Lexmark International v. Static Control Components (2013)
- Docket
- 12-873
- Decided
- 2013-01-01
Summary
Question: Is the test to establish standing for a false advertising claim the same as the test to establish standing under antitrust statutes? Conclusion: No. Justice Antonin Scalia delivered the opinion for the unanimous Court. The Court held that the Lanham Act allowed any party to sue that had been injured by false advertising. However, because that language is so broad, the Court held that a determination of standing to sue should be based on proof that the plaintiffs' interests fall within the zone of interests protected by the law and that a violation of the statute was the proximate cause of the injury in question. In order to prove that the plaintiffs' interest fall within the zone of interest the Lanham Act protects, the plaintiffs must prove that they have a commercial interest in reputation or sales. To prove that the injury in question was caused by a violation of the statute, the plaintiff must show that that economic or reputational injury stemmed directly from the defendant's false advertising. The Court also held that the "reasonable interest" test the U.S. Court of Appeals for the Sixth Circuit applied was not feasible because it was too vague. In this case, Static Control Component's claim satisfied both the zone of interest and proximate cause requirements to pursue a claim under the Lanham Act.