Valu Engineering, Inc. v. Rexnord Corp.

Valu (plaintiff) manufactured conveyor guide rails primarily used in bottling-plant "wet areas" and sought to trademark three guide-rail designs after abandoning a patent application describing the designs' utilitarian advantages; Rexnord (defendant) opposed the trademark application as functional, and the Trademark Trial and Appeal Board sustained the opposition based on Valu's prior patent application, its own advertising touting the designs' functional benefits, its limited range of designs, and the economic benefits to customers. Valu appealed, arguing the Board improperly limited its analysis to wet-area uses rather than assessing all possible uses of the guide rails.