Supreme Court: Non-Competitors May Have Standing for False Advertising Claim

摘要

The U.S. Supreme Court affirms a ruling by the Sixth Circuit that a maker of parts to be used to make replacement toner cartridges for a laser printer has standing to bring a false advertising claim against the printer manufacturer even though the parties do not compete directly in the same market for goods. After applying the "zone-of-interests" test and looking for proximate cause, the court finds that the parts manufacturer falls within the class of parties authorized to bring claims under the Lanham Act's false advertising provisions.