This article discusses the US Court of Appeals for the Second Circuit's recent ruling in Guthrie Healthcare System v Context-Media, Inc. regarding the proper geographic scope of injunction in a trademark infringement case. The Court held that while it is correct that the senior user of a mark must prove a probability of confusion in order to obtain injunctive relief, such injunctive relief should not only extend to those geographic areas for which a probability of confusion has been shown.

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