Holding that to recover for unfair competition based on the use of a generic term, the plaintiff was required to show, inter alia, “an association of origin by the consumer between the mark and the first user, that is, secondary meaning”
In University of Notre Dame Du Lac v. J.C. Gourmet Food Imports Co., 703 F.2d 1372, 1376, 217 USPQ 505, 509 (Fed. Cir. 1983), the court added that section 2(a) embraces concepts of the right to privacy which may be violated even in the absence of likelihood of confusion.