Earlier this year, the Federal Circuit found the COACH mark for famous American handbags to be not famous enough to oppose a similar mark that an educational testing preparation company sought to register. In trademark law, a trademark owner generally has to prove the likelihood of consumer confusion in order to successfully oppose another’s use or registration of a similar mark. This usually means that the two companies will be competing in the same line of business or in related markets. However, those whose marks are famous enough can stop another from registering a similar mark, even if they are not likely to confuse consumers or even run into each other in the marketplace. This is what Coach, the luxury handbag and accessories designer, attempted to do. It brought a dilution claim saying that those who saw the advertising of the Coach testing prep company might not confuse it with the company’s trademark COACH for handbags, but that the use by the testing company was likely to blur or tarnish (to “dilute”) the famous mark of Coach handbags.