## Facts

- Mabs, Inc. owned U.S. Patent No. 2,905,945 covering a “snap-tab” shirt collar construction using inelastic tabs and snap fasteners to hold collar wings in a set position.
- Mabs granted Snap-Tab Corporation the rights to make, use, and sell collar constructions under the patent; Leslie Riverview Realty Corp. owned a one-half interest in Snap-Tab.
- Piedmont Shirt Company manufactured and sold shirts with collars using a snap-tab-type configuration.
- Plaintiffs sued for (1) patent infringement, (2) infringement of the registered mark “SNAP-TAB,” and (3) unfair competition.
- Piedmont denied liability and counterclaimed for declaratory relief, including patent invalidity and non-infringement, invalidity and cancellation of the “SNAP-TAB” registration as generic/descriptive, and related relief.
- The district court allowed Snap-Tab and Leslie Riverview to be added as plaintiffs, then tried the case on the merits.
- On appeal, the Fourth Circuit affirmed per curiam.

## Issues

1. Whether the snap-tab collar patent was invalid in view of prior art and the use of known elements in collar construction.
2. If valid, whether Piedmont’s collar construction infringed the patent claims as properly construed.
3. Whether “SNAP-TAB” was a valid trademark or instead generic/descriptive for a collar feature, and whether the registration should be cancelled.
4. Whether Piedmont’s marketing and sale of its shirts constituted unfair competition (including likelihood of confusion or passing off).

## Decision

- The patent was held invalid for lack of patentable invention over the prior art.
- Alternatively, assuming validity, Piedmont’s products were held not to infringe under a narrow construction of the claims.
- The “SNAP-TAB” trademark registration was held invalid as generic/descriptive and ordered cancelled.
- Plaintiffs failed to prove unfair competition; Piedmont’s goods were identified with its own trademarks and not shown to cause actionable confusion.
- The Fourth Circuit affirmed the judgment on both patent invalidity and non-infringement, and upheld the remainder of the disposition.

## Legal Principles

- A claimed invention that combines known elements from the prior art, without a non-obvious functional result beyond the expected operation of those elements, is not patentable.
- In a field crowded with prior art, patent claims are construed narrowly to avoid covering known structures; an accused product outside the claim’s specific structural relationships does not infringe.
- A term that describes a product feature or names a type of product (generic/descriptive) is not protectable as a trademark absent enforceable distinctiveness; a registration for such a term may be cancelled.
- Absent deception, passing off, or likely source confusion—especially where the defendant clearly marks goods with its own identifiers—copying a functional or generic product feature does not establish unfair competition.

## Conclusion

The court entered judgment for Piedmont, holding the snap-tab collar patent invalid and, in any event, not infringed; it also cancelled the “SNAP-TAB” registration as generic/descriptive and rejected the unfair competition claim, with the Fourth Circuit affirming.


Mabs, Inc. v. Piedmont Shirt Co., 248 F. Supp. 71 (D.S.C. 1965)