The Seventh Circuit Court of Appeals reversed a preliminary injunction against Little Caesars in a trademark dispute with Illinois Tamale Company, ruling that the Chicago-based food company failed to demonstrate a sufficient likelihood of success in proving trademark infringement over the term "Pizza Puff."

In the decision issued Jan. 16, 2026, a three-judge panel led by Circuit Judge Amy St. Eve examined Illinois Tamale Company's claims against LC Trademarks, Inc. and Little Caesar Enterprises, Inc., collectively known as Little Caesars. The case centered on Little Caesars' "Crazy Puffs" product and whether it infringed on Iltaco's trademark-protected "Pizza Puff" product.

Iltaco, doing business as ILTACO, brought the trademark infringement action in the U.S. District Court for the Northern District of Illinois, claiming that Little Caesars' Crazy Puffs product and advertising created a substantial likelihood of confusion with its own 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 advertising.

The district court, presided over by Judge Jeremy C. Daniel, issued a mixed ruling on the preliminary injunction request. The trial court denied the injunction as to "Crazy Puff" and "Puff," finding that Iltaco failed to show sufficient likelihood of success in its trademark infringement action regarding those terms. However, the district court granted the preliminary injunction specifically as to "Pizza Puff."

The appeals court disagreed with the district court's analysis regarding the "Pizza Puff" injunction. "Because the district court erred in concluding that Iltaco showed it was likely to succeed on the merits of its trademark infringement claim pertaining to 'Pizza Puff,' we reverse that portion of its decision," the Seventh Circuit wrote. The court affirmed the district court's decision denying injunctions for "Crazy Puff" and "Puff."

The factual background reveals the deep history behind Iltaco's trademark claims. Illinois Tamale Company was founded in 1927 as a Chicago-based food company. Nearly five decades later, in 1976, Iltaco began selling its pizza puff product, which the court described as similar to a calzone but made from a flour tortilla wrapped around pizza toppings that can be fried or baked. The company has since expanded its pizza puff sales nationwide.

The case involves multiple appeals and cross-appeals, as indicated by the four docket numbers: 24-3317, 25-1072, 25-1076, and 25-1112. This suggests the complexity of the dispute and the various legal issues raised by both parties in their respective appeals.

Oral arguments in the case were held Nov. 14, 2025, before Circuit Judges Michael H. Scudder, Amy J. St. Eve, and Candace Jackson-Akiwumi. The panel took approximately two months to issue its decision, which came down on Jan. 16, 2026.

The reversal represents a significant victory for Little Caesars, which can now continue using the term "Pizza Puff" in its marketing and product descriptions without the preliminary injunction constraint. For Iltaco, the ruling means it must overcome higher legal hurdles to prove its trademark infringement claims as the case proceeds.

Trademark disputes in the food industry often hinge on likelihood of confusion analysis, examining factors such as the similarity of the marks, the similarity of the products, the strength of the plaintiff's mark, and evidence of actual confusion among consumers. The Seventh Circuit's reversal suggests that Iltaco's evidence may not have been sufficient to meet the preliminary injunction standard for the "Pizza Puff" term.

The case highlights the ongoing challenges food companies face in protecting product names and branding in an increasingly competitive marketplace. While Iltaco has nearly five decades of history with its Pizza Puff product, the appeals court determined that this history alone was insufficient to warrant preliminary relief against Little Caesars' use of the contested term.

The underlying trademark infringement lawsuit remains active despite the preliminary injunction ruling. Iltaco can continue to pursue its claims through trial, where it would need to prove trademark infringement by a preponderance of the evidence rather than the likelihood of success standard required for preliminary injunctions.

For businesses operating in the food industry, the decision underscores the importance of building strong evidence of trademark rights and consumer confusion when challenging competitors' product names. The case also demonstrates how preliminary injunction denials do not necessarily doom the underlying trademark claims, as different legal standards apply at different stages of litigation.

The Seventh Circuit's decision resolves the immediate preliminary injunction issues but leaves open questions about the ultimate resolution of Iltaco's trademark infringement claims against Little Caesars.