Guthrie Healthcare System v. ContextMedia, Inc.
United States Court of Appeals for the Second Circuit
826 F.3d 27 (2016)
Guthrie Healthcare (plaintiff), a nonprofit operating facilities in southwestern New York and northwestern Pennsylvania but recruiting and fundraising nationally, held a registered logo trademark that ContextMedia (defendant), a healthcare media provider placing televisions in physicians' offices, used in a nearly identical form; the district court found a likelihood of confusion only within Guthrie's immediate geographic service area and limited the injunction accordingly, permitting ContextMedia's continued use elsewhere including online. Guthrie appealed the injunction's limited scope, and ContextMedia cross-appealed the infringement finding.
Whether an injured senior trademark user who demonstrates likely confusion with a junior user's similar mark may be entitled to an injunction beyond the senior user's geographic region, if a broader injunction is necessary to provide reasonable protection against the infringement.