Case Law
Campfield v. Safelite Group, Inc., 91 F.4th 407 (6th Cir. 2024)
The Auto Glass Repair and Replacement Industry’s Most Powerful Weapon
The 6th Circuit Court of Appeals Ruling in Campfield v. Safelite Group, Inc. 91 F.4th (6th Cir. 2024) gives Ultra Bond Windshield Repair retail users Binding Precedent which means Proximate Cause and Standing to sue Safelite or any other Auto Glass Competitor.
| Jurisdiction | Authority Level | Description |
|---|---|---|
| Within the 6th Circuit (KY, MI, OH, TN) | Binding Precedent | Federal district courts in these states must follow this ruling. If a similar Lanham Act case arises, the legal tests established here are the law of the land. |
| Outside the 6th Circuit (Other U.S. States) | Persuasive Authority | Courts in other circuits (e.g., the 2nd or 9th) are not required to follow it, but lawyers can cite it to "persuade" a judge to adopt the same reasoning, especially if their own circuit hasn't addressed the specific issue. |
Can the 6th Circuit Court of Appeals ruling in Ultra Bond v. Safelite be used as Case Law in other Lanham Act lawsuits?
Yes, the 6th Circuit’s ruling in Campfield v. Safelite Group, Inc., 91 F.4th 407 (6th Cir. 2024)) can indeed be used as case law in other Lanham Act lawsuits.
Because it is a published opinion from a federal appellate court, it carries significant legal weight, though its exact "power" depends on where the new lawsuit is filed.
How the Ruling Functions as Case Law
| Jurisdiction | Authority Level | Description |
|---|---|---|
| Within the 6th Circuit (KY, MI, OH, TN) | Binding Precedent | Federal district courts in these states must follow this ruling. If a similar Lanham Act case arises, the legal tests established here are the law of the land. |
| Outside the 6th Circuit (Other U.S. States) | Persuasive Authority | Courts in other circuits (e.g., the 2nd or 9th) are not required to follow it, but lawyers can cite it to "persuade" a judge to adopt the same reasoning, especially if their own circuit hasn't addressed the specific issue. |
| Circuit (Other U.S. States) | Courts in other circuits (e.g., the 2nd or 9th) are not required to follow it, but lawyers can cite it to "persuade" a judge to adopt the same reasoning, especially if their own circuit hasn't addressed the specific issue |
Can a commercial competitor in another industry besides the auto glass industry sue a competitor deceiving consumers using the Case Law from Campfield v. Safelite Group, Inc., 91 F.4th 407 (6th Cir. 2024)?
Yes, a commercial competitor in Any Industry can potentially use the case law from Campfield v. Safelite Group, Inc., 91 F.4th 407 (6th Cir. 2024) to sue for false advertising under the Lanham Act.
While the case originated in the auto glass industry, the 6th Circuit’s ruling clarified legal standards for proximate cause and standing that apply to federal Lanham Act claims across the board.
Key Legal Precedents Applicable to Other Industries
The Campfield decision is particularly useful for businesses that are not "direct" competitors but are still harmed by a rival's deception of consumers.
- Proximate Cause for Indirect Competitors: The court confirmed that a plaintiff does not have to be a direct competitor to sue. If a company's false advertising influences consumer behavior in a way that directly leads to a loss of sales for the plaintiff—even if they are a supplier to the industry—they can establish "proximate cause".
- The "Intervening Step" Rule: The ruling established that a consumer's decision (influenced by a lie) can act as an "intervening step" without making the damages too remote for a lawsuit. This allows companies to sue if they can prove a clear causal link between the lie and their economic harm.
- Laches and Injunctive Relief: The court ruled that even if a company waited a long time to sue (laches), they can still seek an injunction to stop the false advertising moving forward. This is vital for companies in any industry looking to stop ongoing deceptive practices.
Requirements for Any Commercial Competitor to Sue
To use this case law effectively, a business in any industry must still meet the standard Lanham Act requirements:
- Commercial Interest: The plaintiff must have a commercial interest in sales or reputation that was harmed.
- Economic Injury: They must show they lost money or market share because of the deception.
- Deceptive Statements: The statements must be made in "commercial advertising or promotion".
Limitations Outside the 6th Circuit
The Campfield decision is particularly useful for businesses that are not "direct" competitors but are still harmed by a rival's deception of consumers.
If the competitor is suing in a court outside of the 6th Circuit (which covers KY, MI, OH, and TN), Campfield v. Safelite is considered persuasive authority rather than binding law. Lawyers in other states can cite it to argue that their own courts should adopt the same broad view of who has the right to sue for false advertising.
Since its publication in early 2024,
Campfield v. Safelite Group, Inc. (91 F.4th 401/407) has already begun to influence federal litigation, particularly regarding
statutes of limitations and
Lanham Act causation.
While still relatively new, other courts and legal analysts have cited it to clarify the boundaries of discovery rules and how indirect competitors can prove they were harmed by false advertising.
Recent Citations and Legal Impact
- Expansion of Proximate Cause: Legal reviews have highlighted the case for "opening the door" for industry rivals to use consumer influence as a key element of proximate cause. By allowing a supplier (Ultra Bond) to sue a service provider (Safelite), the ruling is being cited as a broad application of the Supreme Court's Lexmark standard, which previously had more narrow interpretations.
- Laches and Injunctive Relief: The ruling is frequently cited for its clarification that laches (waiting too long to sue) only bars recovery for past damages. It does not prevent a company from seeking an injunction to stop the false advertising from continuing in the future.
Secondary Legal Consequences
- Insurance Contribution Disputes: The original Campfield litigation has spawned its own secondary case law regarding insurance. In 2025, a federal district court ruled that three insurance companies (ACE, Discover, and Zurich) must split the defense costs for the Safelite lawsuit equally, citing the duty to defend triggered by the original Lanham Act claims.
- Industry Standard Pressure: Industry publications note that the ruling is being used to pressure companies to adhere to ROLAGS standards, as the "dollar bill rule" (limiting repairs to six inches) was effectively challenged as potentially false advertising in a court of law.
Can any Ultra Bond retail windshield repair business in any state outside the 6th Circuit file the same Lanham Act lawsuit in Safelite's home state of Ohio and have Binding Precedent?
Yes, a retail windshield repair business from other states can file a Lanham Act lawsuit against Safelite in its home state of Ohio, and doing so would grant them the advantage of "Binding Precedent" from the Campfield v. Safelite ruling.
For Example,
here is how legal geography works in this scenario:
1. Venue: Suing in Ohio
Since Safelite Group, Inc. is headquartered in Columbus, Ohio, the U.S. District Court for the Southern District of Ohio is a proper "venue" for a lawsuit against them.
- The Utah (or other state) Connection: Under federal law, your business's location in Utah does not prevent you from filing in Ohio, provided the court has jurisdiction over the defendant (which it does, as Safelite is based there).
2. Binding Precedent (The 6th Circuit Advantage)
This is the primary reason to file in Ohio. Because Ohio is part of the 6th Circuit, the ruling in Campfield v. Safelite Group, Inc., 91 F.4th 407 (6th Cir. 2024) is binding precedent for all federal district courts in the state.
- Mandatory Follow: A judge in an Ohio federal court must follow the 6th Circuit's interpretation of the Lanham Act.
The "Utah" Difference: If you filed the same lawsuit in a Utah federal court (which is in the 10th Circuit), the Campfield ruling would only be persuasive authority. The Utah judge could read the 6th Circuit's opinion but is not legally required to follow its logic.
3. Key Protections You Inherit
By filing in Ohio, your business would immediately benefit from the specific legal "wins" established in the Campfield case:
- Proximate Cause: You can use the "1:1 relationship" theory established by the court to show that Safelite's "dollar bill rule" directly diverts customers from your repair business to their replacement services.
- Injunctive Relief: Even if your business waited a long time to sue, the 6th Circuit ruled that laches (undue delay) does not prevent you from getting an injunction to stop Safelite's false advertising immediately.
- Market Structure: The court has already acknowledged that in the auto glass market, there is "unlikely to be a more directly injured commercial victim" than a repair-only specialist harmed by false replacement claims.
| Feature | Filing in Ohio (6th Cir.) | Filing in Utah (10th Cir.) |
|---|---|---|
| Campfield Ruling | Binding Precedent (Must be followed) | Persuasive Authority (May be ignored) |
| Standing Level | Established for indirect competitors | Subject to 10th Circuit's interpretation |
| Convenience | Safelite's headquarters; easy access to records | Your home base; potential travel for Safelite |
Would you like me to find a specialized Lanham Act attorney in the Columbus, Ohio area who has experience with the Campfield case?
Finding a specialized Lanham Act attorney in Columbus, Ohio, with direct experience in the Campfield v. Safelite case is a strategic move, as these firms already understand the complex "proximate cause" and "discovery rule" precedents established in that 2024 ruling.
Based on the official court records for Campfield v. Safelite Group, Inc., the following attorneys and firms were involved in the litigation:
While the lead trial counsel is based in Washington, D.C., they worked with established Ohio-based co-counsel who have direct experience litigating this case in the Columbus district court:
Counsel for the Plaintiffs (Ultra Bond / Campfield)
- Merriman Legando Williams & Klang, LLC (Cleveland, OH):
- Drew Legando served as local Ohio counsel for the plaintiffs. This firm has direct experience navigating the specific evidence and ROLAGS industry standards used in the Campfield case. May not be available until the Campfield case is over.
- Kurt B. Olsen was the lead attorney who argued the case before the 6th Circuit. While not based in Columbus, he is the primary architect of the successful Lanham Act strategy used against Safelite. He cannot be used until the Campfield case is over.
Other Relevant Columbus-Area Firms
While not directly on the Campfield docket, these firms specialize in Lanham Act and Unfair Competition within the Columbus area:
- Standley Law Group LLP (Dublin/Columbus, OH): They specialize in unfair competition law and specifically list Lanham Act claims and deceptive business strategies as a core practice area.
- Kohl & Cook Law Firm (Columbus, OH): Focuses on the Ohio Consumer Sales Practices Act, which is the state-level equivalent for deceptive trade practices often cited alongside Lanham Act claims.
- Cotchett, Pitre & McCarthy, LLP: While not in Ohio, this firm recently secured a $31 million settlement against Safelite in 2025 regarding insurance fraud and billing practices. They represent whistleblowers and "underdogs" in commercial litigation against Safelite.
