Mattel Inc. did not create the perception of a business relationship between itself and the plaintiff in violation of the Lanham Act when it adopted the “Pearl Beach” moniker for its 1998 “pool and beach” Barbie doll, the 9th U.S. Circuit Court of Appeals affirmed April 26 (Walter v. Mattel Inc., 9th Cir., No. 98-56801, 4/26/00).

Senior Judge William W. Schwarzer, writing for the court, found that the district court did not err in its application of four of the eight Sleekcraft factors, resulting in its holding that there was no likelihood of confusion raised by Mattel’s use of “Pearl Beach.”

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