Rolex Watch, U.S.A., Inc. v. Michel Co.

Michel Company (defendant) reconditioned used Rolex (plaintiff) watches using non-Rolex parts, including replacing dials, bracelets, and bezels, then sold the reconditioned watches to jewelers while keeping the Rolex trademark on them. Rolex sued for trademark counterfeiting; the district court ruled for Rolex but only required Michel to add its own mark alongside a written disclosure, without enjoining continued use of the Rolex mark. Rolex appealed the adequacy of that remedy.