A DJ asserting trademark infringement and dilution claims against a similarly named rapper failed partly due to a lack of apparent popularity on social media, the U.S. Court of Appeals for the Sixth Circuit ruled on December 13. In Kibler v. Hall, et al., No. 15-2516 (6th Cir. Dec. 13, 2016), the appellate court affirmed summary judgment granted below for Hall, a rapper performing as “Logic” in a suit brought by Kibler, who performs as “DJ Logic.” While the Sixth Circuit agreed with the district court’s rejection of DJ Logic’s claims, it called the district court’s analysis “incomplete and at times flawed,” and pointed out the importance of social media engagements in determining trademark strength.
In 2012, an attorney for DJ Logic, who has been using the moniker since 1999, sent an email to the management company and booking agent of Hall, who has been performing as Logic since 2009, ordering them to stop using the name Logic. The email did not prove persuasive and DJ Logic sued in 2014, asserting claims of trademark infringement and trademark dilution under the Lanham Act, as well as two claims under Michigan law. The district court granted summary judgment in November 2015, dismissing all of DJ Logic’s claims.
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