Self-Realization Fellowship Church v. Ananda Church of Self-Realization

The Self-Realization Fellowship Church (SRF) sued the Ananda Church of Self-Realization (CSR) for infringing its trademarks and trade names for terms like “Self-realization.” The district court dissolved a preliminary injunction enjoining CSR from infringing on SRF’s trade names and marks, and SRF appeals. We affirm the order dissolving the injunction with respect to some of the marks and reverse with respect to others.

I. FACTS AND PROCEEDINGS BELOW

“Self-realization” is the ultimate goal of Hindu-Yoga teaching. The Hindu-Yoga spiritual tradition teaches that there exists an “Ultimate Reality.” The Ultimate Reality is infinite, but it exists at the core of every person’s being as the “Self.” According to Yoga, the goal of life is to transcend one’s finite limitations, like body, ego, and personality, to dissolve the barriers between the personal self and the infinite Self, to “realize” a union with the “Self.” One prominent guru in this religious tradition was Paramahansa Yogananda, known to many Americans as the author of Autobiography of a Yogi.

Modern-day disciples of this guru, this advocate of rising above worldly and ego-bound concerns, have founded two rival schools…