US court finds trademark infringement but denies brand owner damages

A Louisiana federal court found that a former employee’s use of an educational organization’s logo infringed its trademark, but denied monetary relief and an injunction after finding insufficient evidence of harm attributable to the infringement.

A federal court in Louisiana has found that Associated Professional Educators of Louisiana (A+PEL) established trademark infringement under the Lanham Act, but denied monetary relief and injunctive relief against competing educational-services business EDU20/20 LLC and its co-founders.

In a memorandum ruling dated October 14, 2026, US District Judge Terry A. Doughty granted A+PEL’s motion for summary judgment on liability, finding that the defendants’ use of its logo created a likelihood of confusion. The court also granted the defendants’ motion for summary judgment on the remedies available under the Lanham Act, concluding that A+PEL had not established entitlement to damages, an accounting of profits, or an injunction.

The decision in Associated Professional Educators of Louisiana v. EDU20/20 LLC, No. 1:22-cv-05720, highlights an important distinction in trademark litigation: establishing infringement does not automatically entitle a brand owner to financial compensation or injunctive relief.

Former employee’s use of the logo

A+PEL began operating under its trade name in 1984 and developed a logo in 2013. The organization provides training and certification programs for educators and school districts.

Miranda Britt joined A+PEL in 2014 and was later promoted to deputy director. While still employed by A+PEL, she co-founded EDU20/20 with Courtney Dumas in March 2015. The competing business also provided professional development, teacher training, and coaching services to schools and educators in Louisiana.

The dispute centered on Britt’s use of A+PEL’s logo alongside EDU20/20’s branding in four presentations, including sessions at the 2021 Teacher Leader Summit and presentations for local educational organizations.

The logo appeared on biographical slides introducing Britt. In three of the four presentations, it was displayed next to EDU20/20’s logo.

A+PEL argued that the use of its logo suggested an affiliation between the organizations or implied that it endorsed EDU20/20. The court agreed that the circumstances created a likelihood of confusion, emphasizing that Britt had used A+PEL’s actual logo in a context that could lead viewers to infer an organizational relationship.

The court therefore found that A+PEL had established liability under the Lanham Act. Its ruling addressed the use of the logo in the presentations, rather than establishing that every aspect of EDU20/20’s business infringed A+PEL’s trademark.

Why the court denied monetary relief

A+PEL argued that EDU20/20 had benefited commercially from the unauthorized use of its logo. Among the evidence it cited were contracts and business opportunities involving the West Feliciana Parish School District and Washington Parish School District, as well as interest generated following presentations at the Teacher Leader Summit.

The court concluded, however, that the evidence did not adequately connect EDU20/20’s sales to the infringement itself. To establish the relevant connection, A+PEL needed to show that EDU20/20 secured contracts that would otherwise have gone to A+PEL and that confusion caused by the use of the logo was responsible for that diversion.

The court found that the evidence did not establish this causal chain. Although the presentations generated interest in EDU20/20’s services, that interest could have resulted from other factors, including Britt’s professional relationships and the content of the presentations.

The court declined to infer that the logo’s appearance on a single slide was responsible for the subsequent business. It therefore rejected A+PEL’s claim for monetary damages and an accounting of EDU20/20’s profits under the Lanham Act.

The ruling did not establish that no business was diverted. Rather, it found insufficient evidence that the sales at issue were attributable to the trademark infringement.

No injunction despite a finding of infringement

The court also refused to grant injunctive relief. Under the Trademark Modernization Act of 2020, a finding of infringement gives a plaintiff a rebuttable presumption of irreparable harm when seeking an injunction under the Lanham Act. The court recognized that presumption but concluded that A+PEL had not demonstrated sufficient injury arising from the logo use.

A key consideration was that the circumstances giving rise to the confusion had ceased to exist. Britt’s concurrent employment with A+PEL and involvement with EDU20/20 had ended, removing the conditions that had enabled the disputed use of the logo.

The court also found that A+PEL had not adequately demonstrated harm to its brand reputation or goodwill that would justify an injunction. It concluded that the defendants had overcome the presumption of irreparable harm and that injunctive relief was not warranted.

Lessons for trademark practitioners

The ruling illustrates why brand owners should develop evidence supporting both infringement and the remedies they seek. Evidence that consumers or prospective customers are likely to be confused can establish liability. But a claim for monetary compensation requires a sufficient evidentiary basis for the requested award, including a connection between the infringement and the claimed loss where that connection is legally required.

For businesses seeking to recover damages or an infringer’s profits, relevant evidence may include customer communications, purchasing decisions, lost-business records and testimony explaining how the challenged use influenced commercial decisions.

The decision also demonstrates that injunctive relief requires a separate analysis. Even where infringement is established, and a presumption of irreparable harm applies, the court may refuse an injunction if the evidence shows that the circumstances giving rise to the infringement and confusion have ceased.

Background and next steps

The case returned to the district court after the US Court of Appeals for the Fifth Circuit vacated the earlier dismissal of A+PEL’s Lanham Act claim in February 2026. The appellate court had found a genuine dispute of material fact concerning whether Britt’s use of the logo created a likelihood of confusion.

Following the remand, the district court reconsidered liability and remedies. Its October 14 ruling resolved the Lanham Act liability issue in A+PEL’s favor but denied the relief it sought.

The court also declined to exercise supplemental jurisdiction over A+PEL’s remaining Louisiana state-law claims, including claims relating to unfair trade practices, breach of fiduciary duty, and civil conspiracy. Those claims were dismissed without prejudice for lack of jurisdiction, meaning the court did not resolve their merits in this ruling.

Source: Associated Professional Educators of Louisiana v. EDU20/20 LLC, No. 1:22-cv-05720 — October 14, 2026 memorandum ruling.

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