The Board found that “the word CALIFORNIA is a prominent part of applicant’s mark and is not overshadowed by either the word INNOVATIONS or the design element.” Although the mark may also convey the idea of a creative, laid-back lifestyle or mindset, the Board properly recognized that such an association does not contradict the primary geographic significance of the mark. Even if the public may associate California with a particular life-style, the record supports the Board’s finding that the primary meaning remains focused on the state of California.
—In re Cal. Innovations, Inc., 329 F.3d 1334 (Fed. Cir. 2003) (Rader, C.J.), remanding a decision by the Trademark Trial and Appeal Board holding that the mark “California Innovations, Inc.” was primarily geographically deceptively misdescriptive when used by a Canadian-based corporation
Sometimes, a California is just a California.