CEALS Affiliated Scholar David Makman Prevails in Trademark Infringement Case Decided by Ninth Circuit Court of Appeals 

Congratulations to Center for East Asian Legal Studies Affiliated Scholar David Makman (Law Offices of David A. Makman) for his recent victory in a trademark infringement case decided by the U.S. Court of Appeals for the Ninth Circuit. The Ninth Circuit panel affirmed a district court’s conclusion that advertising and selling equity is not connected to a sale of goods or services, and so cannot constitute trademark infringement. It also affirmed the district court’s conclusion that the plaintiff, LegalForce USA, failed to justify an extraterritorial application of the Lanham Act because LegalForce Japan’s services in Japan could not satisfy the “in connection with” goods or services requirement under the Lanham Act. Professor Makman will offer a survey course on the Japanese legal system at UC Law in Fall 2025.