Southern California Darts Assn v. Dino M. Zaffina

The district court entered summary judgment for plaintiff-appellee Southern California Darts Association (“SoCal”) and issued a permanent injunction enjoining defendant-appellant Dino M. Zaffina from using certain marks that have been used by SoCal for several decades. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm.

I. BACKGROUND

For forty years or more, SoCal has promoted the competitive play of the game of darts and has coordinated league play of this game. For a time, beginning in the 1960s, members of SoCal formed and ran a corporation named “Southern California Darts Association, Inc.” (the “original So-Cal corporation”). The corporate powers of the original SoCal corporation were suspended by the State of California in 1977, apparently for nonpayment of the corporate franchise tax. SoCal has, for many years, used the following marks: its full name (“Southern California Darts Association”); the acronym “SCDA”; the nickname “SoCal Darts”; and a logo featuring the organization’s full name and a dart board.

Zaffina was once a member of SoCal. Zaffina and SoCal feuded in July 2010 over whether Zaffina’s middle initial would be used in SoCal’s weekly…