Steele v. Bulova Watch Co.

Bulova Watch Co. (plaintiff), an American company holding the registered "Bulova" trademark, sued Steele (defendant), a U.S. citizen who ran a watch business in Mexico making and selling watches falsely marked "Bulova" to deceive consumers. Steele bought some parts in the United States, and the fraudulent watches often made their way back across the border. He had registered the mark in Mexico, but Mexico's Supreme Court had nullified that registration. The district court held it lacked jurisdiction over the Lanham Act claim; the court of appeals reversed, finding a valid cause of action; the Supreme Court granted certiorari.