US: TTAB clarifies requirements for consent agreements

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

US: TTAB clarifies requirements for consent agreements

The Trademark Trial and Appeal Board (TTAB) issued a precedential opinion in In re American Cruise Lines, Inc. regarding the necessary provisions for an acceptable consent to registration. In doing so, the TTAB provided clarification and guidance to trade mark owners who are negotiating and drafting consent agreements.

American Cruise Lines filed a trade mark application for the mark AMERICAN CONSTELLATION covering cruise ship services. The USPTO refused to register the mark based on a likelihood of confusion with the registered marks CONSTELLATION and CELEBRITY CONSTELLATION, each owned by the same registrant and covering identical services. During the prosecution of its application, in its attempts to overcome the likelihood of confusion refusal, American Cruise Lines submitted two consent agreements between it and the owner of the cited registrations. The USPTO examiner did not accept either consent agreement and maintained the refusal. American Cruise Lines then appealed the refusal to the TTAB.

The second consent agreement submitted listed five reasons why the parties believed that confusion was not likely. However, the examiner argued that it was still a "naked" consent because it did not describe the arrangements undertaken by the parties to avoid confusion, did not include an express undertaking by the parties to make efforts to prevent confusion or to cooperate with one another and take steps to avoid any confusion that may arise in the future. A "naked consent agreement" is one that contains little more than the registrant's consent to registration and, sometimes, a statement that confusion is believed to be unlikely. Naked consent agreements are generally not sufficient to overcome a likelihood of confusion refusal.

The TTAB found that the second consent agreement was not, in fact, a naked one. It held that "a provision in the consent agreement that the parties agree to make efforts to prevent confusion or to cooperate and take steps to avoid confusion that may arise in the future may render the agreement more probative, but it is not an essential provision for the agreement to have probative value." The TTAB noted that the consent agreement at issue included several credible reasons that the parties consider confusion to be unlikely and held that "while the inclusion of provisions to avoid any potential confusion are preferred and probative in consent agreements, they are not mandatory."

The TTAB ruled that a consent agreement in which "competitors have clearly thought out their commercial interests" should be given great weight and that the examiner should not substitute its judgment concerning the likelihood of confusion between two marks for the judgment of the real parties in interest. Accordingly, the TTAB reversed the refusal to register the AMERICAN CONSTELLATION mark.

This decision is instructive because it confirms that the TTAB will give great deference to contracting parties who have entered into a consent agreement and that parties to a consent agreement do not necessarily need to include provisions about taking steps to avoid confusion in order for the consent to be accepted. Nonetheless, given the TTAB's indication that such provisions are preferred and probative, it continues to be advisable to include such provisions.

ash-karen-artz.jpg

danow.jpg

Karen Artz Ash

Bret J Danow

Katten Muchin Rosenman LLP 

575 Madison Avenue

New York, NY 10022-2585

United States

Tel: +1 212 940 8554

Fax: +1 212 940 8671

karen.ash@kattenlaw.com

www.kattenlaw.com

more from across site and SHARED ros bottom lb

More from across our site

Injunctions for HandsFree Labs and Align Technology come as the Court of Appeal warns that busy teams must have the staffing and resources to meet UPC deadlines
The chief technology officer remit, which has been created as the firm is building its litigation team, will include expanding the use of AI in patent and legal work and automating manual processes
Former Hoyng Rokh Moneiger partner Laura Alonso, who brought her team to ECIJA in March, discusses plans to expand further and why ECIJA’s ‘IP DNA’ is helping broaden her work
Amita Haylock discusses building an integrated Asia practice as clients increasingly demand that firms combine IP, technology and data expertise
François Pochart, Grégoire Desrousseaux and Lionel Martin, long-standing figures in the firm’s patent litigation team, are set to help launch a Paris-based litigation offering
The Unitary Patent has passed 100,000 registrations, but new data raises the question of whether 30% uptake is a ceiling or a staging post for further growth, say Michael Nielsen and Darren Smyth of EIP and Andrew Samm at Patently
The new generation of in-house IP leaders want commercial judgment, accessibility and flexibility, with AI raising expectations around both fees and delivery
The firm launched a San Diego office earlier this month, but California investment and expansion is far from complete
The industry’s response to AI requires an unfamiliar ingredient as firms battle to shape their futures
The firm is looking beyond replacing recently departed talent, betting instead on senior leaders to strengthen and expand its patent litigation platform
Gift this article