Chateau Lynch-Bages v. Chateau Angelus S.A.
24-1197
| Fed. Cir. | Jun 13, 2025Background
- Chateau Lynch-Bages (Opposer) opposed Chateau Angelus S.A.’s (Applicant) application to register the trademark "ECHO D’ANGÉLUS," arguing it would likely cause confusion with Opposer’s own registered mark, "ECHO DE LYNCH BAGES."
- The Trademark Trial and Appeal Board (Board) partially dismissed the opposition, finding no likelihood of confusion for certain goods, particularly wine.
- The Board considered the similarity of the goods, channels of trade, consumer care, and third-party registration use of the term “ECHO,” and deemed the goods and channels of trade identical, but found "ECHO" was a weak component.
- In assessing mark similarity, the Board treated "ANGÉLUS" and "LYNCH BAGES" as house marks—despite neither party arguing this—and assigned great weight to these components in its confusion analysis.
- The Federal Circuit reviewed the Board’s factual findings for substantial evidence and its legal conclusions de novo, ultimately finding the Board’s house mark determination unsupported and critical to the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there substantial evidence the marks contained house marks? | No evidence supported this finding; Board erred. | Both terms are main components; didn't address evidence for 'house mark' status. | No substantial evidence; Board erred. |
| Was the Board's similarity analysis flawed due to reliance on 'house marks'? | House mark finding was critical and erroneous, tainting the result. | Did not properly engage with evidence for house marks; relied on 'main component' assertion. | Yes, error was not harmless and undermined analysis. |
| Should the Board's decision be vacated and remanded? | The error requires reversal and further proceedings. | No specific argument on remand. | Yes, vacated and remanded. |
| Did the Board properly weigh the DuPont factors? | Board misapplied similarity factor due to unjustified house mark analysis. | Did not dispute substantial evidence on other factors. | Holding depends on similarity finding; process undermined. |
Key Cases Cited
- In re E.I. DuPont de Nemours & Co., 476 F.2d 1357 (C.C.P.A. 1973) (sets forth the factors for likelihood of confusion in trademark cases)
- On-Line Careline, Inc. v. Am. Online, Inc., 229 F.3d 1080 (Fed. Cir. 2000) (likelihood of confusion is a legal question based on factual findings)
- QuikTrip W., Inc. v. Weigel Stores, Inc., 984 F.3d 1031 (Fed. Cir. 2021) (de novo review of ultimate likelihood of confusion determination)
- Cai v. Diamond Hong, Inc., 901 F.3d 1367 (Fed. Cir. 2018) (defines substantial evidence standard)
- Stratus Networks, Inc. v. UBTA-UBET Commc’ns Inc., 955 F.3d 994 (Fed. Cir. 2020) (factual findings for DuPont factors require substantial evidence)
- In re i.am.symbolic, llc, 866 F.3d 1315 (Fed. Cir. 2017) (marks’ similarity considered by overall impression, not just shared words)