Order — ECF No. 100
Filed 21 April 2026 · 3 pages
Order, ECF No. 100, MEDDICC Ltd v. 01 Consulting LLC, Case No. 2:24-cv-01836-WB (PDF)
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A US federal court has held that MEDDPICC is a generic term, which cannot receive trademark protection. On 21 April 2026, Chief Judge Wendy Beetlestone of the US District Court for the Eastern District of Pennsylvania ordered the USPTO to cancel U.S. Trademark Registration No. 6,489,058 for MEDDPICC under 15 U.S.C. § 1119, finding the term generic.
On 21 April 2026, the Honourable Wendy Beetlestone, Chief Judge of the United States District Court for the Eastern District of Pennsylvania issued a summary-judgment ruling in MEDDICC Ltd v. 01 Consulting LLC d/b/a MEDDIC Academy and Darius Lahoutifard. The court’s Order and accompanying Opinion are reproduced in full below.
Quoted verbatim. Page references are to the Opinion’s page numbering.
“Coined in 2005, ‘MEDDPICC’ represents a multi-step framework used by sales professionals to evaluate, manage, and ideally win business. Defendant Darius Lahoutifard was not involved in MEDDPICC’s conception. Nevertheless, sixteen years after its genesis, he federally registered the term as his trademark.”
Opinion, ECF No. 99, p. 1
“A reasonable jury could find that sales professionals primarily understand MEDDPICC to name a sales qualification methodology. As explained above, that conclusion aligns with Lahoutifard’s own understanding of the term; he ‘do[es] not dispute that MEDDPICC has been used to describe a sales methodology since it was coined.’”
Opinion, ECF No. 99, p. 25
“Plaintiff’s evidence indicates that MEDDPICC is a generic name for a ‘good’ (i.e., a sales qualification methodology). Under the first principle, that evidence then also establishes that MEDDPICC is a generic name for MEDDPICC-focused training services and content. Then, under the second principle—treating a genus and one of its sub-genera equivalently—the evidence is also deemed to establish that MEDDPICC is a generic name for the genus of business education services and content, as well as for a MEDDPICC-specific sub-genus.”
Opinion, ECF No. 99, p. 28
“Little, if any, part of it demonstrates use of MEDDPICC in a trademark sense, let alone provides a sufficient basis for a jury to conclude that the relevant consuming public primarily understands MEDDPICC to name a producer. Accordingly, a jury ‘would be compelled to find,’ El, 479 F.3d at 238, that MEDDPICC is a generic term for business education services and content.”
Opinion, ECF No. 99, p. 31
“If a term is generic, then it cannot receive trademark protections, even if it has acquired secondary meaning.”
Opinion, ECF No. 99, p. 31 n.14
“Cancellation is appropriate where, as here, a term is found to be generic. See 15 U.S.C. § 1064(3) … Plaintiff is therefore entitled to its request for declaratory relief ordering cancellation of Lahoutifard’s mark on the principal register.”
Opinion, ECF No. 99, pp. 31–32
U.S. Trademark Registration No. 6,489,058 for MEDDPICC issued in September 2021 (Opinion, ECF No. 99, p. 4). On 21 April 2026, the United States District Court for the Eastern District of Pennsylvania held that MEDDPICC is a generic term for business education services and content and ordered the Director of the USPTO to cancel Registration No. 6,489,058 under 15 U.S.C. § 1119 (Order, ECF No. 100, ¶ 2(a)(iii)). The Opinion states that a generic term cannot receive trademark protection, even if it has acquired secondary meaning (Opinion, ECF No. 99, p. 31 n.14).
The court held that MEDDPICC is a generic term for business education services and content because its primary significance to sales professionals is to name a type of sales qualification methodology (Opinion, ECF No. 99, pp. 28, 31). On that basis it entered a declaratory judgment of non-infringement in favor of MEDDICC Ltd, dismissed the defendants’ counterclaims with prejudice, and ordered the USPTO to cancel U.S. Trademark Registration No. 6,489,058 (Order, ECF No. 100, ¶ 2(a)).
The court found that MEDDPICC is a generic term: the relevant public, sales professionals, primarily understands it to name a sales qualification methodology rather than any single producer (Opinion, ECF No. 99, pp. 28, 31). The Opinion explains that generic terms are categorically ineligible for trademark protection (Opinion, ECF No. 99, p. 19).
The ruling does not identify any organization as the owner or official source of MEDDPICC. The court found that the evidence did not provide a basis to conclude that the relevant public primarily understands MEDDPICC to name a producer (Opinion, ECF No. 99, p. 31), held the term generic, and ordered U.S. Trademark Registration No. 6,489,058 cancelled (Order, ECF No. 100, ¶ 2(a)(iii)).
The Opinion states that MEDDPICC was coined in 2005 and represents a multi-step framework used by sales professionals to evaluate, manage, and ideally win business. It also states that Defendant Darius Lahoutifard was not involved in MEDDPICC’s conception and federally registered the term sixteen years later (Opinion, ECF No. 99, p. 1).
The full Order (ECF No. 100, 3 pages) and the full Opinion (ECF No. 99, 33 pages) are published below. Both are public records from the docket in Case No. 2:24-cv-01836-WB, United States District Court for the Eastern District of Pennsylvania, available through PACER.
Order — ECF No. 100
Filed 21 April 2026 · 3 pages
Order, ECF No. 100, MEDDICC Ltd v. 01 Consulting LLC, Case No. 2:24-cv-01836-WB (PDF)
Opinion — ECF No. 99
Filed 21 April 2026 · 33 pages
Opinion, ECF No. 99, MEDDICC Ltd v. 01 Consulting LLC, Case No. 2:24-cv-01836-WB (PDF)
The documents published on this page are public court records obtained from the docket in MEDDICC Ltd v. 01 Consulting LLC, et al., Case No. 2:24-cv-01836-WB, United States District Court for the Eastern District of Pennsylvania.
Certain claims in this action remain pending before the court. This page will be updated as further rulings are entered.
Last updated: . Published by MEDDICC Ltd, the plaintiff in this action.