Holiday Inns, Inc. v. 800 Reservation Inc

In Holiday Inns, Inc. v. 800 Reservation Inc. (6th Cir. 1996) 86 F.3d 619, a hotel chain asserted unfair competition and trademark infringement claims under the Lanham Act (15 U.S.C. 1114, 1125) against a reservation service, alleging that the service used a phone number that customers often misdialed when attempting to contact the hotel chain via its 800 number. (86 F.3d at pp. 620-621.) After the hotel chain secured summary judgment on its claims, the Sixth Circuit reversed, concluding there was no evidence that the reservation service created or promoted consumer confusion. (Id. at pp. 622-626.) The Sixth Circuit noted there was evidence that the reservation service tried to dispel confusion by a recorded message informing callers that they had not reached the hotel chain. (Ibid.)