General Motors Corp. v. Keystone

Tong Yang (defendant) manufactured aftermarket replacement grilles with placeholder cutouts shaped exactly like Chevrolet's bowtie and GMC's letter trademarks, sold through retailers including Keystone (defendant), with customers expected to buy the genuine emblems separately from GM (plaintiff) to insert into the placeholders. GM sued for trademark infringement, arguing the placeholders remained visible even after genuine emblems were installed and that their low quality harmed the GM brand through post-sale confusion; the district court found no likelihood of post-sale confusion and granted summary judgment to the defendants, and GM appealed.