## Facts

- Lexmark manufactured laser printers and toner cartridges and sold discounted “Prebate/Return Program” cartridges conditioned on a single-use and return requirement.
- Lexmark’s cartridges contained a microchip that disabled the cartridge when toner ran out, requiring a replacement chip to reuse the cartridge.
- Static Control made and sold components, including microchips, used by independent remanufacturers to refurbish and resell Lexmark cartridges; Static Control did not sell finished cartridges.
- Static Control developed a replacement microchip that allowed remanufacturers to reuse Lexmark’s discounted cartridges.
- Lexmark communicated to end users that the discounted cartridges were subject to a single-use/return restriction and to remanufacturers that using Static Control’s products to remanufacture Lexmark cartridges was “illegal” and that Static Control was engaged in illegal conduct.
- Static Control alleged the statements were false or misleading, harmed its business reputation, and reduced its component sales by discouraging remanufacturers from purchasing from Static Control.
- Lexmark sued Static Control on other theories; Static Control counterclaimed for false advertising under Lanham Act § 43(a), 15 U.S.C. § 1125(a).

## Issues

1. What standard governs who may sue for false advertising under Lanham Act § 1125(a).
2. Whether a plaintiff that is not a direct competitor may sue when it alleges lost sales and reputational harm from the defendant’s misrepresentations.
3. Whether Static Control adequately alleged that its asserted injuries were proximately caused by Lexmark’s alleged false advertising.

## Decision

- The Supreme Court unanimously affirmed the judgment allowing Static Control’s Lanham Act false-advertising claim to proceed.
- The Court held the “who may sue” question is one of statutory cause of action, not free-floating “prudential standing.”
- The Court adopted a two-part inquiry for § 1125(a) false-advertising suits: (1) the plaintiff’s injury must fall within the statute’s zone of interests, and (2) the injury must be proximately caused by the defendant’s statutory violation.
- Static Control plausibly alleged injuries to commercial reputation and sales within the Lanham Act’s zone of interests and plausibly alleged proximate causation because Lexmark’s statements allegedly directly deterred remanufacturers from buying Static Control’s products.

## Legal Principles

- Whether a plaintiff may sue under a federal statute is determined by statutory interpretation of the scope of the cause of action, not by labeling the inquiry “prudential standing.”
- For Lanham Act § 1125(a) false advertising, the zone of interests covers injuries to a commercial interest in reputation or sales; consumer deception alone, without such commercial injury, is insufficient.
- A direct-competitor requirement is not part of § 1125(a); non-competitors may sue if they meet the zone-of-interests and proximate-cause requirements.
- A plaintiff must plausibly allege proximate causation: an economic or reputational injury that flows directly from the deception and results in withheld trade, with a sufficiently direct relationship between the misrepresentation and the harm.
- Multi-factor balancing tests (including antitrust-style approaches) and indeterminate “reasonable interest” formulations are improper substitutes for the zone-of-interests and proximate-cause analysis grounded in the statute.

## Conclusion

The Court standardized Lanham Act false-advertising plaintiff eligibility by requiring allegations of commercial injury to reputation or sales within the statute’s zone of interests and a proximate causal link between the misrepresentation and that injury, permitting suit even by plaintiffs who are not direct competitors.


Lexmark Int’l, Inc. v. Static Control Components, Inc., 572 U.S. 118 (2014)