Lexmark Int'l, Inc. v. Static Control Components, Inc.
134 S. Ct. 1377
| SCOTUS | 2014Background
- Lexmark sells printers and its own cartridge style; Prebate program gives a discount if customers return empty cartridges to Lexmark.
- Prebate cartridges contain a microchip that disables the cartridge unless Lexmark replaces it; Static Control sells components to remanufacture Lexmark cartridges and developed a chip that mimics Lexmark’s.
- Lexmark sued Static Control for copyright violations; Static Control counterclaimed under §43(a) of the Lanham Act for false advertising.
- District Court dismissed Static Control’s Lanham Act claim for lack of prudential standing under a Carpenters-based test; Sixth Circuit reversed applying a different standard.
- The question presented is whether §1125(a) extends to Static Control, a non-direct competitor that alleges injury to its commercial interests.
- The Court ultimately held that Static Control falls within the class authorized to sue under §1125(a), based on zone-of-interests and proximate-cause analyses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §1125(a) authorize Static Control to sue for false advertising? | Static Control: within the statute’s scope to sue for unfair competition harms. | Lexmark: concerns about who Congress intended to protect under §1125(a) via standing rules. | Yes; Static Control may sue under §1125(a). |
| Should zone-of-interests and proximate-causation govern §1125(a) standing, not prudential tests? | Static Control argues for zone-of-interests/proximate-causation framework. | Lexmark urges multifactor balancing/other tests (Associated General Contractors, etc.). | Zone-of-interests and proximate causation govern, not the prudential balancing tests. |
| What is the proper analytical framework to determine who may sue under §1125(a)? | Static Control relies on statutory interpretation; not a mere prudential label. | Lexmark seeks a balancing or direct-competitor approach. | Apply zone-of-interests plus proximate-cause; reject balancing/direct-competitor/reasonable-interest tests. |
| Does Static Control’s injury satisfy proximate-cause requirements under §1125(a)? | Injury flows from Lexmark’s misrepresentations due to its impact on remanufacturers and Static Control’s chips. | Harm to remanufacturers or third parties may be too remote. | Yes; proximate causation shown because Lexmark’s false advertising injures Static Control’s sales and reputation via direct linkage to its microchips. |
Key Cases Cited
- Associated General Contractors of Cal., Inc. v. Carpenters, 459 U. S. 519 (1983) (statutory standing framework for private damages actions)
- Lujan v. Defenders of Wildlife, 504 U. S. 555 (1992) (standing—injury in fact, traceability, redressability)
- Holmes v. Securities Investor Protection Corp., 503 U. S. 258 (1992) (proximate causation for statutory actions; limits on broad standing)
- Steel Co. v. Citizens for Better Environment, 523 U. S. 83 (1998) (statutory standing; emphasis on proper framework)
- Bridge v. Phoenix Bond & Indemnity Co., 553 U. S. 639 (2008) (proximate causation and direct injury in false advertising context)
- Dura Pharmaceuticals, Inc. v. Broudo, 544 U. S. 336 (2005) (proving causation in private actions)