## Facts

- Perfect Fit Industries manufactured mattress pads and covers and introduced a successful mattress cover product marketed as “BedSack.”
- The dispute concerned the packaging trade dress for BedSack, specifically a printed cardboard “J-board” that folded over the end of the packaged product and remained visible to consumers on shelves.
- The district court found Perfect Fit’s J-board trade dress “distinctive and memorable.”
- Acme Quilting, a competitor, marketed a comparable mattress cover (“BedMate”) and intentionally designed J-boards that the district court found “very similar” to Perfect Fit’s and “deliberately copied” from it.
- Perfect Fit sued in the Southern District of New York asserting New York unfair competition (trade dress) and Lanham Act § 43(a) claims.
- After an initial defense judgment based on lack of secondary meaning, an earlier appeal held that secondary meaning was not required for the New York trade-dress claim in the circumstances, and the case was remanded.
- On remand, the district court entered a decree enjoining Acme from misappropriating Perfect Fit’s trade dress, barring use of the infringing J-board, and regulating Acme’s revised packaging.
- After Acme again changed its packaging, the district court held Acme in contempt of the decree and imposed a fine.
- Acme appealed both portions of the decree and the contempt order and fine.

## Issues

1. Whether the district court abused its discretion in crafting an injunction that barred misappropriation of Perfect Fit’s trade dress and regulated Acme’s revised J-boards.
2. Whether the district court properly held Acme in contempt for later packaging that allegedly violated the decree.
3. Whether the contempt fine was properly imposed and adequately explained.

## Decision

- The Second Circuit affirmed the challenged portions of the injunctive decree as within the district court’s discretion.
- The Second Circuit affirmed the contempt adjudication insofar as it found Acme’s later J-board violated the decree.
- The Second Circuit remanded for the district court to explain the basis and purpose of the contempt fine.

## Legal Principles

- Under New York unfair-competition law, deliberate copying of trade dress supporting likely consumer confusion can warrant relief without a showing of secondary meaning (as established earlier in the litigation and applied to the remedy).
- District courts have broad equitable discretion to frame trade-dress injunctions that prevent continued misappropriation and address likely confusing variations, reviewed for abuse of discretion.
- A party may be held in contempt for failing to comply with the letter and spirit of an injunction.
- Contempt fines must be supported by a stated rationale identifying their function (e.g., compensatory or coercive) and explaining the basis for the amount imposed.

## Conclusion

The court upheld broad injunctive relief and enforcement through contempt to prevent continued trade-dress misappropriation, but required a clearer explanation of the monetary sanction to ensure the fine’s purpose and calculation were legally justified.


Perfect Fit Indus., Inc. v. Acme Quilting Co., 646 F.2d 800 (2d Cir. 1981)