572 U.S. 118, 127 (2014)
Lexmark International, Inc. manufactures and sells laser printers along with the toner cartridges designed exclusively for those printers.1
It introduced a Prebate program that offered customers a 20-percent discount on new cartridges if they agreed to return the empty cartridges to Lexmark once used.2 The program terms were communicated to consumers through notices printed on the toner-cartridge boxes.3
Static Control Components, Inc. manufactures and sells components necessary for remanufacturers to refurbish used Lexmark toner cartridges.4 Static Control developed a microchip that could mimic the microchip in Lexmark Prebate cartridges, enabling remanufacturers to refurbish and resell those cartridges after replacing the original chip.5
In 2002 Lexmark sued Static Control alleging violations of the Copyright Act and the Digital Millennium Copyright Act.6 Static Control counterclaimed under section 43(a) of the Lanham Act, alleging that Lexmark misled end-users into believing they are legally bound by the Prebate terms.7 Static Control further alleged that Lexmark sent letters to remanufacturers falsely advising that it was illegal to sell refurbished Prebate cartridges and to use Static Control products.8
Static Control alleged that these statements caused it lost sales and damage to its business reputation.9 The district court granted Lexmark’s motion to dismiss the Lanham Act counterclaim on prudential standing grounds.10 The Sixth Circuit reversed after applying the reasonable-interest test.11 The Supreme Court granted certiorari to decide the appropriate analytical framework.
Whether Static Control may sue Lexmark for false advertising under section 1125(a) of the Lanham Act?12
The §1125(a) cause of action extends to plaintiffs who fall within the zone of interests protected by that statute and whose injury was proximately caused by a violation of that statute.13
Yes. Static Control's alleged injuries of lost sales and damage to its business reputation fall within the zone of interests protected by the Lanham Act because they are injuries to a commercial interest in reputation or sales.14 Static Control sufficiently alleged that its injuries were proximately caused by Lexmark's misrepresentations.15 The deception of consumers and remanufacturers caused them to withhold trade from Static Control, and there is a close 1:1 relationship between reduced remanufacturer sales and reduced microchip sales by Static Control.16
Static Control has adequately pleaded the elements of a Lanham Act cause of action for false advertising.17
Whether the appropriate analytical framework for determining who may sue under the Lanham Act false-advertising provision requires application of the zone-of-interests test and proximate causation?18
The zone-of-interests test and the proximate-cause requirement supply the limits on who may sue under §1125(a), providing better guidance than multifactor balancing tests, direct-competitor tests, or reasonable-interest tests.19
Yes. The Court applied traditional principles of statutory interpretation to determine that the cause of action in §1125(a) extends to plaintiffs within the zone of interests and whose injuries are proximately caused by the violation.20 This framework rejects the multifactor balancing test used by the district court and the reasonable-interest test used by the Sixth Circuit in favor of the direct application of these two principles.21
The zone-of-interests test and the proximate-cause requirement are the appropriate analytical framework for determining who may sue under the Lanham Act false-advertising provision.22