Trader Joe’s Company v. Trader Joe’s United
15/01/2026
Trader Joe’s Company ("Trader Joe’s") is a national grocery chain that has used its distinctive "TRADER JOE’S" name and trademarks since 1967. Trader Joe’s alleges that Trader Joe’s United ("TJU"), a labor union representing some of its employees, sells merchandise such as apparel, mugs, buttons, and tote bags that infringe upon its federally registered trademarks. These items allegedly use the "Trader Joe’s" mark, including distinctive red coloring, capitalized lettering, and similar font style, leading to potential consumer confusion and dilution of the trademarks.
Trader Joe’s filed a lawsuit under the Lanham Act, seeking injunctive relief and damages. The district court dismissed the complaint with prejudice, ruling that there was no plausible likelihood of confusion and that the Norris-LaGuardia Act barred injunctive relief in this labor dispute context. The court also awarded attorneys’ fees to TJU, finding the lawsuit to be frivolous.
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Trademark Infringement: Whether TJU's use of the "Trader Joe’s" mark on merchandise is likely to cause consumer confusion under the Lanham Act.
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Trademark Dilution: Whether TJU's use of the "Trader Joe’s" mark dilutes its distinctiveness.
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Injunctive Relief: Whether the Norris-LaGuardia Act prohibits the issuance of an injunction in this case.
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Trademark Infringement: The Ninth Circuit reversed the district court's dismissal of the trademark infringement claim. The court held that, viewing the allegations in the light most favorable to Trader Joe’s, the district court erred in applying the likelihood-of-confusion test. The court concluded that factors such as the strength of the marks, the relatedness of the parties’ goods, and the similarity of the marks weighed in favor of Trader Joe’s, indicating a plausible likelihood of confusion.
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Trademark Dilution: The court reversed the dismissal of the dilution claim, finding that the district court erred in dismissing it under the nominative fair use doctrine without providing Trader Joe’s an opportunity to respond or applying the requisite three-factor test.
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Injunctive Relief: The court held that the district court prematurely concluded that the Norris-LaGuardia Act barred it from granting injunctive relief without further development of the record or the parties’ positions.
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Attorneys’ Fees: The court vacated the award of attorneys’ fees to TJU, finding that the district court erred in granting them.
The Ninth Circuit reversed the district court's dismissal of Trader Joe’s trademark infringement and dilution claims, vacated the award of attorneys’ fees to TJU, and remanded the case for further proceedings. The court emphasized the importance of allowing Trader Joe’s an opportunity to present its case and for the district court to properly apply the legal standards in evaluating the claims.
Nandini Kohli