Richards v. Cable News Network

Citation: Richards v. Cable News Network, Inc., 15 F.Supp.2d 683 (E.D. Pa. 1998).

Factual Background
Plaintiff owned the registered mark WORLD BEAT for a record label that sold prerecorded reggae-style tapes, records, and CDs. Defendant CNN operated a cable-television show entitled “World Beat,” which covered music news from around the world. CNN also maintained a “World Beat” section on its “cnn.com” website, which provided music information similar to the television show.

Trial Court Proceedings
Plaintiff sought to preliminarily enjoin CNN’s use of the WORLD BEAT name, alleging trademark infringement and unfair competition. The court held that defendant’s use of the name posed no likelihood of confusion to plaintiff’s use, and that the term “world beat” had become generic for a certain genre of music. It noted CNN’s “triple entendre” use of the term, to refer to the genre of “world music,” to suggest the journalistic “beat” covering international music news, and to act as “a metaphor for the musical heartbeat of the globe.”

Recognizing the possibility of many nontrademark meanings for the term “world beat,” the court held that although plaintiff continued to hold trademark rights in the term WORLD BEAT for prerecorded reggae music, he could not preclude CNN’s use of the term in its generic sense in connection with its television show or website. The court thus denied the motion for preliminary injunction.

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