Editor’s note: The lawsuit described below was dismissed in 2024 without a decision on whether Louisiana Christian University’s use of “LCU” infringed Lubbock Christian University’s trademark.

Two Christian universities in neighboring states became involved in a federal legal dispute over three letters: LCU.

Louisiana College, which operates under the name Louisiana Christian University, sued Lubbock Christian University in July 2023. The Louisiana institution asked a federal judge to declare that its use of the initials “LCU” did not infringe the Texas university’s trademark rights.

The case was filed in the U.S. District Court for the Western District of Louisiana after several months of unsuccessful discussions between the universities.

How the dispute began

Lubbock Christian University says it began using the LCU name after becoming a university in 1987. The school subsequently obtained federal trademark protection for a stylized logo containing the three letters.

A trademark filing associated with Lubbock Christian University describes a design in which the letters “L” and “U” are placed over a larger “C.” The registration covers educational services, university courses, athletic events and related activities.

Louisiana College, founded in 1906, registered “Louisiana Christian University” as a trade name with the Louisiana Secretary of State in November 2021. Although Louisiana College remained its legal name, students, employees and members of the public began shortening its new operating name to LCU.

Lubbock Christian learned about the Louisiana school’s use of the initials in 2022. Its president, Scott McDowell, contacted then-Louisiana Christian President Rick Brewer and asserted that the new branding encroached on the Texas institution’s protected trademark.

According to the Louisiana school’s federal complaint, the institutions exchanged letters and held informal discussions during the following months but did not reach an agreement.

Louisiana Christian rejected a proposal to use “LC,” the abbreviation associated with its former Louisiana College name. It said it had already invested substantially in its new identity and believed its use of LCU was legally permissible.

Louisiana Christian’s argument

Louisiana Christian did not accuse the Texas university of trademark infringement. Instead, it sought a declaratory judgment establishing that the two schools could use the same initials without violating federal law.

The Louisiana institution argued that trademark infringement depends primarily on whether consumers are likely to become confused about the source, sponsorship or affiliation of particular goods or services.

Its complaint highlighted several differences between the schools:

• The universities operate in different states.
• Their logos use different designs and colors.
• Louisiana Christian commonly displays its full name alongside LCU.
• The universities have different religious affiliations.
• Their athletic teams compete in different collegiate organizations.
• Prospective college students typically conduct substantial research before choosing a university.

Louisiana Christian also identified other universities, businesses and organizations using the same initials. It contended that the number of third-party users weakened any claim that one institution could control every use of the letters LCU.

The lawsuit focused on the abbreviation rather than an allegation that Louisiana Christian had copied Lubbock Christian’s precise interlocking logo.

Lubbock Christian seeks dismissal

Lubbock Christian responded by asking the Louisiana federal court to dismiss the case for lack of personal jurisdiction.

In its motion to dismiss, the Texas university argued that it was incorporated and headquartered in Texas and lacked sufficient business connections with Louisiana to be sued there.

Lubbock Christian said that sending letters and participating in telephone discussions about possible infringement did not establish the minimum contacts required for a Louisiana court to exercise jurisdiction over it.

The university characterized the lawsuit as a race to the courthouse. Louisiana Christian filed the case on July 13, 2023, less than a week after a telephone discussion during which Lubbock Christian allegedly warned that it was prepared to defend its trademark.

At that point, Lubbock Christian had not filed its own infringement lawsuit. Its court response addressed whether the Louisiana court had authority over the Texas institution rather than whether Louisiana Christian’s branding actually infringed the trademark.

In a statement reported by Lubbock Lights, Lubbock Christian said it regretted the escalation, had attempted to find a negotiated solution and remained prepared to protect its intellectual property.

Court dismisses the Louisiana case

A federal magistrate judge ultimately agreed that Louisiana Christian had not established adequate jurisdiction over Lubbock Christian.

In an April 2024 recommendation, the court concluded that Lubbock Christian was not essentially “at home” in Louisiana and had not directed enough activity toward the state to establish specific jurisdiction. Its registration to conduct business in Louisiana, limited remote employees and cease-and-desist correspondence were insufficient.

The court recommended granting Lubbock Christian’s motion and dismissing Louisiana Christian’s complaint without prejudice. The federal docket identifies the case as terminated on August 16, 2024.

The dismissal did not determine which institution had the stronger claim to the initials. It also did not establish that Louisiana Christian infringed—or did not infringe—Lubbock Christian’s trademark.

Instead, the case ended because the Louisiana court lacked authority over the Texas university. A dismissal without prejudice generally leaves open the possibility of another case being filed in a court with proper jurisdiction, although the available public docket does not show that this lawsuit produced a final ruling on the underlying trademark dispute.