## Facts

- The United States Golf Association (USGA) developed and maintained an amateur golf handicap system whose core was a mathematical formula for computing handicaps from golfers’ scores.
- Data-Max, Inc., doing business as St. Andrews Systems, marketed small computers programmed to calculate golfers’ handicaps using the same formula, advertising calculations “based on the U.S.G.A. formula.”
- USGA sued seeking an injunction to stop Data-Max from using the formula in its devices.
- USGA did not assert patent or copyright rights in the formula; it relied on (1) Lanham Act § 43(a) false designation of origin and parallel New Jersey unfair-competition theories, and (2) New Jersey misappropriation theory derived from *International News Service v. Associated Press*.
- The district court granted partial summary judgment to Data-Max, concluding USGA had no cognizable interest in the formula that could support an injunction, and entered final judgment on those claims under Rule 54(b).
- USGA appealed.

## Issues

1. Whether Lanham Act § 43(a) and New Jersey unfair-competition law can be used to enjoin a competitor’s use of a functional mathematical formula central to a product’s operation.
2. Whether New Jersey’s INS-type misappropriation doctrine permits an injunction against a competitor’s use of that functional formula.

## Decision

- The Third Circuit affirmed the partial summary judgment for Data-Max.
- The court held the handicap formula was functional and not protectable through § 43(a) or New Jersey unfair-competition law to exclude competitors from using it.
- The court rejected the false-designation theory because the formula was not a source-identifier; it was the operative method of calculation.
- The court held New Jersey misappropriation did not extend to granting exclusive control over a functional, standard method of calculation.
- The court accepted appellate jurisdiction under Rule 54(b), treating the disposed claims as final and sufficiently separable from remaining claims.

## Legal Principles

- Functional features or methods cannot be monopolized through Lanham Act § 43(a) or analogous state unfair-competition doctrines when doing so would confer patent-like exclusivity without satisfying patent-law limits.
- § 43(a) targets misleading source identification; it does not create exclusive rights in functional components or methods simply because they are associated with a particular organization.
- INS-style misappropriation is limited and does not create a broad quasi-property right to control functional know-how or calculation methods in ordinary competition.
- Courts may reject efforts to use unfair-competition or misappropriation theories as substitutes for patent protection over useful methods or formulas.

## Conclusion

The Third Circuit held that a golf-handicap mathematical formula is a functional method and, absent patent or copyright, cannot be protected from competitive use through Lanham Act § 43(a), New Jersey unfair competition, or INS-type misappropriation; the judgment for the competitor was affirmed.


United States Golf Ass’n v. St. Andrews Sys., 749 F.2d 1028 (3d Cir. 1984)