In Vanity Fair Mills v. T. Eaton Co., 234 F.2d 633 (2d Cir.), cert. denied, 352 U.S. 871, 77 S.Ct. 96, 1 L.Ed.2d 76 (1956), the Court concluded that under Bulova, three factors were relevant to a determination of the extraterritorial reach of the Lanham Act: (1) whether the defendant was a United States citizen, (2) whether the defendant's conduct had a substantial effect on United States commerce, and (3) whether there was a conflict with trademark rights established under foreign law. Id. at 642-43. In Vanity Fair, the defendant was not a United States citizen and there was a conflict with trademark rights established under foreign law. Stating that either one of these factors "might well be determinative and ... the presence of both is certainly fatal," we then held that "the remedies provided by the Lanham Act ... should not be given extraterritorial application against foreign citizens acting under presumably valid trademarks in a foreign country." Id. at 643.