A visual representation that consists merely of an illustration of the goods, or of an article that is an important feature or characteristic of the goods or services, is merely descriptive under Trademark Act §2(e)(1), just as a merely descriptive word would be. See In re Pierce Arrow Motor Car Co., 55 F.2d 434, 436 (C.C.P.A. 1932) (holding the pictorial representation of the front end of an automobile enclosed within a hexagonal border merely descriptive of automobiles and automobile parts); Hangzhou Mengku Tech. Co. v. Shanghai Zhenglang Tech. Co., Opp. No. 91272143, 2024 TTAB LEXIS 575, at *30-39 (2024) (holding the pictorial representation of a wood block puzzle 3D game merely descriptive of downloadable and/or mobile computer games); In re Underwater Connections, Inc., 221 USPQ 95, 95 (TTAB 1983) (holding the pictorial representation of a compressed air gas tank merely descriptive of travel-tour services involving underwater diving); In re Eight Ball, Inc., 217 USPQ 1183, 1184 (TTAB 1983) (holding the pictorial representation of a cue stick and eight ball to be merely descriptive of applicant’s billiard parlor services); Thistle Class Ass’n v. Douglass & McLeod, Inc., 198 USPQ 504, 511-12 (TTAB 1978) (holding the pictorial representation of a thistle in the mark to be merely descriptive of the class of sailboats sold by applicant); see also In re Soc’y for Priv. & Com. Earth Stations, 226 USPQ 436, 438 (TTAB 1985) (holding the pictorial representation of an earth station merely descriptive of services of an association promoting the interests of members of the earth-station industry).

Similarly, when a mark is comprised of wording that is descriptive under §2(e)(1) and a design element that is a pictorial representation of the goods, or that reinforces the descriptive meaning of the wording, the entire mark is merely descriptive. See, e.g., DuoProSS Meditech Corp. v. Inviro Med. Devices Ltd., 695 F.3d 1247,1255 (Fed. Cir. 2012) (finding that the combination of the term SNAP and the design of a broken exclamation point, viewed as a whole, would be perceived as depicting the snapping of a syringe plunger, which is used in connection with various medical syringes); Robinson v. Hot Grabba Leaf, LLC, 2019 USPQ2d 149089, at *8 (TTAB 2019) (finding that the design of a tobacco leaf combined with the wording GRABBA LEAF, viewed as a whole, would be perceived as conveying applicant’s cigar wrap could be used as a tobacco leaf to wrap grabba tobacco or that grabba leaf tobacco was an ingredient in the wraps); In re Swatch Grp. Mgmt. Servs. AG, Ser. No. 85485359, 2014 TTAB LEXIS 131, at *33-35 (2014) (finding that the design element depicting a tourbillon - a watch component - combined with the word TOURBILLON reinforced the singular impression conveyed by the mark as a whole as merely descriptive for "jewellery, horological and chronometric instruments"), aff’d per curiam, 599 Fed. Appx. 959 (Fed. Cir. 2015).

To be considered merely descriptive, the illustration or representation "need not be completely accurate, realistic or true-to-life." Hangzhou Mengku Tech. Co. v. Shanghai Zhenglang Tech. Co., 2024 TTAB LEXIS 575, at *25-26 (citing In re Swatch Grp. Mgmt. Servs. AG, 2014 TTAB LEXIS 131, at *12); In re LRC Prods. Ltd., Ser. No. 73276141,1984 TTAB LEXIS 39, at *5 (1984). However, if the illustration or representation is sufficiently stylized, it may no longer be merely descriptive and thus may be registrable. See, e.g., In re LRC Prods. Ltd., 1984 TTAB LEXIS 39, at *1, *5-6 (finding the representation of two gloved hands not merely an illustration of applicant’s gloves, but rather sufficiently stylized as to "remove it from the category of merely descriptive marks"); In re Gen. Elec. Co., Ser. No. 73110126, 1980 TTAB LEXIS 72, at *4 (1980) (finding the representation of an electrical plug and cord to be "stylized, rather than realistic, in nature" and thus not merely descriptive of rechargeable batteries); In re Curtiss-Wright Corp., Ser. No. 72443625, 1974 TTAB LEXIS 159, at *1-2 (1974) (finding the representation of a rotor and rotor housing of the Wankel-type rotary combustion engine to be fanciful and thus not merely descriptive of engines for land, water and air vehicles).