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Blastoff, a corporation in the business of creating and marketing cartoon characters, filed a trademark application to register the mark "St Louis Rams" as the Rams, an NFL football club, were preparing to move from Los Angeles to St. Louis.

In response, the Rams sued Blastoff and moved for summary judgment arguing, among other issues, that the team had acquired rights to the "St. Louis Rams" mark prior to Blastoff and that registration of Blastoff's marks would result in confusion with the Rams' marks. The district court granted the Rams' motion for summary judgment, which was affirmed by the Seventh Circuit.

On appeal, the Seventh Circuit concluded that the Rams had established protectable rights in its trademark. The court analogized the Rams' situation to that of the Indianapolis Colts, observing that the move of the Colts from Baltimore did not break the continuity of the team's name, or allow a third party to use its name. The Rams demonstrated both prior adoption of the mark and "use in a way sufficiently public to identify or distinguish the marked goods in an appropriate segment of the public mind as those of [the adopter of the mark]."

The court also upheld the lower court's finding that the Blastoff marks would likely cause confusion with those of the Rams. As the court explained, whether there is a likelihood of confusion is a "question of fact as to the actual actions and reactions of prospective purchasers of the goods and services of the parties." The court relied on a seven factor test in determining whether a likelihood of confusion exists, while acknowledging that their relative importance must be judged on a case-by-case basis. The "keystone" of this analysis is likelihood of confusion as to affiliation, source, connection or sponsorship of goods and services among the relevant class of customers. Usually such confusion is "forward confusion," which occurs "when customers mistakenly think that the junior user's goods or services are from the same source or are connected with the senior user's goods or services."

However, in this case Blastoff relied on the doctrine of "reverse confusion," in which a large junior user saturates the market with a similar trademark to the senior user. Although the junior user does not seek to profit from the senior user's mark, the senior user is still injured because the public believes that there is some connection between the two. The court made clear that such a claim could not work as Blastoff was not such a senior user, and he had no protectable rights in the marks.

Blastoff argued that, because the Colorado State college football team also uses the name Rams, the Rams mark is generic and the Rams NFL team had lost an exclusive right to use the mark. As the court explained, a term may be considered generic if it is commonly used to designate a kind of goods or represents common linguistic usage for such goods. In this case, the Rams mark is used to designate a team playing professional football and there are no other teams with the same name. Thus, the Rams mark is not the generic name of a professional football team.

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