Amicus Brief

Victor Moseley and Cathy Moseley d/b/a Victor’s Little Secret v. V Secret Catalogue, Inc.

Published: January 1, 2002


U.S. Supreme Court

Our Position

The U.S. Federal Trademark Dilution Act requires the owner of a famous trademark to show a likelihood of dilution to obtain an injunction.


The Court ruled that the Federal Trademark Dilution Act requires proof of actual dilution rather than mere likelihood of dilution. After an INTA-led campaign in response to this ruling, the Trademark Dilution Revision Act of 2006 was passed, which, among other things, established an express likelihood of dilution standard.