Case Explained: 26a0192p.06

Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-07

The sixth-circuit affirmed the district court’s grant of summary judgment in favor of MillerKnoll, Inc., dismissing all claims brought by the Nelson family for trademark infringement under the Lanham Act (15 U.S.C. § 1125(a)), state common law trademark infringement, fraud, conspiracy to commit fraud, unjust enrichment, and cancellation of trademark registrations. The court held that the plaintiffs’ claims failed because they had authorized MillerKnoll’s use and ownership of the “Bubble Lamp” intellectual property through a series of contractual agreements: the 2006 Royalty Agreement and its 2015 Addendum. Applying Michigan contract law, the court interpreted these documents as unambiguously granting MillerKnoll exclusive rights, title, and interest in the Nelson-designed products covered by the agreements, including the Bubble Lamp designs and associated trademarks. The court reasoned that authorization or consent to a defendant’s conduct defeats claims for both federal and state trademark infringement, as well as related tort claims like fraud and unjust enrichment, because a plaintiff cannot sustain a claim based on conduct they permitted. Additionally, the court found an alternative basis for affirmance in the doctrine of ratification. The court determined that Mico Nelson ratified MillerKnoll’s ownership and use of the intellectual property by continuing to accept royalty payments from the company after he had actual knowledge of MillerKnoll’s asserted ownership rights. Regarding the request to cancel trademark registrations, the court held that the plaintiffs failed to present clear and convincing evidence of fraud on the United States Patent and Trademark Office, noting that their expert testimony regarding false statements was conclusory and insufficient to create a genuine issue of material fact. As a practical consequence, the judgment in favor of MillerKnoll stands final; the company retains ownership and the right to use the Bubble Lamp intellectual property, and all pending claims by the Nelson family are dismissed without further litigation or damages.

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