• Victoria's Secret Must Prove "Actual Dilution," But How?
  • June 17, 2003 | Author: Susan M. Robiner
  • Law Firm: Leonard, Street and Deinard, Professional Association - Minneapolis Office
  • In a ruling (Moseley v. V. Secret Catalog, Inc.) on March 4, 2003, the United States Supreme Court held that holders of a famous trademark must show "actual dilution" of the mark in order to establish a violation of the 1995 Federal Anti-Dilution Act. In so doing, the high court settled a dispute among the circuit courts but gave little guidance on the dilution theory.