A United States judge has dismissed the trademark infringement case made by Haas Automation against its former Formula 1 team principal Guenther Steiner.
In May, the Haas F1 team's parent company Haas Automation sued Steiner for alleged trademark infringements in his Surviving to Drive autobiography, claiming that Steiner used Haas branding and trademarks in his book without permission or consent from the company.
After not getting a satisfactory response from Steiner on the matter, Haas Automation took the Italian and his book's publisher Ten Speed to court in California, where the parent company is headquartered.
Haas took particular issue with the photography used in the book, including the front cover, which Haas Automation alleged breached federally registered trademarks for its CNC machine tools business and motorsport activities.
Steiner's defence argued that the use of Haas logos fell under fair use and was protected by the First Amendment. The California judge ruled the use of Haas logos was artistically relevant to the book and was not explicitly misleading, two criteria on which a copyright infringement is judged according to the so-called Rogers test.
"The Book recounts Steiner’s experiences as team principal of the Haas F1 Team during the 2022 season," the court documents stated.
"Using photos that include the Haas marks is an artistic choice to provide additional context about the 2022 season with the Haas F1 Team.
"Here, there is no explicit indication, overt claim, or explicit misstatement that the 'source of the work' is Haas Automation.
"While there’s an argument the photo on the cover implicitly suggests endorsement or sponsorship, there is no explicitly misleading statement or suggestion by way of the Haas marks.
"Accordingly, defendants’ use here of the Haas marks is protected under Rogers. Defendants’ motion is therefore granted."
A state-level common law unfair business practices claim was also dismissed. The defence sought to have its legal fees reimbursed by Haas Automation but, because Haas' complaint was deemed "objectively reasonable", that motion was denied.
Steiner has also taken Haas to court himself in North Carolina over commissions and royalties that he alleges his former employer owes him over several years, a case that is still ongoing.
Backed by Haas Automation founder and NASCAR team owner Gene Haas, Steiner was the driving force behind the Haas F1 team from its inception in 2014.
The former Jaguar and Red Bull Racing director led Haas F1 as team principal from its first grand prix in 2016 until the end of the 2023 season, when his expiring contract was not renewed and he was replaced by Ayao Komatsu.
When approached by Motorsport.com the Haas F1 team declined to comment on the matter.