A recent federal court ruling in a case involving adidas draws renewed attention to the pleading requirements underlying Section 1114 trademark infringement and counterfeiting claims involving soccer merch amid the World Cup 2026 frenzy. In a newly issued decision, a federal court in Oregon dismissed – with leave to amend – certain claims that adidas lodged against Hall of Fame Sports Memorabilia Inc., holding that the company failed to plead which federally registered marks formed the basis of its Section 1114 claims in connection with allegedly “knockoff” Real Madrid and Argentina jerseys.
The Case in Brief: Adidas filed its trademark infringement, counterfeiting, and unfair competition suit against Hall of Fame Sports Memorabilia Inc. in 2024, accusing the retailer of selling unauthorized Real Madrid and Argentina soccer jerseys bearing imitations of its famous Three-Stripe branding. New Jersey-based Hall of Fame moved to dismiss portions of the complaint, contending that adidas failed to adequately identify the specific federally registered trademarks underlying its infringement and counterfeiting claims.
The Court’s Core Holding
In her May 18 ruling, Judge Karin J. Immergut of the U.S. District Court for the District of Oregon emphasized that trademark infringement and counterfeiting claims under Section 1114 of the Lanham Act apply only to “registered marks” and require plaintiffs to identify the federally registered trademarks allegedly infringed. Here, adidas relied on its signature “Three-Stripe Mark,” which it described as “a unitary branding device” tied to multiple registrations.
The court pushed back, stating that while adidas “very well may” possess viable claims under Section 1114, the company failed to connect the allegedly infringing jerseys to any particular registered marks identified in its complaint. More specifically, the opinion distinguished between adidas’ reliance on the broader Three-Stripe Mark and the statutory requirement that Section 1114 claims identify the particular federally registered marks allegedly infringed.
> The ruling does not invalidate adidas’ Three-Stripe branding rights or dispose of the case altogether, as the court granted adidas leave to amend its complaint and replead the claims using specific trademark registrations.
Ultimately, the latest round of the case highlights a recurring issue in design-mark and trade dress litigation: the distinction between overarching commercial branding concepts and the specific federally registered marks required to adequately plead Section 1114 claims. While apparel companies increasingly seek protection for recurring visual signifiers associated with their brands, federal counterfeiting claims remain tied to registered marks.
That tension is especially pronounced in athletic apparel, where brand recognition frequently operates through simplified and highly repetitive visual elements.
THE BOTTOM LINE: The decision may prove more significant for what it signals about Section 1114 pleading requirements than for its immediate outcome. As soccer jerseys increasingly function as both athletic merchandise and fashion goods (and are subject to increased infringement ahead of the World Cup), trademark disputes are centering less on standalone logos and more on combinations of recurring design elements associated with particular brands. At minimum, the opinion underscores the importance of tying broader branding concepts to specific federally registered marks when pleading Section 1114 claims.
The case is Adidas America, Inc. v. Hall of Fame Sports Memorabilia, Inc., 3:24-cv-02120 (D. Or.).
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