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Yankee Candle Co., Inc. v. Bridgewater Candle Co., LLC

Trial court properly dissected copyright-protected elements of candle labels from unprotected elements and determined that copyrights in labels with photographic images identifying candle fragrances were not infringed by similar candle labels; plaintiff failed to establish that combination of its labels, product design, advertising campaign, and marketing techniques created secondary meaning that would constitute protected "trade dress."

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APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS [Hon. Michael A. Ponsor, U.S. District Judge]

Yankee Candle Company (“Yankee”), a leading manufacturer of scented candles, sued competitor Bridgewater Candle Company (“Bridgewater”) on counts of copyright infringement and trade dress infringement under federal law, as well as on state claims of common law trade dress infringement, tortious interference, and deceptive trade practices under Mass. Gen. Laws ch. 93A. The district court granted summary judgment to Bridgewater on all claims except those of tortious interference and violation of 93A. Yankee Candle Co. v. Bridgewater Candle Co., 99 F. Supp. 2d 140 (D. Mass. 2000) [hereinafter Yankee I]. In a later memorandum, the district court determined that Yankee’s evidentiary support for its federal copyright and trade dress claims was irrelevant with respect to the state claim for tortious interference, and substantially limited Yankee’s ability to introduce such evidence. Yankee Candle Co. v. Bridgewater Candle Co., 107 F. Supp. 2d 82, 86-87 (D. Mass. 2000) (memorandum) [hereinafter Yankee II]. The court also concluded that the alleged actionable behavior was not committed “primarily and substantially” in Massachusetts, and granted Bridgewater summary judgment on Yankee’s 93A claim. Id. at 88-89. Yankee then stipulated as to the voluntary dismissal of its tortious interference claim so that it could appeal.

On appeal, Yankee challenges: (i) the grant of summary judgment on its copyright claims; (ii) the grant of summary judgment on its federal trade dress claims; (iii) the district court’s decision to narrow the scope of trial and severely limit allowable evidence; and (iv) the grant of summary judgment on the 93A claim. For the reasons explained herein, we affirm the opinions of the district court.

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