Curtin v. United Trademark Holdings, Inc.

Consumers cannot oppose trademarks just for being generic—only commercial harm counts

Summary :

Rebecca Curtin, a law professor and doll collector, opposed the trademark registration of “Rapunzel” for dolls by United Trademark Holdings. She claimed the word was generic and should be available to everyone. However, the court ruled that since she was just a consumer and not a competitor, she had no legal standing to oppose the registration.

Facts :

- Rebecca Curtin filed an opposition against United Trademark Holdings' attempt to register “Rapunzel” as a trademark for dolls.

- She argued that “Rapunzel” is a common fairy tale name and not a brand, so it shouldn’t be registered.

- She feared that allowing the trademark would reduce competition and creativity in doll making.

Findings :

- The court applied the Lexmark test (zone of interest + direct harm).

- The court found that Curtin, as a consumer, does not meet the “zone of interest” required under the trademark law.

- Her claims about harm (higher prices, less competition) were too indirect and speculative.

Suggestion :

- Only those with a commercial stake—such as competitors or businesses—can legally oppose trademarks based on claims like genericness or descriptiveness.

- Consumers without business interests don’t have the legal standing to file such oppositions.

Judgment :

The Federal Circuit dismissed the case on May 22, 2025, ruling that Rebecca Curtin lacked standing to oppose the trademark. The name “Rapunzel” remained registered under United Trademark Holdings.