptive mark the statutory presumption of secondary meaning, the court affirmed the lower court's ruling on the ground that the plaintiff had not demonstrated that a likelihood of confusion between the two marks.
More detail of Leelanau Wine Cellars, Ltd. v. Black & Red, Inc. after the jump.
