Stay informed on all the biggest stories in Formula 1. Sign up here to receive the Prime Tire newsletter in your inbox every Monday and Friday.
Haas Automation’s lawsuit against former team principal Guenther Steiner and his publisher, Ten Speed Press, has been dismissed, according to court documents from the Central District Court of California.
The lawsuit, filed by the sponsor of the Formula One team owned by Gene Haas, was over alleged trademark infringement in Steiner’s 2023 autobiography, “Surviving to Drive.” According to a copy of the lawsuit, Haas Automation accused Steiner of “unlawfully” using and displaying “the Haas Automation Trademarks and the Haas Automation Trade Dress for Steiner’s personal financial gain and illicit profit.”
Judge André Birotte, Jr. granted the defendant’s motion to dismiss on Sept. 25, and it was “dismissed without leave to amend.”
The defendants’ argument claimed that “the use of the Haas Marks is protected by the First Amendment under the Rogers test or, in the alternative, as nominative fair use.” The Rogers test is essentially a two-part test to determine whether there is trademark infringement, determining artistic relevance, and if it was misleading. The court determined that the Rogers test was appropriate in this lawsuit because Steiner and his publisher did not “use the Haas Marks as trademarks, or source-identifying marks, with respect to the Book.”
“Naturally, the Book details Steiner’s experience as Team Principal of the Haas F1 Team. That necessarily requires him to mention the Haas name,” the order states. “As many sports biographies do, it includes photographs of the season, which will undoubtedly show the Haas Marks.”
The court determined that the book was both artistically relevant and not explicitly misleading with the use of Haas’ marks. Because the book focuses on Steiner’s stint as Haas’ team principal, “using photos that include the Haas Marks is an artistic choice to provide additional context about the 2022 season with the Haas F1 Team.”
As for the explicitly misleading component, the court did acknowledge that “there’s an argument the photo on the cover implicitly suggests endorsement or sponsorship.” However, there isn’t an “explicitly misleading statement or suggestion by way of the Haas Marks.”
A motion from the defense to reimburse legal fees was denied, and a California common law unfair business practices claim was dismissed.
Meanwhile, Steiner’s lawsuit against Haas in North Carolina is pending. The former team principal is alleging unpaid commissions and unauthorized use of his likeness. The 59-year-old led Haas as team principal from its beginning in 2014, prior to its joining the Formula One grid in 2016, and left Haas ahead of the 2024 season. Steiner remains a visible figure in the paddock.
Top photo: BENJAMIN CREMEL/AFP via Getty Images
