Mastercrafters Clock & Radio Co. v. Vacheron & Constantin-Le Coultre Watches, Inc.
United States Court of Appeals for the Second Circuit
221 F.2d 464 (1955)
Vacheron (defendant) imported the well-known, prestigious Swiss Atmos clock, retailing at $175, while Mastercrafters (plaintiff) manufactured a similar-looking but electrically corded "Model 308" clock bearing its own name, retailing at $30-$40. Mastercrafters sought a declaratory judgment that its clock didn't unfairly compete with the Atmos; Vacheron counterclaimed to enjoin the Model 308's sale, presenting customer statements referring to "the lower-priced Atmos" and getting a clock "just like the Atmos" for $30-$40. The district court ruled for Mastercrafters, finding no unfair competition partly because Mastercrafters's own name appeared on the Model 308, and Vacheron appealed.
Whether a likelihood that a third party such as a purchaser's friend will confuse the sources of a product is sufficient to render a manufacturer's copying actionable.