Abitron Austria GmbH v. Hetronic Int’l, Inc.
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Abitron Austria GmbH v. Hetronic Int’l, Inc. and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Abitron Austria GmbH v. Hetronic Int’l, Inc..
The Supreme Court addressed the foreign reach of the Lanham Act's provisions on trademark infringement in the case between Hetronic and Abitron. The Court concluded that the Lanham Act does not apply extraterritorially and is limited to domestic claims. The decision vacated and remanded the Tenth Circuit's ruling, which had extended the Act to foreign conduct.
Holding
The single most important “bottom line” of what the Court decided in Abitron Austria GmbH v. Hetronic Int’l, Inc..
The Court held that the Lanham Act's provisions are not extraterritorial and apply only to domestic claims.
Constitutional Concepts
These are the Constitution-related themes that appear in Abitron Austria GmbH v. Hetronic Int’l, Inc.. Click a concept to see other cases that involve the same idea.
-
Why Commerce Clause is relevant to Abitron Austria GmbH v. Hetronic Int’l, Inc.
The case involves the application of the Lanham Act, which is based on Congress's power to regulate commerce. The Court's decision hinges on whether the Act applies extraterritorially, which directly relates to the scope of Congress's power under the Commerce Clause.
Syllabus excerpt (verbatim)Hetronic maintains that the Lanham Act's defnition of 'commerce'—'all commerce which may lawfully be regulated by Congress,' § 1127—rebuts the presumption against extraterritoriality.
-
Why Judicial Review is relevant to Abitron Austria GmbH v. Hetronic Int’l, Inc.
The Court exercises its power of judicial review to interpret the scope of the Lanham Act and determine its extraterritorial reach.
Syllabus excerpt (verbatim)Held: Applying the presumption against extraterritoriality, § 1114(1)(a) and § 1125(a)(1) of the Lanham Act are not extraterritorial and extend only to claims where the infringing use in commerce is domestic.
-
Why State–Federal Power is relevant to Abitron Austria GmbH v. Hetronic Int’l, Inc.
The decision involves the allocation of authority between federal and foreign jurisdictions, as it determines the territorial limits of federal law.
Syllabus excerpt (verbatim)The presumption 'serves to avoid the international discord that can result when U. S. law is applied to conduct in foreign countries.'
Key Quotes
Short excerpts from the syllabus in Abitron Austria GmbH v. Hetronic Int’l, Inc. that support the summary and concepts above.
Applying the presumption against extraterritoriality, § 1114(1)(a) and § 1125(a)(1) of the Lanham Act are not extraterritorial.
The presumption against extraterritoriality reflects the longstanding principle 'that legislation of Congress, unless a contrary intent appears, is meant to apply only within the territorial jurisdiction of the United States.'
The proceedings below were not in accord with this understanding of extraterritoriality.
