District Judge Paul Engelmayer
Other than its state law claims for deceptive trade practices and false advertising—for which summary judgment was granted for Horizon Trading USA—district court granted Coach judgment on its Lanham Act claims of trademark infringement and false designation of origin. It also granted Coach judgment on its claim for copyright infringement under 17 USC §501. Horizon sold counterfeit sunglasses bearing a design consisting of stylized letters “G” and “C,” which infringed Coach’s “Signature C” mark. In addition to defendants’ admission that their sunglasses were likely to cause confusion, the court found defendants’ “GC” mark—a registered trademark of USA Tiger Group—indistinguishable from Coach’s mark. Rejecting as “wholly without merit” defendants’ claim of lawful use of a registered trademark, the court found numerous differences between the USA Tiger Group mark and defendants’ infringing mark. The same was true of defendants’ “CC” sunglasses, which used a pattern of Cs in combinations identical to Coach’s Signature C mark. Considering the factors in Union of Orthodox Jewish Organizations, the court found an award of $100,000 in statutory damages under 15 USC §1117(c)(1) appropriate.