IP Law Daily, TRADEMARK—6th Cir.: Furniture company wins trademark suit brought by famed designer’s estate, (Jul 8, 2026)

By Jonathan Anderson

The appeals court concluded that the manufacturer of Herman Miller furniture is authorized to use and own the intellectual property in dispute.

The U.S. Court of Appeals for the Sixth Circuit affirmed a lower court’s grant of summary judgment to MillerKnoll, Inc. in a lawsuit alleging trademark infringement and related tort claims. At issue is who owns the intellectual property rights to a geometric hanging light fixture known as the “Bubble Lamp” designed by George Nelson, the famed former design director of Herman Miller, Incorporated, later renamed MillerKnoll (hereinafter HMI). A three-judge panel found that HMI is authorized to use and own the Bubble Lamp intellectual property, and that Nelson’s son ratified HMI’s use and ownership of the intellectual property by accepting royalty payments. The appeals court further rejected a request to cancel HMI’s trademark registrations for the Bubble Lamp IP (Nelson v. MillerKnoll, Inc., No. 25-1940 (6th Cir. Jul. 7, 2026)).

Background. The roots of the case stem from Nelson’s employment at HMI in the mid-twentieth century. During his employment at HMI, Nelson had no written formal agreement with the company regarding ownership or use of the Bubble Lamp-related intellectual property (IP) rights but instead had a verbal agreement to be paid a royalty on all designs he submitted to the company. In 1957, after Nelson no longer worked at HMI, the parties entered into a written agreement in which HMI agreed “to provide Mr. Nelson royalties for furniture products and patterns designed by him.”

Nelson died in 1986, at which time any IP rights he owned passed to his widow, Jacqueline Nelson. In 2006, Jacqueline entered into a royalty agreement with HMI in which the company agreed to pay Jacqueline the royalty rate of 1.5% per unit sold in exchange for certain rights to Nelson-designed furniture products. The 2006 agreement did not cover the Bubble Lamp IP, but the agreement did allow the parties to add additional products to be covered in the future.

In 2015, Mico Nelson, the son of George Nelson and Jacqueline Nelson, who was acting under Jacqueline’s power of attorney, entered into an addendum to the 2006 agreement. The 2015 addendum expanded the 2006 agreement to add, as new “Licensed Products,” both “Nelson branded Lamp Products” and all “Nelson branded products not covered” by the original agreement.

In 2021, after HMI asserted ownership of the Bubble Lamp IP, Plaintiffs filed suit in the Southern District of New York asserting six claims: fraud; conspiracy to commit fraud; unjust enrichment; trademark infringement under the Lanham Act, 15 U.S.C. § 1125(a); common law trademark infringement and unfair competition; and cancellation of certain design registrations pursuant to 15 U.S.C. §§ 1119, 1052(d). The suit was later transferred to the Western District of Michigan. Following discovery, the district court granted summary judgment to Defendants on all counts. The district court concluded that HMI’s use of the Bubble Lamp IP was not unlawful because Plaintiffs authorized HMI’s use and ownership of that IP in the 2015 addendum to the 2006 agreement, and ratified HMI’s conduct by accepting millions of dollars in royalty payments from HMI. Plaintiffs appealed.

Analysis. The appeals court agreed with the district court’s decision to grant summary judgment to Defendants on all counts. The appeals court found that HMI is authorized to use and own the Bubble Lamp IP under the terms of the 2006 agreement and the 2015 addendum. Mico also ratified HMI’s use and ownership of the IP by accepting royalty payments from HMI, including after he learned that HMI was asserting ownership of the Bubble Lamp IP. The appeals court further rejected Plaintiffs’ request to cancel HMI’s trademark registrations for the Bubble Lamp IP, noting that they presented no evidence supporting their cancellation claims.

Authorization. First, the court found that the agreements unambiguously authorize HMI to manufacture and sell the Bubble Lamps, and to own and use the Bubble Lamp IP.

The 2006 agreement defines “Licensed Product” to mean “the products described in the Product Description” subsection, which establishes that “Licensed Products” means products owned by HMI. Thus, the court found that authorization defeats all the plaintiffs’ federal and state infringement claims. The court further held that Defendants are entitled to summary judgment on the state law tort claims because such claims relate to HMI’s alleged “theft” and unauthorized use of the Bubble Lamp IP, which the court found were defeated by authorization.

Ratification. Second, the appeals court found that Mico’s ratification of HMI’s use and ownership of the Bubble Lamp IP provides an alternative basis for affirming the district court’s grant of summary judgment on both the infringement and tort claims. The appeals court agreed with the district court’s conclusion that Mico ratified HMI’s use and ownership of the Bubble Lamp IP by accepting royalty payments under the terms of the 2006 agreement and 2015 addendum.

Cancellation. Third, the appeals court found that Defendants are entitled to summary judgment on the cancellation claims. The court found that Plaintiffs offered no real evidence showing that HMI or other relevant actors made fraudulent statements upon which the U.S. Patent and Trademark Office relied in issuing and maintaining the trademarks for the Bubble Lamp IP.

The Case is No. 25-1940.

Judge: Clay, E.

Attorneys: Gaetan E. Gerville (Warner, Norcross & Judd LLP) for Patrice Nelson. Mark L. Durbin (Barnes & Thornburg) for MillerKnoll, Inc.

Companies: MillerKnoll, Inc.

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