By: Shannon Kavanagh
Golf, a sport rooted in tradition and custom, is being innovated by some of its best players. In 2022, Tiger Woods and Rory McIlroy teamed up to create a tech-infused golf league, Tomorrow’s Golf League (TGL).[1] The TGL players hit their shots off real grass, rough, and sand into a simulator screen.[2] Once the ball is on the green, the players putt it like they would on a regular course.[3]
With any new sports league, team, or venture, there comes a wide range of intellectual property considerations. The league hosts six teams from cities across America, including a team in Los Angeles, the LA Golf Club,[4] which is at the center of an unraveling trademark dispute.[5]
TGL filed a trademark application just one day before announcing LA Golf Club’s addition to the league in June 2023.[6] Eight days following the announcement of the team, a golf equipment company, LA Golf Partners LLC (“LAGP”), filed a trademark application for “LA GOLF CLUB” covering services in international classes 35, 41, and 43.[7] This mark became registered on the supplemental register at the end of 2024.[8]
In October 2023, LAGP sent a letter to TGL outlining their concerns regarding the league’s applications, but they did not explicitly oppose TGL’s application.[9] The parties had multiple conversations with LAGP requesting a potential business partnership. However, the TGL stated that they were not interested, and they did not think that their applications infringed on LAGP’s registered trademark.[10]
According to TGL, LAGP did not communicate with the league for eight months after the parties initially spoke.[11] LAGP then sent a cease and desist letter to them just before the beginning of the league’s season in January 2025.[12] The cease and desist letter demands that TGL stop using marks that LAGP alleges are confusingly similar to their registered trademark.[13]
TGL alleges that because of the lack of communication from LAGP until just before the start of the season, the cease and desist was done in bad faith and to garner attention because of the anticipation of the beginning of the league’s season.[14] TGL argues that the LAGP marks and the marks used by TGL’s LA team are not confusingly similar, LAGP’s marks are merely descriptive, the marks are different in commercial impression, and the services covered under LAGP’s mark are different from those covered in TGL’s trademark applications.[15] TGL also argues that the only shared element of the marks is the abbreviation of Los Angeles, LA, which is a commonly used abbreviation, especially in regards to sports teams.[16] Specifically, the LA Rams, LA Dodgers, LA Galaxy as well as others all use this abbreviation.[17]
TGL argues that because “LA GOLF CLUB” is registered on the supplemental register, this proves that it is merely descriptive, and therefore, is not afforded the same rights as a mark registered on the principal register.[18] Trademarks must acquire secondary meaning, meaning that the mark is a source-identifier to consumers.[19]
TGL requests declarations of non-infringement, no false designation of origin or unfair competition, no dilution, no unfair competition or deceptive trade practices, equitable estoppel prohibiting enforcement, and a petition for cancellation of LAGP’s “LA GOLF CLUB” trademark.[20]
TGL requests a jury trial, which may be required to lay out all the facts in this case, if the parties decide not to settle.[21] This dispute showcases a cautionary tale for future sports teams and leagues looking to protect their new brands. It is important to file trademark applications as early as possible and to use those marks in commerce, protecting the team or league from potential disputes like the one faced by TGL.
[1] Keith Jenkins, What is TGL? Schedule, players in Woods-McIlroy golf league, ESPN (Mar. 3, 2025, 1:44 PM), https://www.espn.com/golf/story/_/id/42391272/what-tgl-golf-league-formed-woods-mcilroy.
[2] Id.
[3] Id.
[4] This is TGL Presented by Sofi, TGL Golf, https://tglgolf.com/explained.
[5] Kyle Jahner, Woods-McIlroy League Sues to Cement Right to Use ‘LA Golf Club’, Bloomberg L., (Jan. 7, 2025, 1:26 PM), https://www.bloomberglaw.com/bloomberglawnews/ip-law/X666UB44000000?bna_news_filter=ip-law#jcite.
[6] Demand for Jury Trial at 2, TGL Golf Holdings v. LA Golf Partners (D. Del. 2025) (No. 1:25-cv-00011), https://www.bloomberglaw.com/document/X3UV3JM7HSM8HBPD4B3RDJ0S9VT.
[7] LA GOLF CLUB, Registration No. 7,616,256. Classes 35, 41, and 43 cover services including advertising and business, education and entertainment, and hotels and restaurants, respectively.
[8] LA GOLF CLUB, Registration No. 7,616,256.
[9] Demand for Jury Trial at 14, TGL Golf Holdings v. LA Golf Partners (D. Del. 2025) (No. 1:25-cv-00011), https://www.bloomberglaw.com/document/X3UV3JM7HSM8HBPD4B3RDJ0S9VT.
[10] Id.
[11] Id.
[12] Id. at 3.
[13] Id. at 2.
[14] Id. at 3.
[15] Demand for Jury Trial at 3, TGL Golf Holdings v. LA Golf Partners (D. Del. 2025) (No. 1:25-cv-00011), https://www.bloomberglaw.com/document/X3UV3JM7HSM8HBPD4B3RDJ0S9VT.
[16] Id.
[17] Id.
[18] Kyle Jahner, Woods-McIlroy League’s ‘LA Golf’ Fight Probes Weak IP Rights, Bloomberg L. (Jan. 23, 2025, 3:34 AM), https://news.bloomberglaw.com/ip-law/woods-mcilroy-leagues-la-golf-fight-probes-weak-ip-rights.
[19] Id.
[20] Demand, supra note 6 at 18-21.
[21] Jahner, supra note 17.
