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Retail
12 min read
Areas of Expertise :
Trademarks, Unfair Competition, Retail, Advertising, Damages
Published Date:
Last Modified Date:
Jurisdiction:
Federal. Second Circuit
Court:
A disagreement over secondhand Chanel products developed into a seven-year federal trademark case between Chanel, Inc. and What Comes Around Goes Around LLC, doing business as What Goes Around Comes Around and commonly known as WGACA. Chanel filed the action in the U.S. District Court for the Southern District of New York on March 14, 2018. Its allegations went beyond the resale of used luxury goods. Chanel challenged WGACA's use of Chanel trademarks and imagery in advertising, its representations about authenticity, and its sale of certain Chanel-branded products whose serial numbers or sales history Chanel disputed. WGACA denied liability and maintained, among other positions, that genuine Chanel products could lawfully be resold and identified by the Chanel marks.
The case eventually reached a jury before U.S. District Judge Louis L. Stanton. On February 6, 2024, the jury found WGACA liable on Chanel's Lanham Act claims for trademark infringement, false association, unfair competition, and false advertising and awarded Chanel $4 million in statutory damages. A later bench trial addressed equitable remedies, followed by a February 2025 final judgment requiring $12,739 in disgorgement and imposing a permanent injunction. The district court denied WGACA's post-trial challenge in June 2025, and WGACA pursued an appeal in the U.S. Court of Appeals for the Second Circuit.
Chanel filed Chanel, Inc. v. What Comes Around Goes Around LLC in the Southern District of New York. The litigation challenged the way WGACA sold and promoted Chanel-branded merchandise through its luxury resale business. Chanel alleged that WGACA used Chanel's marks and other brand references in a manner that could create a false impression of affiliation, sponsorship, approval, or authorization. Chanel's amended pleadings included federal claims for trademark infringement, false association and endorsement, and false advertising, as well as claims under New York General Business Law §§ 349 and 350.
WGACA disputed Chanel's allegations. Its defenses included arguments concerning the resale of genuine branded merchandise and the use of trademarks to identify products being offered on the secondary market. Those issues remained part of the litigation as the parties moved through discovery and toward summary judgment.
Judge Stanton issued a 55-page opinion addressing the parties' competing summary judgment motions. WGACA obtained dismissal of Chanel's claims under New York General Business Law §§ 349 and 350, but the court declined to dismiss the principal Lanham Act claims. Chanel obtained partial summary judgment on trademark infringement involving non-genuine Chanel-branded point-of-sale items and 11 non-genuine handbags bearing serial numbers stolen from the Renato Corti factory. The court also initially granted judgment concerning a handbag bearing serial number 17744200, a ruling that was later vacated after an error in the underlying data came to light.
The decision also discussed expert survey evidence. Chanel's consumer survey expert, David Franklyn, conducted two surveys that measured potential Chanel purchasers' level of confusion after reviewing WGACA's 2015 website. WGACA's expert, Dr. Melissa Pittaoulis, challenged Franklyn's methodology, survey design, and sample size. Judge Stanton did not resolve the competing expert opinions at summary judgment, stating that expert credibility was a question for the factfinder.
As trial approached, Judge Stanton set out the order in which the remaining issues would be heard. The jury would first decide liability and any legal remedies assigned to it, including statutory damages. After the jury completed its work, the court would hear evidence concerning equitable relief, including disgorgement and an injunction.
The order specifically identified Dr. Andrew Safir and Henry Kahrs as experts whose opinions would be reserved for the equitable-remedies phase. Safir was associated with Chanel's financial analysis, while Kahrs was associated with WGACA's financial presentation. Their opinions were not designated for the jury phase.
The jury trial began on January 9, 2024. The evidence covered WGACA's advertising, use of Chanel marks and imagery, statements concerning authenticity, sales records, product provenance, and the status of specific Chanel-branded merchandise. The parties also addressed Chanel's internal serial-number records and whether particular products could be traced through Chanel's manufacturing, quality-control, and distribution systems.
Part of that evidence arose from a November 2012 theft at the Renato Corti factory. Approximately 30,000 Chanel labels, stickers, and authenticity cards bearing unique serial numbers were stolen. Chanel used its internal ORLI system to track the allocation of serial numbers to factories and their later assignment to products that had passed specified quality-control procedures. Serial numbers reported as stolen or missing could be voided in that system.
While the jury trial was underway, Judge Stanton revisited the 2022 summary judgment ruling concerning handbag serial number 17744200. The earlier decision had classified that handbag as non-genuine and counterfeit because its recorded characteristics did not match the product Chanel had authorized under the serial number.
The court was then informed that the ruling had relied on a recently discovered data-entry error in WGACA's sales records. The serial number had been mistyped, and the correct ORLI record had been produced for use at trial. Judge Stanton vacated the portion of the summary judgment decision concerning that handbag, allowing the corrected evidence to be addressed through the trial record.
Consumer perception remained part of the dispute as the case went to trial. Chanel's consumer survey expert, David Franklyn, had examined how potential Chanel purchasers interpreted WGACA's presentation of Chanel merchandise. His surveys addressed whether respondents perceived affiliation, sponsorship, approval, or authorization between the companies.
WGACA's consumer survey expert, Dr. Melissa Pittaoulis, challenged features of Franklyn's work, including its methodology, survey design, and sample size. WGACA also moved during trial to exclude Franklyn's testimony and report. The disagreement placed the design and interpretation of consumer-confusion surveys among the evidentiary questions presented in the case.
After a trial that lasted from January 9 through February 6, the jury found WGACA liable on Chanel's Lanham Act claims for trademark infringement, false association, unfair competition, and false advertising. It awarded Chanel $4 million in statutory damages under 15 U.S.C. § 1117(c)(2) for the sale or offering for sale of Chanel-branded handbags bearing counterfeit trademarks.
That verdict did not resolve every requested remedy. Chanel continued to seek disgorgement of profits and permanent injunctive relief, both of which were reserved for Judge Stanton rather than the jury.
Judge Stanton conducted a separate bench trial from July 15 through July 19, 2024. Chanel asked the court to order disgorgement and impose restrictions on WGACA's future Chanel-related marketing and sales practices. The court considered financial evidence and the expert opinions that had been reserved for this phase.
Chanel's economic expert, Dr. Andrew Safir, provided financial analysis associated with Chanel's requested monetary relief. WGACA's financial expert, Henry Kahrs, provided financial analysis concerning WGACA's profits. The court had previously directed that the opinions of both experts be heard only in connection with the equitable-remedies proceedings.
Judge Stanton entered final judgment on February 26, 2025. In addition to the jury's $4 million statutory damages award, the court ordered WGACA to disgorge $12,739 in net profits. That amount related to the sale of 51 Chanel-branded handbags bearing voided Chanel serial numbers and 779 Chanel-branded counter-support items that the jury found had not been authorized for sale by Chanel.
The permanent injunction placed detailed conditions on specified Chanel-related advertising and sales practices. Its provisions addressed certain uses of Chanel trademarks, Chanel-related hashtags and discount codes, runway and advertising images, store displays, product-authenticity representations, and the amount of Chanel branding used to identify merchandise. The judgment also required specified non-affiliation disclaimers on webpages and physical tags.
WGACA filed a notice of civil appeal on March 28, 2025. The Second Circuit opened the appeal on March 31 as Chanel, Inc. v. What Comes Around Goes Around LLC, No. 25-722.
Post-trial motions were still pending in the district court, so the appeal was initially affected by a stay under Federal Rule of Appellate Procedure 4(a)(4). The appellate proceedings resumed after Judge Stanton decided those motions.
WGACA moved for judgment as a matter of law and for a new trial under Rules 50 and 59 of the Federal Rules of Civil Procedure. On June 26, 2025, Judge Stanton denied WGACA's challenge and left the $4 million statutory damages award intact. In discussing the trial record, the court stated that there was sufficient evidence of willful infringement while also noting that the infringing transactions represented a small portion of WGACA's overall Chanel-branded sales, most of which were within the bounds of the Lanham Act.
Chanel separately requested attorneys' fees and litigation costs. Judge Stanton declined to classify the case as "exceptional" for purposes of a Lanham Act fee award and denied the request for attorneys' fees. The court did, however, award Chanel $560,978.97 in litigation costs. On July 9, 2025, the Second Circuit lifted the stay and received an amended notice of appeal. The appeal was reported as remaining pending as of July 2026.
United States District Court for the Southern District of New York
Case Name:
Chanel, Inc. v. What Comes Around Goes Around LLC
Trademark Infringement
Counterfeit products
Brand Dilution
Branding
Deceptive Advertising
Marketing
Retail Stores
Consumer Protection
Consumer Fraud
A disagreement over secondhand Chanel products developed into a seven-year federal trademark case between Chanel, Inc. and What Comes Around Goes Around LLC, doing business as What Goes Around Comes Around and commonly known as WGACA. Chanel filed the action in the U.S. District Court for the Southern District of New York on March 14, 2018. Its allegations went beyond the resale of used luxury goods. Chanel challenged WGACA's use of Chanel trademarks and imagery in advertising, its representations about authenticity, and its sale of certain Chanel-branded products whose serial numbers or sales history Chanel disputed. WGACA denied liability and maintained, among other positions, that genuine Chanel products could lawfully be resold and identified by the Chanel marks.
The case eventually reached a jury before U.S. District Judge Louis L. Stanton. On February 6, 2024, the jury found WGACA liable on Chanel's Lanham Act claims for trademark infringement, false association, unfair competition, and false advertising and awarded Chanel $4 million in statutory damages. A later bench trial addressed equitable remedies, followed by a February 2025 final judgment requiring $12,739 in disgorgement and imposing a permanent injunction. The district court denied WGACA's post-trial challenge in June 2025, and WGACA pursued an appeal in the U.S. Court of Appeals for the Second Circuit.
Chanel filed Chanel, Inc. v. What Comes Around Goes Around LLC in the Southern District of New York. The litigation challenged the way WGACA sold and promoted Chanel-branded merchandise through its luxury resale business. Chanel alleged that WGACA used Chanel's marks and other brand references in a manner that could create a false impression of affiliation, sponsorship, approval, or authorization. Chanel's amended pleadings included federal claims for trademark infringement, false association and endorsement, and false advertising, as well as claims under New York General Business Law §§ 349 and 350.
WGACA disputed Chanel's allegations. Its defenses included arguments concerning the resale of genuine branded merchandise and the use of trademarks to identify products being offered on the secondary market. Those issues remained part of the litigation as the parties moved through discovery and toward summary judgment.
Judge Stanton issued a 55-page opinion addressing the parties' competing summary judgment motions. WGACA obtained dismissal of Chanel's claims under New York General Business Law §§ 349 and 350, but the court declined to dismiss the principal Lanham Act claims. Chanel obtained partial summary judgment on trademark infringement involving non-genuine Chanel-branded point-of-sale items and 11 non-genuine handbags bearing serial numbers stolen from the Renato Corti factory. The court also initially granted judgment concerning a handbag bearing serial number 17744200, a ruling that was later vacated after an error in the underlying data came to light.
The decision also discussed expert survey evidence. Chanel's consumer survey expert, David Franklyn, conducted two surveys that measured potential Chanel purchasers' level of confusion after reviewing WGACA's 2015 website. WGACA's expert, Dr. Melissa Pittaoulis, challenged Franklyn's methodology, survey design, and sample size. Judge Stanton did not resolve the competing expert opinions at summary judgment, stating that expert credibility was a question for the factfinder.
As trial approached, Judge Stanton set out the order in which the remaining issues would be heard. The jury would first decide liability and any legal remedies assigned to it, including statutory damages. After the jury completed its work, the court would hear evidence concerning equitable relief, including disgorgement and an injunction.
The order specifically identified Dr. Andrew Safir and Henry Kahrs as experts whose opinions would be reserved for the equitable-remedies phase. Safir was associated with Chanel's financial analysis, while Kahrs was associated with WGACA's financial presentation. Their opinions were not designated for the jury phase.
The jury trial began on January 9, 2024. The evidence covered WGACA's advertising, use of Chanel marks and imagery, statements concerning authenticity, sales records, product provenance, and the status of specific Chanel-branded merchandise. The parties also addressed Chanel's internal serial-number records and whether particular products could be traced through Chanel's manufacturing, quality-control, and distribution systems.
Part of that evidence arose from a November 2012 theft at the Renato Corti factory. Approximately 30,000 Chanel labels, stickers, and authenticity cards bearing unique serial numbers were stolen. Chanel used its internal ORLI system to track the allocation of serial numbers to factories and their later assignment to products that had passed specified quality-control procedures. Serial numbers reported as stolen or missing could be voided in that system.
While the jury trial was underway, Judge Stanton revisited the 2022 summary judgment ruling concerning handbag serial number 17744200. The earlier decision had classified that handbag as non-genuine and counterfeit because its recorded characteristics did not match the product Chanel had authorized under the serial number.
The court was then informed that the ruling had relied on a recently discovered data-entry error in WGACA's sales records. The serial number had been mistyped, and the correct ORLI record had been produced for use at trial. Judge Stanton vacated the portion of the summary judgment decision concerning that handbag, allowing the corrected evidence to be addressed through the trial record.
Consumer perception remained part of the dispute as the case went to trial. Chanel's consumer survey expert, David Franklyn, had examined how potential Chanel purchasers interpreted WGACA's presentation of Chanel merchandise. His surveys addressed whether respondents perceived affiliation, sponsorship, approval, or authorization between the companies.
WGACA's consumer survey expert, Dr. Melissa Pittaoulis, challenged features of Franklyn's work, including its methodology, survey design, and sample size. WGACA also moved during trial to exclude Franklyn's testimony and report. The disagreement placed the design and interpretation of consumer-confusion surveys among the evidentiary questions presented in the case.
After a trial that lasted from January 9 through February 6, the jury found WGACA liable on Chanel's Lanham Act claims for trademark infringement, false association, unfair competition, and false advertising. It awarded Chanel $4 million in statutory damages under 15 U.S.C. § 1117(c)(2) for the sale or offering for sale of Chanel-branded handbags bearing counterfeit trademarks.
That verdict did not resolve every requested remedy. Chanel continued to seek disgorgement of profits and permanent injunctive relief, both of which were reserved for Judge Stanton rather than the jury.
Judge Stanton conducted a separate bench trial from July 15 through July 19, 2024. Chanel asked the court to order disgorgement and impose restrictions on WGACA's future Chanel-related marketing and sales practices. The court considered financial evidence and the expert opinions that had been reserved for this phase.
Chanel's economic expert, Dr. Andrew Safir, provided financial analysis associated with Chanel's requested monetary relief. WGACA's financial expert, Henry Kahrs, provided financial analysis concerning WGACA's profits. The court had previously directed that the opinions of both experts be heard only in connection with the equitable-remedies proceedings.
Judge Stanton entered final judgment on February 26, 2025. In addition to the jury's $4 million statutory damages award, the court ordered WGACA to disgorge $12,739 in net profits. That amount related to the sale of 51 Chanel-branded handbags bearing voided Chanel serial numbers and 779 Chanel-branded counter-support items that the jury found had not been authorized for sale by Chanel.
The permanent injunction placed detailed conditions on specified Chanel-related advertising and sales practices. Its provisions addressed certain uses of Chanel trademarks, Chanel-related hashtags and discount codes, runway and advertising images, store displays, product-authenticity representations, and the amount of Chanel branding used to identify merchandise. The judgment also required specified non-affiliation disclaimers on webpages and physical tags.
WGACA filed a notice of civil appeal on March 28, 2025. The Second Circuit opened the appeal on March 31 as Chanel, Inc. v. What Comes Around Goes Around LLC, No. 25-722.
Post-trial motions were still pending in the district court, so the appeal was initially affected by a stay under Federal Rule of Appellate Procedure 4(a)(4). The appellate proceedings resumed after Judge Stanton decided those motions.
WGACA moved for judgment as a matter of law and for a new trial under Rules 50 and 59 of the Federal Rules of Civil Procedure. On June 26, 2025, Judge Stanton denied WGACA's challenge and left the $4 million statutory damages award intact. In discussing the trial record, the court stated that there was sufficient evidence of willful infringement while also noting that the infringing transactions represented a small portion of WGACA's overall Chanel-branded sales, most of which were within the bounds of the Lanham Act.
Chanel separately requested attorneys' fees and litigation costs. Judge Stanton declined to classify the case as "exceptional" for purposes of a Lanham Act fee award and denied the request for attorneys' fees. The court did, however, award Chanel $560,978.97 in litigation costs. On July 9, 2025, the Second Circuit lifted the stay and received an amended notice of appeal. The appeal was reported as remaining pending as of July 2026.
Plaintiff: David Franklyn Chanel offered David Franklyn as a consumer survey expert. He conducted two surveys examining whether potential Chanel purchasers viewing WGACA's website perceived the reseller as affiliated with, sponsored by, approved by, or authorized by Chanel. Judge Stanton discussed the surveys in the March 2022 summary judgment opinion and left the competing expert credibility issues for the factfinder.
Defense: Dr. Melissa Pittaoulis WGACA offered Dr. Melissa Pittaoulis as a consumer survey rebuttal expert to evaluate Franklyn's survey evidence. She questioned aspects of his methodology, survey design, and sample size, and the district court identified her as WGACA's expert in the survey dispute. Her role focused on assessing the reliability of Franklyn's survey work rather than determining ultimate trademark liability.
Chanel identified Dr. Andrew Safir as an economic expert whose analysis addressed financial issues tied to Chanel's requested monetary relief. Judge Stanton later designated Safir's opinions for the equitable-remedies phase, where they were considered by the court rather than the jury deciding liability and statutory damages.
Henry Kahrs was identified by Judge Stanton as an expert for the equitable-remedies phase. His financial analysis addressed WGACA’s profits and other remedies-related issues, while Judge Stanton separately determined the final disgorgement award.
A trademark expert witness could be used in a dispute involving marketplace use of trademarks, reseller advertising, brand identification, industry practices, or other technical issues outside ordinary factual testimony. Depending on the assignment, such an expert may analyze how trademarks are used in a particular market, how branded goods are identified in resale channels, or customary practices involving brand references in advertising.
Judge Stanton recognized that the Lanham Act generally allows unauthorized resellers to sell genuine trademarked goods. Chanel's claims focused instead on products alleged to be non-genuine, outside Chanel's quality-control process, or never authorized for initial sale. The court later noted that most of WGACA's Chanel-branded sales remained within the bounds of the Lanham Act.
Chanel's claims addressed both the status of individual products and WGACA's marketing practices. The record covered advertising, social-media content, Chanel marks and images, promotional campaigns, and authenticity statements. The jury ultimately found WGACA liable for false association and false advertising in addition to trademark infringement.
Chanel relied on David Franklyn's surveys to examine whether potential purchasers perceived a relationship between WGACA and Chanel. WGACA challenged that evidence through Dr. Melissa Pittaoulis, who questioned the survey methodology, design, and sample size. The court left the competing expert credibility issues for the factfinder.
Chanel used ORLI records to compare disputed serial numbers with manufacturing, quality-control, and distribution information. Judge Stanton distinguished between non-genuine infringing goods and counterfeit goods, explaining that a product could infringe Chanel's trademark without necessarily being counterfeit. The later correction involving serial number 17744200 also depended on accurate product and sales records.
The jury awarded Chanel $4 million in statutory damages for handbags bearing counterfeit trademarks, while Judge Stanton later ordered $12,739 in disgorgement during the equitable-remedies phase. The final judgment also imposed a permanent injunction governing specified Chanel-related marketing and authenticity practices. Chanel's later request for attorneys' fees was denied, although the court awarded $560,978.97 in litigation costs.
The Chanel v. WGACA litigation began in 2018 over the reseller's use of Chanel trademarks, advertising, authenticity representations, and disputed Chanel-branded products. After a partial summary judgment ruling in March 2022, the remaining Lanham Act claims proceeded to trial in early 2024, where the parties presented evidence on advertising, product provenance, serial numbers, authenticity, consumer perception, and trademark use. The court also corrected an earlier ruling after a data-entry error involving serial number 17744200 was discovered. On February 6, 2024, the jury found WGACA liable and awarded Chanel $4 million in statutory damages. Judge Stanton later held a separate remedies trial, entered final judgment in February 2025 with $12,739 in disgorgement and a permanent injunction, and in June 2025 denied WGACA's post-trial challenge and Chanel's request for attorneys' fees while awarding Chanel $560,978.97 in costs. WGACA continued its Second Circuit appeal, which was reported as pending as of July 2026.
Why did Chanel sue What Goes Around Comes Around?
Chanel alleged that WGACA infringed its trademarks and used Chanel branding in ways that could suggest affiliation, sponsorship, approval, or authorization. The case also involved disputed Chanel-branded merchandise, serial-number records, authenticity representations, false association, and false advertising, while WGACA denied liability and relied in part on principles allowing resale of genuine trademarked goods.
Did the court rule that unauthorized resale of genuine Chanel products is illegal?
No. Judge Stanton recognized that trademark law generally permits resale of genuine branded goods even without authorization from the trademark owner. The disputed issues instead concerned goods alleged to be non-genuine or counterfeit, products outside Chanel's quality-control process, and advertising that supported the jury's findings on false association and false advertising.
What did the jury find against WGACA?
On February 6, 2024, the jury found WGACA liable for trademark infringement, false association, unfair competition, and false advertising under the Lanham Act. It awarded Chanel $4 million in statutory damages under 15 U.S.C. § 1117(c)(2) for Chanel-branded handbags bearing counterfeit trademarks, while disgorgement and injunctive relief were reserved for Judge Stanton.
What happened with Chanel serial number 17744200?
The court initially ruled that a handbag associated with serial number 17744200 was non-genuine and counterfeit. During the 2024 trial, however, a data-entry error in WGACA's sales records was discovered, and the correct Chanel ORLI record was produced. Judge Stanton then vacated that portion of the earlier summary judgment ruling so the corrected evidence could be considered at trial.
What relief did Chanel receive after trial?
Chanel received a $4 million statutory damages award, $12,739 in disgorgement tied to 51 handbags with voided serial numbers and 779 unauthorized counter-support items, and a permanent injunction regulating specified Chanel-related sales and advertising practices. The court later denied attorneys' fees but awarded $560,978.97 in litigation costs, and WGACA appealed the final judgment.
Plaintiff: David Franklyn Chanel offered David Franklyn as a consumer survey expert. He conducted two surveys examining whether potential Chanel purchasers viewing WGACA's website perceived the reseller as affiliated with, sponsored by, approved by, or authorized by Chanel. Judge Stanton discussed the surveys in the March 2022 summary judgment opinion and left the competing expert credibility issues for the factfinder.
Defense: Dr. Melissa Pittaoulis WGACA offered Dr. Melissa Pittaoulis as a consumer survey rebuttal expert to evaluate Franklyn's survey evidence. She questioned aspects of his methodology, survey design, and sample size, and the district court identified her as WGACA's expert in the survey dispute. Her role focused on assessing the reliability of Franklyn's survey work rather than determining ultimate trademark liability.
Chanel identified Dr. Andrew Safir as an economic expert whose analysis addressed financial issues tied to Chanel's requested monetary relief. Judge Stanton later designated Safir's opinions for the equitable-remedies phase, where they were considered by the court rather than the jury deciding liability and statutory damages.
Henry Kahrs was identified by Judge Stanton as an expert for the equitable-remedies phase. His financial analysis addressed WGACA’s profits and other remedies-related issues, while Judge Stanton separately determined the final disgorgement award.
A trademark expert witness could be used in a dispute involving marketplace use of trademarks, reseller advertising, brand identification, industry practices, or other technical issues outside ordinary factual testimony. Depending on the assignment, such an expert may analyze how trademarks are used in a particular market, how branded goods are identified in resale channels, or customary practices involving brand references in advertising.
Judge Stanton recognized that the Lanham Act generally allows unauthorized resellers to sell genuine trademarked goods. Chanel's claims focused instead on products alleged to be non-genuine, outside Chanel's quality-control process, or never authorized for initial sale. The court later noted that most of WGACA's Chanel-branded sales remained within the bounds of the Lanham Act.
Chanel's claims addressed both the status of individual products and WGACA's marketing practices. The record covered advertising, social-media content, Chanel marks and images, promotional campaigns, and authenticity statements. The jury ultimately found WGACA liable for false association and false advertising in addition to trademark infringement.
Chanel relied on David Franklyn's surveys to examine whether potential purchasers perceived a relationship between WGACA and Chanel. WGACA challenged that evidence through Dr. Melissa Pittaoulis, who questioned the survey methodology, design, and sample size. The court left the competing expert credibility issues for the factfinder.
Chanel used ORLI records to compare disputed serial numbers with manufacturing, quality-control, and distribution information. Judge Stanton distinguished between non-genuine infringing goods and counterfeit goods, explaining that a product could infringe Chanel's trademark without necessarily being counterfeit. The later correction involving serial number 17744200 also depended on accurate product and sales records.
The jury awarded Chanel $4 million in statutory damages for handbags bearing counterfeit trademarks, while Judge Stanton later ordered $12,739 in disgorgement during the equitable-remedies phase. The final judgment also imposed a permanent injunction governing specified Chanel-related marketing and authenticity practices. Chanel's later request for attorneys' fees was denied, although the court awarded $560,978.97 in litigation costs.
The Chanel v. WGACA litigation began in 2018 over the reseller's use of Chanel trademarks, advertising, authenticity representations, and disputed Chanel-branded products. After a partial summary judgment ruling in March 2022, the remaining Lanham Act claims proceeded to trial in early 2024, where the parties presented evidence on advertising, product provenance, serial numbers, authenticity, consumer perception, and trademark use. The court also corrected an earlier ruling after a data-entry error involving serial number 17744200 was discovered. On February 6, 2024, the jury found WGACA liable and awarded Chanel $4 million in statutory damages. Judge Stanton later held a separate remedies trial, entered final judgment in February 2025 with $12,739 in disgorgement and a permanent injunction, and in June 2025 denied WGACA's post-trial challenge and Chanel's request for attorneys' fees while awarding Chanel $560,978.97 in costs. WGACA continued its Second Circuit appeal, which was reported as pending as of July 2026.
Why did Chanel sue What Goes Around Comes Around?
Chanel alleged that WGACA infringed its trademarks and used Chanel branding in ways that could suggest affiliation, sponsorship, approval, or authorization. The case also involved disputed Chanel-branded merchandise, serial-number records, authenticity representations, false association, and false advertising, while WGACA denied liability and relied in part on principles allowing resale of genuine trademarked goods.
Did the court rule that unauthorized resale of genuine Chanel products is illegal?
No. Judge Stanton recognized that trademark law generally permits resale of genuine branded goods even without authorization from the trademark owner. The disputed issues instead concerned goods alleged to be non-genuine or counterfeit, products outside Chanel's quality-control process, and advertising that supported the jury's findings on false association and false advertising.
What did the jury find against WGACA?
On February 6, 2024, the jury found WGACA liable for trademark infringement, false association, unfair competition, and false advertising under the Lanham Act. It awarded Chanel $4 million in statutory damages under 15 U.S.C. § 1117(c)(2) for Chanel-branded handbags bearing counterfeit trademarks, while disgorgement and injunctive relief were reserved for Judge Stanton.
What happened with Chanel serial number 17744200?
The court initially ruled that a handbag associated with serial number 17744200 was non-genuine and counterfeit. During the 2024 trial, however, a data-entry error in WGACA's sales records was discovered, and the correct Chanel ORLI record was produced. Judge Stanton then vacated that portion of the earlier summary judgment ruling so the corrected evidence could be considered at trial.
What relief did Chanel receive after trial?
Chanel received a $4 million statutory damages award, $12,739 in disgorgement tied to 51 handbags with voided serial numbers and 779 unauthorized counter-support items, and a permanent injunction regulating specified Chanel-related sales and advertising practices. The court later denied attorneys' fees but awarded $560,978.97 in litigation costs, and WGACA appealed the final judgment.
Trademark Infringement
Counterfeit products
Brand Dilution
Branding
Deceptive Advertising
Marketing
Retail Stores
Consumer Protection
Consumer Fraud
Elevator & Escalator, +4
Retail
Product Liability, +4
Retail