The Seventh Circuit Court of Appeals issued a mixed ruling Thursday in a trademark infringement dispute between Illinois Tamale Company and Little Caesars, reversing part of a district court's preliminary injunction while affirming other portions of the lower court's decision.
The case centers on Illinois Tamale Company's trademark-protected 'Pizza Puff' product and Little Caesars' advertising for its 'Crazy Puffs' food item. Illinois Tamale Company, doing business as Iltaco, filed suit against LC Trademarks, Inc. and Little Caesar Enterprises, Inc., claiming the pizza chain's product and advertising created a substantial likelihood of consumer confusion with Iltaco's established trademark.
Iltaco, founded in 1927 and based in Chicago, began selling its pizza puff product in 1976. The company's pizza puff is described as similar to a calzone but made from a flour tortilla wrapped around pizza toppings that can be either fried or baked. According to court documents, Iltaco has expanded its pizza puff sales nationwide since its introduction nearly five decades ago.
The trademark dispute arose when Little Caesars began advertising its 'Crazy Puffs' product. Iltaco argued that Little Caesars' use of variations containing the word 'Puff' would cause consumer confusion with its established 'Pizza Puff' trademark. The Chicago-based company sought a preliminary injunction to prevent Little Caesars from using 'Crazy Puff,' 'Pizza Puff,' and 'Puff' in its product names and advertising materials.
The U.S. District Court for the Northern District of Illinois, Eastern Division, initially granted a partial preliminary injunction. Judge Jeremy C. Daniel denied the injunction request regarding 'Crazy Puff' and 'Puff,' finding that Iltaco failed to demonstrate sufficient likelihood of success in its trademark infringement claims for those specific terms. However, the district court granted the preliminary injunction concerning 'Pizza Puff,' concluding that Iltaco had shown likelihood of success on the merits for that particular trademark claim.
The case proceeded through multiple appeals, with case numbers 24-3317, 25-1072, 25-1076, and 25-1112 consolidated before the Seventh Circuit. Oral arguments were held on Nov. 14, 2025, before a three-judge panel consisting of Circuit Judges Amy Coney Barrett Scudder, Amy J. St. Eve, and Candace Jackson-Akiwumi.
In the Jan. 16, 2026 decision authored by Circuit Judge St. Eve, the Seventh Circuit reversed the district court's analysis regarding the 'Pizza Puff' preliminary injunction. The appeals court concluded that the district court had erred in finding that Iltaco demonstrated likelihood of success on the merits of its trademark infringement claim specifically pertaining to 'Pizza Puff.'
The Seventh Circuit affirmed the district court's decision regarding 'Crazy Puff' and 'Puff,' upholding the lower court's determination that Iltaco had not shown sufficient likelihood of success in proving trademark infringement for those terms.
This ruling represents a significant development in food industry trademark law, particularly concerning the protection of product names that incorporate common descriptive terms. The decision addresses the complex analysis courts must undertake when evaluating trademark infringement claims involving similar but not identical product names in competitive markets.
The case highlights the challenges facing established regional food companies when larger national chains introduce products with similar naming conventions. Trademark law requires plaintiffs to demonstrate both that they have protectable trademark rights and that defendant's use of similar marks creates likelihood of consumer confusion.
For Iltaco, the mixed ruling means the company cannot prevent Little Caesars from using 'Pizza Puff' in its advertising, despite Iltaco's decades-long use of the trademark. However, the company's underlying trademark infringement lawsuit continues, and the appeals court's decision addresses only the preliminary injunction motions, not the ultimate merits of the trademark claims.
The decision also reflects the food industry's increasingly competitive landscape, where product naming and branding play crucial roles in consumer recognition and market positioning. As regional food companies expand nationally and encounter larger competitors, trademark disputes over similar product names are likely to continue arising.
Little Caesars can now proceed with its 'Crazy Puffs' marketing campaign without the preliminary injunction restrictions that had been imposed regarding 'Pizza Puff' usage. The company had successfully argued that Iltaco failed to meet the legal standard for preliminary injunctive relief on most of its trademark claims.
The case will now return to the district court for further proceedings on the underlying trademark infringement claims, where both parties will have opportunity to present evidence on the ultimate question of whether Little Caesars' 'Crazy Puffs' product creates actionable trademark infringement.