The U.S. Court of Appeals for the Seventh Circuit reversed a lower court's preliminary injunction against Little Caesars in a trademark dispute with Illinois Tamale Company over food product naming rights, according to a Jan. 16, 2026 ruling.
The court held that Illinois Tamale Company, doing business as Iltaco, failed to demonstrate a sufficient likelihood of success on the merits of its trademark infringement claim regarding the term "Pizza Puff." However, the appeals court affirmed the district court's denial of injunctive relief for the terms "Crazy Puff" and "Puff."
Iltaco, a Chicago-based food company founded in 1927, brought the trademark infringement action against LC Trademarks Inc. and Little Caesar Enterprises Inc. The dispute centered on Little Caesars' "Crazy Puffs" food product and associated advertising materials.
The case stems from Iltaco's long history with pizza puff products. The company began selling its signature pizza puff in 1976, describing it as similar to a calzone but made from a flour tortilla wrapped around pizza toppings that can be either fried or baked. Iltaco has since expanded its pizza puff sales nationwide and claims trademark protection over the "Pizza Puff" designation.
Iltaco argued that Little Caesars' Crazy Puffs product and advertising campaign created a substantial likelihood of consumer confusion with its trademark-protected Pizza Puff product. The company sought a preliminary injunction to prevent Little Caesars from using "Crazy Puff," "Pizza Puff," and "Puff" in its product names and promotional materials.
The U.S. District Court for the Northern District of Illinois, Eastern Division, under Judge Jeremy C. Daniel, initially granted partial relief to Iltaco. The district court denied the preliminary injunction request regarding "Crazy Puff" and "Puff," finding Iltaco had not demonstrated sufficient likelihood of success on its trademark infringement claims for those terms. However, the trial court granted the preliminary injunction specifically for "Pizza Puff."
Little Caesars appealed the district court's decision to grant injunctive relief for "Pizza Puff," while Iltaco cross-appealed the denial of its broader injunction request. The case was argued before the Seventh Circuit on Nov. 14, 2025.
The three-judge panel, consisting of Circuit Judges Scudder, St. Eve, and Jackson-Akiwumi, unanimously ruled in favor of Little Caesars on the primary appeal. Circuit Judge St. Eve authored the opinion for the court.
The Seventh Circuit found that the district court erred in its analysis of Iltaco's likelihood of success on the trademark infringement claim pertaining to "Pizza Puff." The appeals court determined that Iltaco had not met the standard required for preliminary injunctive relief, which requires plaintiffs to demonstrate they are likely to succeed on the merits of their underlying claims.
In trademark infringement cases, courts typically analyze several factors to determine likelihood of confusion, including the similarity of the marks, the similarity of the products, the area and manner of concurrent use, the degree of care likely to be exercised by consumers, the strength of the plaintiff's mark, and evidence of actual confusion.
The ruling represents a significant victory for Little Caesars, allowing the pizza chain to continue using "Pizza Puff" in its marketing materials without restriction. The decision also affirms the district court's earlier ruling that permitted Little Caesars to use "Crazy Puff" and "Puff" in its advertising.
For Iltaco, the ruling means the company cannot prevent Little Caesars from using terminology that Iltaco considers confusingly similar to its trademarked product name. The Chicago-based company, which has been operating for nearly a century, must now rely on other legal strategies if it wishes to protect what it views as its trademark rights.
The case highlights the complexities of trademark law in the food industry, where similar descriptive terms may be used by multiple companies to market comparable products. The ruling suggests that companies seeking trademark protection must meet high evidentiary standards when attempting to restrict competitors' use of potentially overlapping terminology.
The decision affects both companies' marketing strategies going forward. Little Caesars can continue its current advertising approach for Crazy Puffs products, while Iltaco may need to strengthen its trademark protection efforts through alternative legal avenues.
The case was consolidated under docket numbers 24-3317, 25-1072, 25-1076, and 25-1112, reflecting multiple related appeals stemming from the original district court proceedings. The underlying district court case was filed as No. 1:24-cv-05210.
This ruling adds to the body of Seventh Circuit precedent regarding trademark disputes in the food service industry and establishes important guidelines for preliminary injunction standards in trademark infringement cases involving descriptive product terminology.