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"The only thing necessary for the triumph of evil is for good men to do nothing"
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Bath & Body Works v Luzier Personalized Cosmetics, 76 F.3d 743 (6th Cir. 1996)

PLAINTIFF: Bath & Body Works, Inc., and Bathco, Inc., since 1990, have been nationwide retailers of personal care products

DEFENDANT : Luzier Personalized Cosmetics is a small, family owned and operated business and although much smaller than Bath & Body Works, it is also a nationwide retailer of cosmetics and personal care products.

Both were marketing products with similar labels and names. Lower court ruled the words "bath and body" were generic. On June 20, 1994, the jury returned a verdict in favor of Luzier on the unfair competition claims. Bath & Body Works appealed.

Court of Appeals affirmed the lower court decision in favor of Luzier.

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