Case: Trademarks/Injunctions (2d Cir.)

The Second Circuit affirmed a federal district court in New York’s denial of an individual’s motion for preliminary injunctions in this trademark infringement action against Tidal Growth Consultants related to the “South Asian Film Festival,” “South Asian International Film Festival,” “SAIFF,” and “SAFF” marks. According to the appeals court, the individual was unlikely to succeed on the merits because the evidence suggested that the “South Asian Film Festival” and “SAFF” marks weren’t primarily associated with the individual in the public mind, and the complaint didn’t allege facts demonstrating that Tidal Growth used the “South Asian International Film Festival” and “SAIFF” ...