Mead Data Central, Inc. v. Toyota Motor Sales, U.S.A., Inc.
United States Court of Appeals for the Second Circuit
875 F.2d 1026 (1989)
Mead Data Central, Inc. (plaintiff) operated a computer legal-research service under the trademark Lexis, and Toyota Motor Corporation (defendant), after being advised no conflict existed, began marketing new luxury cars under the mark Lexus. Mead sued for trademark dilution after Toyota ignored cease-and-desist letters, and at trial the evidence showed 76 percent of surveyed attorneys associated Lexis with Mead's legal-research service, but only 1 percent of the general public made any such connection; the district court nonetheless found a likelihood of dilution and ruled for Mead, and Toyota appealed.
Whether trademark dilution can occur if there is no reasonable likelihood of a mental association between the marks in the minds of consumers.