How have the courts interpreted dictionary definitions in determining whether a trademark is descriptive?

⁴ The author of this opinion has noted elsewhere his general [ ] reticen[ce] to invoke dictionary definitions, at least in contexts perhaps unforeseen by their writers. Mastrovincenzo v. City of New York , 435 F.3d 78, 107 (2d Cir. 2006) (Sack, J., concurring in part and dissenting in part). As the district court pointed out, however, the use of dictionaries for the purpose of deciding whether a trademark is descriptive is permissible. See March Order, 2014 WL 1202939, at *5, 2014 U.S. Dist. LEXIS 38606, at *13 (citing Coach Servs. , 668 F.3d at 1378 ). Moreover, it seems to us that these definitions of collective are reasonable and relatively uncontroversial. The district court therefore properly relied on them in the March Order, and we follow suit.

⁴ The author of this opinion has noted elsewhere his general [ ] reticen[ce] to invoke dictionary definitions, at least in contexts perhaps unforeseen by their writers. Mastrovincenzo v. City of New York , 435 F.3d 78, 107 (2d Cir. 2006) (Sack, J., concurring in part and dissenting in part). As the district court pointed out, however, the use of dictionaries for the purpose of deciding whether a trademark is descriptive is permissible. See March Order, 2014 WL 1202939, at *5, 2014 U.S. Dist. LEXIS 38606, at *13 (citing Coach Servs. , 668 F.3d at 1378 ). Moreover, it seems to us that these definitions of collective are reasonable and relatively uncontroversial. The district court therefore properly relied on them in the March Order, and we follow suit.