Lexmark International, Inc. v. Static Control Components, Inc.
United States Supreme Court
134 S. Ct. 1377 (2014)
Lexmark's (plaintiff) printer cartridges contained a microchip that disabled the cartridge once empty, letting the customer either discard it or return it for a refilled cartridge with a new chip; Static Control (defendant) made parts, including an imitation microchip, to help remanufacturers refurbish and resell Lexmark cartridges. Seeking to boost its own direct-return program, Lexmark offered customers a discount for returning empty cartridges and warned remanufacturers by letter that using Static Control's products to refurbish and resell Lexmark cartridges was illegal. After Lexmark sued Static Control for copyright infringement, Static Control countersued for false advertising, claiming Lexmark's packaging notices and warning letters misleadingly implied Static Control's business was illegal, in violation of the Lanham Act. The district court dismissed Static Control's countersuit for lack of standing; the Sixth Circuit reversed, and the Supreme Court granted certiorari.
Whether a plaintiff has standing to sue for false advertising under the Lanham Act if the plaintiff's zone of interests is within those protected by the Lanham Act and the plaintiff's injuries are proximately caused by the defendant's violation of the statute.