Trademark Tensions on the Track: Court Upholds First Amendment Protections in Haas v. Steiner

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The intersection of trademark law and creative expression continues to evolve, most recently in Haas Automation, Inc. v. Guenther Steiner and Ten Speed Press, 2024 WL 4440914 (C.D. Cal. September 25, 2024). Haas provides fresh insight into how courts analyze trademark claims involving biographical works and sports photography. The court dismissed Haas Automation’s lawsuit, which alleged that Steiner’s book “Surviving to Drive,” infringed on the company’s trademarks associated with the Haas F1 racing team. In line with the Supreme Court’s decision in Jack Daniel’s Properties, Inc. v. VIP Products LLC, Haas underscores that trademark rights may be curtailed where expressive content is not misleading about its source.

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