IP Law Daily, TRADEMARK—D. Md.: MADDIS mark dispute proceeds to trial on Lanham Act claims, copyright and contract claims dismissed, (Apr 6, 2026)

By Ravindra Kumar Singh, B.L.

Genuine disputes over use in commerce and likelihood of confusion precluded summary judgment on the trademark claim.

A federal district court in Maryland has granted in part and denied in part cross-motions for summary judgment in a dispute concerning the use of the term “MADDIS,” allowing the Lanham Act trademark claim to proceed to trial while dismissing the plaintiff’s unjust enrichment/joint copyright and breach of implied-in-fact contract claims. The court held that genuine disputes of material fact existed as to whether the plaintiff used the mark in commerce and whether the defendant’s conduct created a likelihood of confusion. However, it found no evidence that the plaintiff conferred a cognizable benefit on the defendant or that the parties reached a sufficiently definite agreement to support a contract claim (Titan Systems, LLC v. SRI International, No. 8:24-cv-01286-LKG (D. Md. Mar. 31, 2026)).

Background. The plaintiff, Titan Systems, LLC, is a Maryland-based company providing custom design and integration support for military systems and vehicle applications. The defendant, SRI International, is a California-based nonprofit research institute engaged in national security and advanced systems work, frequently acting as a prime contractor or subcontractor on government-funded projects. The parties had a prior working relationship, including a subcontract and a mutual nondisclosure agreement, and collaborated on a lobbying initiative known as the MADDIS campaign.

The dispute centered on the asserted “MADDIS” mark, short for “Multi-Agency Data Dissemination and Interoperability Services.” Titan obtained registration for “MINOTAUR MULTI AGENCY DATA DISSEMINATION AND INTEROPERABILITY SERVICES (MADDIS)” on March 4, 2025, and later applied for a second mark covering “MULTI-AGENCY DATA DISSEMINATION AND INTEROPERABILITY SERVICES (MADDIS),” claiming first use in commerce in November 2020. Titan alleged that SRI used the same or a confusingly similar designation in PowerPoint briefings presented to Congress and government officials in connection with funding efforts. The underlying materials related to a technology initiative aimed at enabling secure and coordinated data sharing across military agencies.

The dispute arose from a joint effort between the parties in late 2020 and early 2021 to promote the MADDIS concept to government stakeholders and secure congressional funding. Titan claimed that it played a central role in developing early versions of the presentation materials and that the parties had an understanding to share work and profits. It filed suit asserting claims under the Lanham Act, unjust enrichment and joint copyright, and breach of an implied-in-fact contract. SRI moved for summary judgment on all claims, arguing lack of trademark rights, the absence of a benefit conferred or an enforceable contract. Titan cross-moved for partial summary judgment on the trademark and contract claims.

Trademark claim. The court declined to grant summary judgment to either party on the Lanham Act claim under 15 U.S.C. § 1125(a)(1)(A), finding genuine disputes on key elements. Citing U.S. Search, LLC v. U.S. Search.com Inc., 300 F.3d 517 (4th Cir. 2002), the court reiterated that a plaintiff must establish a valid, protectable mark. It further relied on Int’l Bancorp, LLC v. Société des Bains de Mer, 329 F.3d 359 (4th Cir. 2003), to emphasize the requirement of use in commerce.

The central dispute concerned whether Titan had actually used the “MADDIS” mark in commerce. SRI argued that Titan’s reliance on internal emails and limited communications did not qualify as commercial use, while Titan pointed to email correspondence and website materials as evidence of interstate use. The court held that these conflicting factual assertions required resolution by a factfinder, making summary judgment inappropriate.

On likelihood of confusion, the court applied the multifactor test articulated in George & Co. LLC v. Imagination Ent. Ltd., 575 F.3d 383 (4th Cir. 2009). While SRI argued that no evidence of confusion existed, Titan identified instances where government officials allegedly misunderstood the source of the materials. The court held that these competing accounts created triable issues, particularly given that evidence of actual confusion is often paramount.

Unjust enrichment and copyright. The court granted summary judgment in favor of SRI on the unjust enrichment and joint copyright claim. Applying Maryland law as articulated in Yost v. Early, 589 A.2d 1291 (Md. Ct. Spec. App. 1991), the court held that Titan failed to establish that it conferred a benefit on SRI.

Although Titan contributed to early presentation materials, the court found that SRI independently developed the final materials presented to Congress and conducted subsequent lobbying without Titan’s involvement. It also noted that the government contracts awarded to SRI followed a separate procurement process, and Titan neither participated in proposals nor performed work under those contracts.

The court rejected Titan’s theory that its early contributions indirectly enabled SRI to secure government funding, describing the alleged connection as “too remote and tenuous.” Even assuming the existence of a joint work under the Copyright Act, the absence of a causal link between Titan’s contributions and SRI’s financial gains proved fatal to the claim.

No enforceable implied contract. The breach of implied-in-fact contract claim also failed for lack of mutual assent and definiteness. Relying on Innovations Surgery Center, P.C. v. United Healthcare Insurance Co., 722 F. Supp. 3d 582 (D. Md. 2024), the court emphasized that an enforceable contract requires a clear agreement on essential terms.

Titan argued that the parties had agreed to share work and profits, but the court found no evidence of agreed terms regarding profit-sharing percentages, scope of work, or allocation mechanisms. The alleged understanding of a “fair share” was deemed too vague to constitute a binding agreement. The court further observed that the parties’ prior dealings were memorialized in writing, indicating a customary practice of formal contracting. Titan presented no evidence that the parties intended to deviate from this practice for the MADDIS project. Accordingly, the absence of both definiteness and intent to be bound defeated the claim.

Damages. The court declined to grant summary judgment on damages under the Lanham Act, noting that such relief under 15 U.S.C. § 1117(a) depends on the outcome of the underlying trademark claim. Because material factual disputes remained, the damages issue could not be resolved at this stage.

The Case is No. 8:24-cv-01286-LKG.

Judge: Griggsby, L.

Attorneys: Megan Brenna Betts (Wilt Toikka Kraft, LLP) for Titan Systems, LLC. Deborah B. Baum (Pillsbury Winthrop Shaw Pittman LLP) for SRI International.

Companies: Titan Systems, LLC; SRI International

Cases: Trademark MarylandNews