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The U.S. Supreme Court's holding in Abitron Austria GmbH v. Hetronic International, Inc. makes clear that, for the time being, U.S. plaintiffs cannot enforce the Lanham Act against non-U.S. defendants who transact exclusively outside of U.S. borders.
Supreme Court held that the Lanham Act only extends to claims where the claimed trademark infringing use is domestic, making clear that for now US plaintiffs cannot enforce Lanham Act against non US defendants who transact exclusively outside of USA borders.