A recent TTAB decision shows that clothing and entertainment services may be related for trademark purposes, even when they are not directly competitive. This article explains how the Board analyzes relatedness, why small wording changes may not avoid confusion, and what brand owners should consider before adopting or expanding a trademark.

Are Personal Training Services Related to Clothing for Trademark Purposes? As more fitness-focused ecommerce brands expand into branded apparel and digital content, trademark applicants often find themselves navigating complex questions about whether their goods and services are “related” for purposes of trademark registration.

This case is a reminder that trademark law doesn’t require two products to be the same—or even competitive—for confusion in the marketplace to occur. It’s enough if the products are related in a way that creates a plausible impression of common origin in the mind of the consumer. In other words, relatedness isn’t just about the products themselves—it’s about how, where, and to whom they are sold.

Ultimately, this decision reminds trademark owners that even identical marks are not enough to win a Section 2(d) claim without evidence showing the real-world relationship between the goods or services. The Board emphasized that each case rests on its own record and that assumptions about what “might” be related won’t suffice. This decision underscores several important trademark law doctrines, including the related goods doctrine, the natural zone of expansion, and how third-party evidence is weighed in establishing relatedness.

The central issue revolved around the likelihood of confusion between MetaBev’s application to register the trademark “CHILL” for hard seltzer and several pre-existing trademarks owned by Molson Coors Beverage Company USA LLC and Chillfizz Beverage LLC. These existing trademarks also featured the term “CHILL” and were used for beer and hard seltzer.