2nd Circ. Revives TM Suit Over 'Black Ice' Air Fresheners

Law360 (November 19, 2020, 9:50 PM EST) -- The Second Circuit on Thursday partially revived a suit over "Black Ice" automotive air fresheners, ruling that a New York federal court wrongly decided the company behind Little Tree products hadn't offered enough evidence supporting its claims that Energizer's "Midnight Black Ice Storm" products infringe its trademark.

Car-Freshner Corp. had sued Energizer Holdings Inc. in 2017, alleging infringement of the "Black Ice" trademark, as well as infringement of its "Bayside Breeze" trademark through Energizer's "Boardwalk Breeze" products, according to the suit.

In August 2019, a New York federal court granted Energizer's motion for summary judgment, ruling that Car-Freshner Corp. hadn't submitted enough...

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