The latest round of a high-stakes clash between Louis Vuitton and Van Cleef & Arpels over their respective jewelry collections brought a win for Louis Vuitton. In a decision on March 5, the French Court of Cassation’s Commercial, Financial, and Economic Chamber ruled in favor of Louis Vuitton, rejecting an appeal filed by Van Cleef & Arpels owner Richemont International in a case alleging parasitic competition. The Court of Cassation’s ruling affirms an earlier decision from the Paris Court of Appeal, which dismissed Richemont’s claims that Louis Vuitton unfairly capitalized on Van Cleef & Arpels’s iconic Alhambra motif by way of its Color Blossom jewelry collection.
A Bit of Background: Richemont filed suit against Louis Vuitton back in 2017, claiming that the LVMH-owned brand has sought to “free ride” on the reputation, investments, or creative efforts of Van Cleef & Arpels. Specifically, Richemont takes issue with the Color Blossom collection that Louis Vuitton introduced in 2015, which it claims bears striking similarities to Van Cleef & Arpels’s almost-60-year-old Alhambra range.
Richemont alleged that Louis Vuitton’s infringing collection consists of a four-sided floral design set in a metal frame and semi-precious stones that mirror its Alhambra clover design (below, right). Beyond that, Louis Vuitton’s Color Blossom (below, left) pricing structure resembles that of Alhambra, per Richemont, and its marketing strategy blurs the distinction between the two brands.
Against this background, Richemont sought an order from the court to block Louis Vuitton’s manufacture and sale of thirty-one different jewelry pieces; it also requested €15 million in damages and a public announcement on Louis Vuitton’s website acknowledging the ruling.
In its defense, Louis Vuitton argued that it has long made use – and maintains trademark registrations for – its own clover design on jewelry, and that the design is inspired by its iconic toile monogram. At the same time, Louis Vuitton sought to chip away at the strength of Van Cleef & Arpels’s rights in the coveted Alhambra design, maintaining that floral designs, including four-round-petal designs, are widely used by other jewelry companies and that such use is in line with prevailing market trends and common industry practices.
A Big Win for Louis Vuitton
In its decision on March 5, as first reported by TFL, the Court of Cassation upheld the Paris Court of Appeals’ June 2023 ruling, which rejected Richemont’s claims of parasitic competition. Delving into the parties’ respective claims, the Court of Cassation found that Richemont fell short in establishing parasitic intent on the part of Louis Vuitton. (Under French law, parasitism requires proof that an entity deliberately placed itself “in the wake” of a competitor to benefit from its reputation or investments. This means that a mere resemblance between products is insufficient – the plaintiff must demonstrate intentional and unfair exploitation by a competitor.)
Specifically, the court held that …
> No Exclusive Ownership of the Quatrefoil Motif: The four-sided floral design is not unique to Van Cleef & Arpels. The court highlighted that Louis Vuitton has used a similar motif in its Monogram canvas since 1896 and that the Color Blossom collection is a natural extension of Louis Vuitton’s existing design language rather than an attempt to imitate Van Cleef & Arpels’s Alhambra collection.
> Design Differences: While both parties’ collections feature floral motifs with semi-precious stones, Vuitton’s Color Blossom collection includes distinct design modifications, according to the court.
> Market Trends and Industry Practices Justify the Overlap: The court found that semi-precious stones set in precious metals were common in high-end jewelry. Many luxury houses have used similar floral motifs, thereby, reinforcing the notion that the Color Blossom design is part of a broader market trend rather than an attempt to copy Alhambra.
> Lack of Intent to Exploit: The court found no evidence that Vuitton’s collection is a strategic attempt to confuse consumers or piggyback on Van Cleef & Arpels’s brand. Instead, it held that Vuitton has simply expanded its monogram flower motif into fine jewelry, a move consistent with its broader brand evolution.
With the foregoing in mind, the Court of Cassation rejected Richemont’s appeal and upheld the Paris Court of Appeal’s decision, dismissing the luxury goods giant’s claims of parasitic competition against Louis Vuitton. In doing so, the court denied Richemont’s request for a sales ban on 31 Louis Vuitton jewelry pieces and rejected its bid for €15 million in damages.
A Few Takeaways: The court’s decision is noteworthy in that it reaffirms the requirements for successfully claiming parasitism, namely, the burden on the filing-party to show intentional exploitation of its reputation by a competitor. Beyond that, the ruling also appears to limit the extent to which even very-well-known brands can claim exclusive rights over common design elements, with the court confirming that widely used motifs, such as quatrefoil clovers, cannot be monopolized. And still yet, the decision strengthens the protections that exist for brands around product expansion (akin to the zone of natural expansion in the U.S. to some extent), thereby, allowing that companies to expand upon existing designs without facing legal restrictions.
The case is Société Cartier v. Louis Vuitton Malletier, 05/03/25, n°23-21.157 (Cass. Com.).
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