Rebecca Curtin v. United Trademark Holdings (Fed. Cir., May 22, 2025) 2023-2140

This is an opinion from the Federal Circuit addressing whether a consumer, Rebecca Curtin, had the legal right, or statutory standing, to oppose a trademark registration for "RAPUNZEL" covering dolls and toy figures. The case explores the requirements for bringing an opposition under 15 U.S.C. § 1063 of the Lanham Act, particularly focusing on whether a consumer's interests fall within the "zone of interests" protected by the statute and if their alleged harm is proximately caused by the registration, applying the framework established in the Supreme Court's Lexmark decision. Ultimately, the court affirmed the Trademark Trial and Appeal Board's decision that Ms. Curtin, as a mere consumer, lacked the necessary commercial interest and demonstrated only too remote and speculative harm to have standing for this type of opposition.

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