Coach, Inc. v. Goodfellow, 717 F.3d 498

Coach sued Goodfellow and the flea market for trademark infringement by vendors under the Lanham Act; district court granted partial summary judgment on liability for contributory infringement and later awarded damages and attorney’s fees.
Defendant Goodfellow owned and operated The Southwest Flea Market in Memphis, controlled day-to-day operations, and held ultimate authority over vendors.
The flea market rented 75–100 booths and storage to multiple vendors; Director of Operations Johnson managed daily activities under Goodfellow’s oversight.
Coach notified Goodfellow of counterfeit Sales in January 2010 and the District Attorney’s Office notified him in March 2010; law enforcement conducted raids in 2010, 2011, and the market was ultimately shut down in 2011.
Goodfellow admitted knowledge of ongoing counterfeiting and raids, but evidence showed minimal, inconsistent remedial action and no license checks or vendor attestations.
The district court held Goodfellow contributorially liable under Inwood, awarded damages of $5,040,000, and later granted attorney’s fees for an exceptional case; these rulings were upheld on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Lanham Act supports contributory liability	Coach asserts Goodfellow knew or should have known of infringement and facilitated it.	Goodfellow contends there is no contributory liability without partnership or control over vendors.	Yes; Goodfellow liable for contributory infringement.
Whether the district court erred in applying Inwood standard to flea market operators	Inwood permits liability for those who facilitate infringement; flea markets may be liable.	Hardfellow argues insufficient evidence of partnership or control; remediations are not enough.	No error; liability supported by continued facilitation despite knowledge.
Whether attorney’s fees were properly awarded as an exceptional case	Prevailing party may recover fees where infringement is willful and case exceptional.	Goodfellow contends no exceptional case or that liability was not clearly established at the time.	Yes; district court did not abuse discretion; case deemed exceptional.

Inwood Laboratories, Inc. v. Ives Laboratories, Inc., 456 U.S. 844 (Supreme Court, 1982) (establishes contributory liability for facilitating infringement)
Hard Rock Cafe Licensing Corp. v. Concession Services, Inc., 955 F.2d 1143 (7th Cir. 1992) (willful blindness standard for flea market operators)
Fonovisa, Inc. v. Cherry Auction, Inc., 76 F.3d 259 (9th Cir. 1996) (knowledge of infringing activity supports liability)
Tiffany (NJ), Inc. v. eBay, Inc., 600 F.3d 93 (2d Cir. 2010) (remedial steps insufficient when knowledge of specific listings is required)
Rosetta Stone Ltd. v. Google, Inc., 676 F.3d 144 (4th Cir. 2012) (marketplaces can be liable for vendor infringement with knowledge)
U.S. Structures, Inc. v. J.P. Structures, Inc., 130 F.3d 1185 (6th Cir. 1997) (exceptional-case standard for attorney’s fees)
Leelanau Wine Cellars, Ltd. v. Black & Red, Inc., 502 F.3d 504 (6th Cir. 2007) (foundational standard for proving infringement and causation)