Direct Causal Link to Deceitful Advertising Required

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Affirming the trial court, the court conceded, contrary to that tribunal that specifically, "Basic Research asserts that the phrase ‘use of another's advertising idea in your advertisement' should not be limited to claims of misappropriation or wrongful taking of another's advertising idea, but should rather include any form of ‘misuse,' including deceitful advertising. 

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False Advertising Products as Patented Covered

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Elcom Technologies v. Hartford Ins. Co. of the Midwest, 991 F. Supp. 1294 (D. Utah 1997) (applying Pennsylvania law).  
False advertising claim in suit for intellectual property claiming that Elcom improperly marketed its products as patented when they were not, triggers coverage under "advertising injury" offense of "misappropriation of advertising ideas or style of doing business."