A Fight Over the Four-Leaf Clover: Louis Vuitton Ends up the Lucky One
Katarina Mazzanobile
May 8
4 min read
Louis Vuitton's Blossom Collection (left) and Van Cleef & Arpels' Alhambra Collection (right)
A four-leaf clover may seem like a simple design; however, for Van Cleef & Arpels, this symbol has been a defining feature of its brand since 1968.[1] For over fifty-five years, Van Cleef & Arpels has sold the handcrafted, intricate, and unique design of its Alhambra collection.[2] Jacques Arpels, the nephew of Van Cleef’s founder, would gather four-leaf clovers from his garden, believing in their lucky significance, which became the inspiration for Van Cleef & Arpels’ most famous collection, the Alhambra collection.[3] From 2012 to 2016, Louis Vuitton (“LV”) introduced a new jewelry collection called “Blossom,” which featured a four-leaf clover design similar to Van Cleef & Arpels’.[4]
As a result, in 2017, Van Cleef brought suit against Louis Vuitton, alleging that LV attempted to “free ride” off the reputation and creative efforts of the Alhambra collection.[5] Like the Alhambra collection, the Blossom collection also had three different-sized jewelry pieces and used similar colors for the semi-precious stones.[6] In the Paris Commercial Court, LV was found liable and banned from selling the Blossom line.[7] However, in June 2023, the Paris Court of Appeals dismissed Van Cleef’s claims of parasitic competition—a ruling that was ultimately upheld by France’s highest court, the Court of Cassation, on March 5, 2025, marking a definitive victory for Louis Vuitton.[8] On appeal, Louis Vuitton argued that it maintains trademark registrations for the clover design, which was inspired by its signature monogram design.[9] Furthermore, Louis Vuitton argued many other companies use this floral design, as it is in line with market trends.[10]
The Court of Cassation held that because Van Cleef was unable to prove any parasitic intent on LV’s part, and the mere resemblance of the two products was insufficient, LV could not be held liable for free riding and parasitic intent.[11] Parasitic intent requires unfair exploitation by a competitor, which includes inserting oneself in a competitor’s market to profit off their reputation.[12] Here, both LV and Van Cleef are high-end luxury brands that create jewelry.[13] From a consumer perspective, the court discussed that it was clear LV did not intend to free-ride off Van Cleef & Arpels’ brand but rather expand its extremely successful monogram collection into a jewelry piece.[14] The court also found no likelihood of confusion between the Blossom and the Alhambra collections.[15]
This decision is significant as it provides insights for luxury brands navigating product expansion, highlighting that proving intent plays a pivotal role in parasitic competition claims.[16] Mere similarities in design will not win in court.[17] Furthermore, this decision is vital for brands considering product expansion.[18] When a company expands its products, this can lead to increased exposure to intellectual property lawsuits, which in turn can lead to fines, lawsuits, and damage to a brand’s reputation.[19] During expansion, brands should first consider clearly differentiating new collections.[20] Like how Louis Vuitton tied its Blossom collection to its historic monogram design, brands should emphasize their own style, values, and heritage when expanding.[21] Furthermore, brands should keep accurate records relating to product development.[22] Documenting the evolution of a trademark, including the creative process and dates, can help prove originality.[23] Finally, another consideration when brands expand is to consistently monitor competitor activities.[24] Proactively addressing potential trademark disputes can minimize the risk of costly litigation.[25]
This case also emphasizes the importance of maintaining free market competition and preventing monopolies.[26] If Van Cleef were the only brand allowed to create the four-leaf clover motif, this could drive up prices as well as lower quality.[27] In the absence of competition in the luxury jewelry market, brands could inflate prices and neglect to innovate their products without fear of losing business.[28] Ultimately, this decision serves as a reminder to luxury brands that while protecting creative expression is essential, healthy competition and innovation in the luxury industry are also vital for consumer choice and brand expansion.[29]
[8]See Société Cartier v. Louis Vuitton Malletier, Cour de cassation [Cass.][supreme court for judicial matters] com., Mar. 5, 2025, Bull. civ. IV, No. 23-21.157 (Fr.); see alsoJewelry Fight, supra note 5.
[17]See id.; see also Han Stanton & Jared Bryant, Safeguarding Style: An Examination of Brand Protection in the Fashion and Luxury Industry 39, World Trademark Rev.: Special Reports, (2023) (noting “major brands do not necessarily have a monopoly on certain signs” in discussing a similar dispute between adidas and Thom Browne over the use of stripes in the companies’ branding).
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