The United States Court of Appeals for the Second Circuit ruled recently that the United States Polo Association (USPA) cannot use its “Double Horsemen” logo on men’s fragrances, affirming the district court’s finding of trademark infringement and entry of a permanent injunction in favor of PRL USA Holdings, Inc. (PRL). PRL is the owner and licensor of Polo Ralph Lauren Corporation’s trademarks, including the POLO and Polo Player Logo marks, registered in connection with fragrances. The USPA, the governing body for the sport of polo in the United States, and Ralph Lauren have been at odds over USPA’s use of a mounted polo player design mark, including its Double Horsemen logo, for nearly 30 years.
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