INTA Amicus Request - Louboutin v Yves Saint Lauren

8/3/2019 INTA Amicus Request - Louboutin v Yves Saint Lauren

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UNITED STATES COURT OF APPEALS FO R THE SECOND CIRCUITThurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500

MOTION INFORMATION STATEMENTDocket Number(s): 1 1 - 3 3 03 -' CVMotion for: .Extension of ime to seek leave and file

amicus curiae brief .Set forth below preclse, complete statement of rehef sought:Movant International Trademark Association seeks anextension of time to file an amicus curiae brief and theaccompanying motion for leave to file to November 14,2011MOVING PARTY: International Trademark AssociationD Plaintiff 0 DefendantD AppellantiPetitioner 0 Appellee/RespondentX non-party (amicus curiae) .MOVING ATTORNEY: _ I " ' a " " ' J l ~ e t ' " ' C ......J ...I ...JmU.L_-_______

Caption [use shor t title1Christian Louboutin S.A., et aI., v. Yves Saint LaurentAmerica Holdings, Inc., et al.

OPPOSINGPARTY:___I_A___________OPPOSING ATTORNEY: _-=.N..!!/..o.A"--__________

[name of attorney, with firm, address, p,hone number and e-mail]Cooley LLP Appellants consent to the proposed extension of the deadline.- - : ; - 1 7 1 7 1 4 - r - i A v - e - n - u - e - o ~ f ~ t : ; - h - e - A m - - e - , r i ~ c - : - a s - - - - - - - - - - - - Appellees are willing to consent on the condition that the time~ N ' : ' : e " " ' w ' - : Y = o r ...k 7 , : ! _ . N ~ e ~ w 7 ' _ Y , . , , 0 f _ ! r k " ' - - " - ' 1 0 > < : : O : ' : : ' 3 ' - " 6 ' _ _ _ ; - - - - - - - - - - for Appellees' brief is similarly extended by 21 days. Appellants- ' 2 " ' - 1 ' " " 2 " - - - ' 4 - ' - 7 ~ 9 _ ' - 6 ~ 5 " - ' 0 " _ ' 0 " _ ' ; _ J . j . > < . c u " " I ' " ' - l u " " m ~ @ ~ c " " ' 0 " - ' 0 " " 1 " " e y , ; . . ..,.c""o ....


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UNITED STATES COURT OF APPEALSFOR THE SECOND CIRCUIT---------------------------------- ) (CHRISTIAN LOUBOUTIN S.A.,CHRISTIAN LOUBOUTIN, L.L.C.,CHRISTIAN LOUBOUTIN,

P laintiffs-CounterDefendants-Appellants,vs.

YVES SAINT LAURENT AMERICAHOLDINGS, INC., YVES SAINTLAURENT S.A.S., YVES SAINTLAURENT A M ~ R I C A , INC.,

Defendants-CounterClaimants-Appellees.

---------------------------------- ) (

DECLARATION IN SUPPORT OFTHE INTERNATIONALTRADEMARK ASSOCIATION'SMOTION FOR EXTENSION OFTIME TO SEEK LEAVE ANDFILE AMICUS CURIAE BRIEFNo. 11-3303-CV

JANET L. CULLUM, pursuant to Title 28, United States Code, Section1746, hereby declares under penalty of perjury:

1. I am a member of the bar of this Court and a partner at the law firmCooley LLP. My firm represents the International Trademark Association("INTA"), an organization that intends to seek leave to file an amicus curiae briefin the above-captioned matter in support of vacatur of the August 10, 2011 order ofthe District Court denying the motion of Plaintiffs-Counter-Defendants-AppellantsChristian Louboutin S.A., et al. ("Appellants") for a preliminary injunction andremand to the District Court. I respectfully submit this Declaration in support of

Case: 11-3303 Document: 73-2 Page: 1 10/26/2011 429219 7

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INTA's motion for extension of time to seek leave and to file its proposed amicuscuriae brief beyond the ordinary amicus briefing deadline.

2. Founded in 1878, INTA is a not-for-profit organization dedicated tothe support and advancement of trademarks and related intellectual propertyconcepts as essential elements of trade and commerce. INTA has over 5,700members in more than 190 countries. Its members include trademark owners, lawfirms, and other professionals who regularly assist brand owners in the creation,protection and enforcement of their trademarks. All of INTA's members share thegoal of promoting an understanding of the essential role trademarks play infostering informed decisions by consumers, effective commerce, and faircompetition.

3. INTA members frequently are participants in trademark litigation asboth plaintiffs and defendants, and therefore are interested in the development ofclear, consistent and fair principles of trademark and unfair competition law.INTA has substantial expertise and has participated as amicus curiae in numerouscases involving significant trademark issues, including in this Court. 1

Cases in which INTA has filed amicus briefs include Tiffany (NJ) Inc. v.eBay, Inc., 131 S. Ct. 647 (2010) (mem.); Contessa Premium Foods, Inc. v. BerdexSeafood, Inc., 546 U.S. 957 (2005) (mem.); KP Permanent Make-Up, Inc. v.Lasting Impression I, Inc., 543 U.S. 111 (2004); Dastar Corp. v. TwentiethCentury Fox Film Corp., 539 U.S. 23 (2003); Moseley v. V Secret Catalogue, Inc.,537 U.S. 418 (2003); TrafFix Devices, Inc. v. Mktg. Displays, Inc., 532 U.S. 23(2001); Wal-Mart Stores, Inc. v. Samara Bros. Inc., 529 U.S. 205 (2000); Fla.

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4. INTA was initially founded as the United States TrademarkAssociation, in part to encourage the enactment offederal trademark legislationafter the invalidation on constitutional grounds of the United States' first trademarkact. Since that time, INTA has been instrumental in making recommendations andproviding assistance to legislators in connection with all major pieces of federaltrademark legislation, including the Lanham Act in 1946 and the FederalTrademark Dilution Act ("FTDA") in 1995, as well as international trademarklaws and treaties such as the Madrid Protocol and the Trademark Law Treaty.

Prepaid Postsecondary Educ. Expense Bd. v. College Sav. Bank, 527 U.S. 627( 1 9 9 9 ) ~ Dickinson v. Zurko, 527 U.S. 150 ( 1 9 9 9 ) ~ Qualitex Co. v. Jacobson Prods.Co., 514 U.S. 159 ( 1 9 9 5 ) ~ Two Pesos, Inc. v. Taco Cabana, Inc., 505 U.S. 763( 1 9 9 2 ) ~ K Mart Corp. v. Cartier, Inc., 486 U.S. 281 ( l 9 8 8 ) ~ Rosetta Stone Ltd. v.Google, Inc.,No. 10-2007 (4th Cir. 2 0 1 1 ) ~ Fleischer Studios, Inc. v. A. V.E.L.A.,No. 09-56317 (9 th Cir., Aug. 9, 2011) Levi Strauss & Co. v. Abercrombie & FitchTrading Co., No. 09-16322 (9th Cir. Feb. 8, 2 0 1 1 ) ~ Chloe v. Queen Bee ofBeverlyHills, LLC, 616 F.3d 158 (2d Cir. 2 0 1 0 ) ~ Penguin Group (USA) Inc. v. AmericanBuddha, 609 F.3d 30 (2d Cir. 2 0 1 0 ) ~ Starbucks Corp. v. Wolfe's Borough Coffee,Inc., 588 F.3d 97 (2d Cir. 2 0 0 9 ) ~ Louis Vuitton Malletier S.A. v. Haute DiggityDog, LLC, 507 F.3d 252 (4th Cir. 2 0 0 7 ) ~ Test Masters Educ. Servs., Inc. v. Singh,428 F.3d 559 (5th Cir. 2 0 0 5 ) ~ Playboy Enters., Inc. v. Netscape Commc'ns Corp.,354 F.3d 1020 (9th Cir. 2 0 0 4 ) ~ WarnerVision Entm't Inc. v. Empire of Carolina,Inc., 101 F.3d 259 (2d Cir. 1 9 9 6 ) ~ Preferred Risk Mut. Ins. Co. v. United States, 86F.3d 789 (8th Cir. 1 9 9 6 ) ~ Conopco, Inc. v. May Dep't Stores Co., 46 F.3d 1556(Fed. Cir. 1 9 9 4 ) ~ Ralston Purina Co. v. On-Cor Frozen Foods, Inc., 746 F.2d 801(Fed Cir. 1 9 8 4 ) ~ Anti-Monopoly, Inc. v. Gen. Mills Fun Group, Inc., 684 F.2d 1316(9th Cir. 1 9 8 2 ) ~ In re Borden, Inc., 92 F.T.C. 669 (1978), aff'd sub nom. Borden,Inc. v. Fed. Trade Comm 'n, 674 F.2d 498 (6th Cir. 1982), vacated and remanded,461 U.S. 940 (1983) ( m e m . ) ~ Redd v. Shell Oil Co., 524 F.2d 1054 (10th Cir.1 9 7 5 ) ~ Century 21 Real Estate Corp. v. Nev. Real Estate Advisory Comm 'n, 448 F.Supp. 1237 (D.Nev. 1978), aff'd, 440 U.S. 941 (1979) ( m e m . ) ~ ITC Ltd. v.Punchgini, Inc, 880 N.E.2d 852 (N.Y. 2007).

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5. INTA intends to file an amicus brief in support of vacatur and remandin order to address two legal issues: First, whether the district court erred inrejecting the presumption of validity attendant to the federal trademark registrationof Appellant Christian Louboutin ("Appellant") by incorrectly construing it as abroad "claim 'to the color red'" in general for women's designer shoes, instead ofthe much-narrower claim as defined in the registration, namely "a lacquered redsole on footwear." U.S. Trademark Reg. No.3, 361,597 (emphasis added).Second, whether the district court erred by improperly applying the muchcriticized aesthetic functionality doctrine, which has been substantially limited bymany appellate decisions such as Au-Tori1Otive Gold, Inc. v. Volkswagen ofAmerica, Inc., 457 F.3d 1062 (9th Cir. 2006).

6. INT A believes that it can provide the Court valuable insight withregard to these issues, which are of great importance to brand owners andconsumers. INT A recently addressed the issue of aesthetic functionality in theamicus brief it submitted to the United States Court of Appeals for the NinthCircuit in support of rehearing in the case of Fleischer Studios, Inc. v. A. V.E.L.A.,No. 09-56317, after which the Ninth Circuit panel issued an amended opinion on

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August 9, 2011. As an independent organization dedicated to the advancement oftrademark law, INT A is uniquely qualified to aid the Court in its determination ofthis important matter.

7. Under the expedited briefing schedule set by the Court and Rule 29(e)of the Federal Rules of Appellate Procedure, INTA's motion for leave to file anamicus brief and the proposed brief itself are currently due on October 24, 2011.

8. INTA's United States Amicus Subcommittee as a whole did not learnof this appeal until October 18,2011. Although beginning in early September2011, an INT A staff liaison had some communications with Appellant in whichAppellant indicated it might ask INT A to file an amicus brief, no request wasforthcoming. Hence, the matter was not brought to the attention of the U.S.Amicus Subcommittee. Appellant's opening brief was filed on October 17, 2011,and after reviewing the brief, INT A concluded that it might be of assistance to theCourt by filing an amicus brief addressing the issues described above. INT Aimmediately initiated its internal procedures for obtaining approval for such afiling, which it has now obtained. More time is necessary for INTA's counsel toanalyze the issues in greater depth and prepare a brief that will best aid the Court inits decision-making process.

9. My firm along with the law firm of Pirkey Barber LLP recently

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agreed to author an amicus brief in this matter on behalf of INTA. Given theamount of time my colleagues and I anticipate needing in order to familiarizeourselves and the very short time within which we have known about this appeal,we will require additional time to draft the brief and thus have submitted thisapplication to extend the ordinary deadline.

10. INTA thus respectfully requests leave to file an amicus brief, and anaccompanying motion for leave to file such brief, on or before November 14, 201 I.

11. In accordance with the schedule set by the Court, Appellees' responsebrief is not due until December 12, 2011. If this Motion were 'granted, Appelleeswould have approximately four weeks in which to prepare a response to thearguments raised in the INTA's proposed amicus brief.

12. Appellants consent to the proposed extension of the deadline.13. Appellees are willing to consent on the condition that the timefor

Appellees' brief is similarly extended by 21 days. Appellants consent to this 21-day extension for the filing of Appellees' brief.

14. Assuming the Court grants this motion to extend the deadline, INTAwill formally seek leave to file the brief on or before November 14,2011, and willappend a copy of its proposed amicus brief to its motion for leave.

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WHEREFORE, it is respectfully requested that the Court enter an orderpermitting INTA until November 14, 2011, to file an amicus curiae brief and anyaccompanying motion papers.Executed: New York, New YorkOctober 24, 2011

/ / / / JANET L. CULLUM/ f

i /,/ C,00LEY LLP114 Avenue of the Americas

New York, New York 10036Phone: (212) 479-6500

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Counsel for International TrademarkAssociation


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UNITED STATES COURT OF APPEALSFOR THE SECOND CIRCUIT- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ) (

CHRISTIAN LOUBOUTIN S.A.,CHRISTIAN LOUBOUTIN, L.L.C.,CHRISTIAN LOUBOUTIN,P laintiffs-CounterDefendants-Appellants,vs.

YVES SAINT LAURENT AMERICAHOLDINGS, INC., YVES SAINTLAURENT S.A.S., YVES SAINTLAURENT AMERICA, INC.,

Defendants-CounterClaimants-Appellees.---------------------------------- ) (

NOTICE OF ERRATANo. 11-3303-CV

On behalfof amicus The International Trademark Association, the attachedAmended Declaration in Support of the International Trademark Association'sMotion for Extension ofTime to Seek Leave and File Amicus Curiae Brief issubmitted. The INTA's Motion for Extension ofTime to Seek Leave and FileAmicus Curiae Briefwas filed earlier today, October 24,2011. The supportingDeclaration contained an incorrect date. The Declaration has accordingly beenmodified to change Paragraph 11 to reflect the correct date on which Appellee'sresponse brief is due from December 12 to December 5, and to state therefore that,if the INTA's motion of amicus were granted, Appellees would have three weeks


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in which to prepare a response to the arguments in the INTA's proposed amicusbrief.

Executed: New York, New YorkOctober 24, 2011/ ;// 'I JANET L. CULLUM

1/ II C ~ O L E Y L L P Lr114 Avenue of the AmericasNew York, New York 10036Phone: (212) 479-6500

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Counsel for International TrademarkAssociation


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UNITED STATES COURT OF APPEALSFOR THE SECOND CIRCUIT---------------------------------- XCHRISTIAN LOUBOUTIN S.A.,CHRISTIAN LOUBOUTIN, L.L.C.,CHRISTIAN LOUBOUTIN,

P laintiffs-CounterDefendants-Appellants,vs.

YVES SAINT LAURENT AMERICAHOLDINGS, INC., YVES SAINTLAURENT S.A.S., YVES SAINTLAURENT AMERICA, INC.,

Defendants-CounterClaimants-Appellees.---------------------------------- X

AMENDED DECLARATION INSUPPORT OF TH:eINTERNATIONAL TRADEMARKASSOCIATION'S MOTION FOREXTENSION OF TIME TO SEEKLEAVE AND FILE AMICUSCURIAE BRIEFNo. 11-3303-CV

JANET L. CULLUM, pursuant to Title 28, United States Code, Section1746, hereby declares under penalty of perjury:

1. I am a member of the bar of this Court and a partner at the law firmCooley LLP. My firm represents the International Trademark Association("INTA"), an organization that intends to seek leave to file an amicus curiae briefin the above-captioned matter in support of vacatur of the August 10,2011 order ofthe District Court denying the motion ofPlaintiffs-Counter-Defendants-AppellantsChristian Louboutin S.A., et al. ("Appellants") for a preliminary injunction andremand to the District Court. I respectfully submit this Declaration in support of


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INTA's motion for extension of time to seek leave and to file its proposed amicuscuriae brief beyond the ordinary amicus briefing deadline.

2. Founded in 1878, INTA is a not-for-profit organization dedicated tothe support and advancement of trademarks and related intellectual propertyconcepts as essential elements of trade and commerce. INTA has over 5,700members in more than 190 countries. Its members include trademark owners, lawfirms, and other professionals who regularly assist brand owners in the creation,protection and enforcement of their trademarks. All ofINTA's members share thegoal of promoting an understanding of the essential role trademarks play infostering informed decisions by consumers, effective commerce, and faircompetition.

3. INTA members frequently are participants in trademark litigation asboth plaintiffs and defendants, and therefore are interested in the development ofclear, consistent and fair principles of trademark and unfair competition law.INTA has substantial expertise and has participated as amicus curiae in numerouscases involving significant trademark issues, including in this Court. I

Cases in which INTA has filed amicus briefs include Tiffany (NJ) Inc. v.eBay, Inc., 131 S. Ct. 647 (2010) (mem.); Contessa Premium Foods, Inc. v. BerdexSeafood, Inc., 546 U.S. 957 (2005) (mem.); KP Permanent Make-Up, Inc. v.Lasting Impression 1, Inc., 543 U.S. 111 (2004); Dastar Corp. v. TwentiethCentury Fox Film Corp., 539 U.S. 23 (2003); Moseley v. V Secret Catalogue, Inc.,537 U.S. 418 (2003); TrajFix Devices, Inc. v. Mktg. Displays, Inc., 532 U.S. 23(2001); Wal-Mart Stores, Inc. v. Samara Bros. Inc., 529 U.S. 205 (2000); Fla.

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4. INTA was initially founded as the United States TrademarkAssociation, in part to encourage the enactment of federal trademark legislation

after the invalidation on constitutional grounds of the United States' first trademarkact. Since that time, INTA has been instrumental in making recommendations andproviding assistance to legislators in connection with all major pieces of federaltrademark legislation, including the Lanham Act in 1946 and the FederalTrademark Dilution Act ("FTDA") in 1995, as well as international trademarklaws and treaties such as the Madrid Protocol and the Trademark Law Treaty.

Prepaid Postsecondary Educ. Expense Bd. v. College Sav. Bank, 527 U.S. 627(1999); Dickinson v. Zurko, 527 U.S. 150 (1999); Qualitex Co. v. Jacobson Prods.Co., 514 U.S. 159 (1995); Two Pesos, Inc. v. Taco Cabana, Inc., 505 U.S. 763(1992); K Mart Corp. v. Cartier, Inc., 486 U.S. 281 (1988); Rosetta Stone Ltd. v.Google, Inc.,No. 10-2007 (4th Cir. 2011); Fleischer Studios, Inc. v. A. V.E.L.A.,No. 09-56317 (9th Cir., Aug. 9, 2011) Levi Strauss & Co. v. Abercrombie & FitchTrading Co., No. 09-16322 (9th Cir. Feb. 8,2011); Chloe v. Queen Bee o/BeverlyHills, LLC, 616 F .3d 158 (2d Cir. 2010); Penguin Group (USA) Inc. v. AmericanBuddha, 609 F.3d 30 (2d Cir. 2010); Starbucks Corp. v. Wolfe's Borough Coffee,Inc., 588 F.3d 97 (2d Cir. 2009); Louis Vuitton Malletier S.A. v. Haute DiggityDog, LLC, 507 F.3d 252 (4th Cir. 2007); Test Masters Educ. Servs., Inc. v. Singh,428 F.3d 559 (5th Cir. 2005); Playboy Enters., Inc. v. Netscape Commc 'ns Corp.,354 F.3d 1020 (9th Cir. 2004); WarnerVision Entm 't Inc. v. Empire o/Carolina,Inc., 101 F.3d 259 (2d Cir. 1996); Pre/erred Risk Mut. Ins. Co. v. United States, 86F.3d 789 (8th Cir. 1996); Conopco, Inc. v. May Dep 't Stores Co., 46 F.3d 1556(Fed. Cir. 1994); Ralston Purina Co. v. On-Cor Frozen Foods, Inc., 746 F.2d 801(Fed Cir. 1984); Anti-Monopoly, Inc. v. Gen. Mills Fun Group, Inc., 684 F.2d 1316(9th Cir. 1982); In re Borden, Inc., 92 F.T.C. 669 (1978), aff'd sub nom. Borden,Inc. v. Fed. Trade Comm 'n, 674 F.2d 498 (6th Cir. 1982), vacated and remanded,461 U.S. 940 (1983) (mem.); Redd v. Shell Oil Co., 524 F.2d 1054 (10th Cir.1975); Century 21 Real Estate Corp. v. Nev. Real Estate Advisory Comm 'n, 448 F.Supp. 1237 (D.Nev. 1978), aff'd, 440 U.S. 941 (1979) (mem.); ITC Ltd. v.Punchgini, Inc, 880 N.E.2d 852 (N.Y. 2007).

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5. INTA intends to file an amicus brief in support ofvacatur and remandin order to address two legal issues: First, whether the district court erred in

rejecting the presumption ofvalidity attendant to the federal trademark registrationofAppellant Christian Louboutin ("Appellant") by incorrectly construing it as abroad "claim 'to the color red'" in general for women's designer shoes, instead ofthe much-narrower claim as defined in the registration, namely "a lacquered redsole on footwear." U.S. Trademark Reg. No.3, 361,597 (emphasis added).Second, whether the district court erred by improperly applying the muchcriticized aesthetic functionality doctrine, which has been substantially limited bymany appellate decisions such as Au-Tomotive Gold, Inc. v. Volkswagen ofAmerica, Inc., 457 F.3d 1062 (9th Cir. 2006).

6. INTA believes that it can provide the Court valuable insight withregard to these issues, which are of great importance to brand owners andconsumers. INT A recently addressed the issue of aesthetic functionality in theamicus brief it submitted to the United States Court ofAppeals for the NinthCircuit in support of rehearing in the case ofFleischer Studios, Inc. v. A. VE.L.A.,No. 09-56317, after which the Ninth Circuit panel issued an amended opinion on

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August 9, 2011. As an independent organization dedicated to the advancement oftrademark law, INT A is uniquely qualified to aid the Court in its determination of

this important matter.7. Under the expedited briefing schedule set by the Court and Rule 29( e)

of the Federal Rules ofAppellate Procedure, INTA's motion for leave to file anamicus brief and the proposed brief itself are currently due on October 24, 2011.

8. INTA's United States Amicus Subcommittee as a whole did not learnof this appeal until October 18, 2011. Although beginning in early September2011, an INTA staff liaison had some communications with Appellant in whichAppellant indicated it might ask INT A to file an amicus brief, no request wasforthcoming. Hence, the matter was not brought to the attention of the U.S.Amicus Subcommittee. Appellant's opening brief was filed on October 17, 2011,and after reviewing the brief, INTA concluded that it might be of assistance to theCourt by filing an amicus brief addressing the issues described above. INT Aimmediately initiated its internal procedures for obtaining approval for such afiling, which it has now obtained. More time is necessary for INTA's counsel toanalyze the issues in greater depth and prepare a brief that will best aid the Court inits decision-making process.

9. My firm along with the law firm ofPirkey Barber LLP recently

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agreed to author an amicus brief in this matter on behalf of INTA. Given theamount of time my colleagues and I anticipate needing in order to familiarize

ourselves and the very short time within which we have known about this appeal,we will require additional time to draft the brief and thus have submitted thisapplication to extend the ordinary deadline.

10. INTA thus respectfully requests leave to file an amicus brief, and an. accompanying motion for leave to file such brief, on or before November 14,2011.

11. In accordance with the schedule set by the Court, Appellees' responsebrief is not due until December 5,2011. If this Motion were granted, Appelleeswould have approximately three weeks in which to prepare a response to thearguments raised in the INTA's proposed amicus brief.

12. Appellants consent to the proposed extension of the deadline.13. Appellees are willing to consent on the condition that the time for

Appellees' brief is similarly extended by 21 days. Appellants consent to this 21-day extension for the filing ofAppellees' brief.

14. Assuming the Court grants this motion to extend the deadline, INTAwill formally seek leave to file the brief on or before November 14,2011, and willappend a copy of its proposed amicus brief to its motion for leave.

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WHEREFORE, it is respectfully requested that the Court enter an orderpermitting INTA until November 14,2011, to file an amicus curiae brief and any

accompanying motion papers.Executed: New York, New YorkOctober 24, 2011

:' COLEYLLP\ " - ~ l i 14 Avenue of the AmericasNew York, New York 10036

Phone: (212) 479-6500Counsel for International TrademarkAssociation


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INTA Amicus Request - Louboutin v Yves Saint Lauren

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