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Quality Inns International, Inc. v. Patel
Citations: 622 F. Supp. 826; 228 U.S.P.Q. (BNA) 700; 1985 U.S. Dist. LEXIS 13596Docket: Civ A. J85-0930(L)
Court: District Court, S.D. Mississippi; November 22, 1985; Federal District Court
Quality Inns International, Inc. filed a motion for a preliminary injunction against Ron Patel and Jay Patel, operators of The Comfort Lodge, to prevent them from using the name "Comfort Lodge" and a similar logo, citing potential trademark infringement under the Trademark Act of 1946. Quality Inns owns the "Comfort Inn" trademark used by 187 hotels across North America, including six in Mississippi. The defendants acquired an establishment previously known as "Econo-Lodge" and modified the signage to "Comfort Lodge." Evidence revealed that Ron Patel sought a logo resembling that of Comfort Inn, although the sign's designer claimed it was not based on the Comfort Inn logo. Prior to the new sign's installation, the defendants used both "Comfort Lodge" and "The Lodge." A complaint from a youth baseball team, who mistakenly associated their accommodations with Quality Inns, further prompted Quality Inns to request that the defendants cease using the "Comfort Lodge" name. The new sign was installed on September 12, 1985, shortly before Quality Inns initiated legal action. The case references 15 U.S.C. § 1114, which prohibits unauthorized use of a registered trademark that is likely to cause confusion. The Fifth Circuit outlines several factors for assessing the likelihood of confusion in trademark cases: the type of trademark, degree of similarity between marks, similarity of products, identity of retail outlets and purchasers, identity of advertising media, defendants' intent, and actual confusion. Stronger trademarks receive greater protection, and while evidence of the strength of the plaintiff's marks was lacking, the plaintiff operates numerous hotels using these marks. The similarity between the two marks is pronounced, with both featuring striped orb designs in similar colors and common first words in their names, which could lead to consumer confusion. The services offered by both parties—motel accommodations—target the same consumer base. They also share the use of signs for advertising, although no specific evidence was presented regarding the advertising media. Actual confusion was demonstrated through complaints from patrons believing they were at a Comfort Inn and confusion among suppliers and callers. The court concludes that the plaintiff has shown a substantial likelihood of success on its claims and will suffer irreparable harm to its reputation if a preliminary injunction is not granted. The potential harm to the defendants from discontinuing use of the name and design is significant but does not outweigh the plaintiff's potential damage. Therefore, the court grants the plaintiff's motion for a preliminary injunction, requiring the defendants to report compliance within 30 days. Notably, the plaintiff's trademarks are registered and have been in use since April 2, 1981.