Meemi v Wardrobe: WARDROBE mark survives, but MY-WARDROBE.COM freed from limits
MeemivWardrobe
- Court
- High Court
- Judgment
- 18 December 2012
- Citation
- [2012] EWHC 3617 (Ch)
A judge must weigh all the relevant factors together, not dismiss each one on its own.
Meemi, which ran MY-WARDROBE.COM, tried to cancel a rival's WARDROBE trademark and fought limits placed on its own marks. The High Court kept WARDROBE registered but removed the limits on Meemi's registrations.
What happened
Meemi owned MY-WARDROBE.COM trademarks for online clothing retail. It tried to invalidate Wardrobe (Beautiful Clothes) Ltd's earlier WARDROBE trademark, arguing the word was simply descriptive of clothing. The hearing officer at the Intellectual Property Office disagreed and also limited Meemi's own registrations, pointing to Wardrobe (Beautiful Clothes) Ltd's longstanding goodwill in upmarket London retail under the WARDROBE name, a risk of passing off, where customers might wrongly believe two businesses are connected. Meemi appealed both findings to the High Court.
What did the court decide in Meemi v Wardrobe?
The judge agreed that WARDROBE describes a whole collection of clothing rather than a feature of any single garment, so it was not merely descriptive and the registration stood. On the second issue, the judge found the hearing officer had looked at each factor, the descriptive flavour of the word, the different trading spheres, the geographically limited goodwill, and the lack of actual confusion, in isolation rather than standing back and weighing them together. Taken as a whole, the judge concluded there was no real likelihood that consumers would be misled, so the limits on Meemi's marks were lifted.
What we learned from this
- What I'd take from this is that a word can describe a whole range or collection of products without being too descriptive to register as a trademark, if it doesn't describe any one product's features.
- When arguing passing off, where customers might wrongly believe two businesses are connected, it's worth presenting the full picture rather than relying on one strong point alone.
- A geographically limited reputation, such as an upmarket London store, won't automatically block a national online retailer from using a similar name.
- Decision makers need to look at the cumulative weight of the evidence, not tick off each factor separately and dismiss it.
Things to be aware of
- This case turned on its specific facts, a traditional London shop against a national online retailer, so it isn't a general rule that descriptive words can never support a passing off claim.
- The ruling doesn't mean WARDROBE is a strong trademark, only that it cleared the bar for registration on these facts.
- The removal of limits on Meemi's marks reflected the judge's view of the evidence at that time, not a permanent guarantee against future disputes.
The businesses involved
Meemi Ltd
Registered in England in January 2003 and dissolved in February 2017. Based in London, it traded as the online fashion retailer MY-WARDROBE.COM, selling clothing by mail order and over the internet.
- Companies House
- 04627828 Dissolved
- Incorporated
- January 2003
- Note
- Ceased February 2017
- Registered office
- London
- Business activity
- Retail sale via mail order houses or via Internet
- UK trademarks
- 0
Wardrobe (Beautiful Clothes) Ltd
Owner of the earlier WARDROBE trademark registered for clothing. The Intellectual Property Office treated it as holding longstanding upmarket London retail goodwill under that name.
- Companies House
- 01129152 Dissolved
- Incorporated
- August 1973
- Note
- Ceased December 2017
- Registered office
- London
- Business activity
- Retail sale of clothing in specialised stores
- UK trademarks
- 1
What happened next
- Thomson Reuters Practical Law reported that the High Court allowed Meemi's appeal against the IPO's limitation of its MY-WARDROBE.COM trademark registrations.Source: Practical Law (Thomson Reuters)
- The Financial Times later reported on management changes at My-Wardrobe, including the departure of the business's founder from the company.Source: Ft
- A direct commerce industry news site reported that administrators were later appointed to Meemi Ltd, trading as My-Wardrobe.com, in connection with securing the business's future.Source: Homeofdirectcommerce
What others said about it
- The Intellectual Property Office's original decision recorded Meemi's argument that WARDROBE is inherently descriptive and wouldn't be seen by consumers as a sign of trade origin.Source: Ipo
How we can help
If something in this case sounds familiar, talk it through with us. The first call is free for new clients.
This page is for information purposes only and does not constitute trademark advice or guidance. Summary drafted with AI assistance from the published judgment and checked by The Trademark Helpline (how we write these). Judgment: [2012] EWHC 3617 (Ch) on Find Case Law, published under the Open Justice Licence. Company details from Companies House; trademark counts from the UK trademark register. Last reviewed 27 October 2026. Report an error.
