Judge rules Oakland airport can’t include San Francisco Bay in its name

SAN FRANCISCO — A federal judge on Tuesday blocked the renaming of Oakland International Airport, ruling that adding “San Francisco Bay” to the name causes travelers to mistakenly believe that the East Bay airport is affiliated with or run by the same management as San Francisco’s airport.

The Port of Oakland, which operates the airport, told San Francisco officials in March of a plan to rename the airport, but officials in San Francisco objected to the plan on the grounds that the change would increase the “likelihood of confusion” between the two airports, according to court filings.

The city and county of San Francisco filed the lawsuit seeking an injunction on April 18, alleging trademark infringement, unfair competition and false designation of the airport, according to court documents.

U.S. Magistrate Thomas S. Hixson’s ruling on Tuesday dismissed two of San Francisco’s claims – that the name change would cause “initial interest confusion” in which a company uses a competitor’s trademark to falsely direct attention to them, and that the name change would cause “point of sale confusion,” in which passengers would mistakenly buy tickets to the wrong airport, according to court filings.

Hixson accepted that the injury to SFO would be an “implied association” between SFO and OAK, noting that SFO is “routinely ranked among the top airport brands” while OAK is “is rated worse in terms of customer satisfaction,” according to court documents.

He added that SFO has made “substantial investments” to growing and improving the airport’s facilities and has won awards and recognitions. OAK, on the other hand, is smaller, has limited infrastructure and hosts less flights.

“Because in the United States the name of a city is normally in the name of an airport only if the city owns or partially owns that airport, the new name for the Oakland airport strongly implies affiliation with San Francisco and the San Francisco International Airport,” Hixson wrote. “This damages the goodwill and value of San Francisco’s Mark and deprives San Francisco of control over its Mark.”

Hixson also concluded that the damage would be “difficult or impossible” to quantify. San Francisco would “suffer irreparable harm” from OAK’s name change, he wrote.

The harm to OAK would be “minimal when it remains free to use the well-known name for the Oakland airport that it has used for 60 years,” Hixson added.

The name change was aimed at attracting travelers coming to the Bay Area who may not be familiar with Oakland’s proximity to other Bay Area cities. It was also meant to spur economic growth following the Covid-19 pandemic and help increase the flow of travelers through the least busy of the Bay Area’s three major airports.

The initial announcement was met with opposition from people in the San Francisco tourism and hospitality industry, many travelers and some California legislators. Some airlines, including Spirit Airlines, Southwest Airlines and Volaris, supported the name change, while others including United Airlines, Japan Airlines and Vietnam Airlines, opposed the change.

“The court order temporarily blocks OAK’s new name on the basis of the third type of alleged confusion: that travelers may think OAK is affiliated with SFO,” Port of Oakland spokesperson Robert Bernardo said in a statement. “OAK is not associated with SFO, of course, but is rather a convenient and centrally located option for travelers throughout the Bay Area.”

Bernardo added that the Port of Oakland is considering all available legal options.

“For months, we have tried reasoning with Oakland officials to avoid litigation and come up with alternative names that would work for all of us,” said San Francisco City Attorney David Chiu in a statement. “Unfortunately, those efforts were not productive, and we had no choice but to ask the court to step in and protect our trademark.”

Chiu added that San Francisco invested millions of dollars in making SFO “the world class airport it is today.”

“We have built an incredible brand, and we are happy the Court agreed that brand should be legally protected from trademark infringement,” he said.

“We are very grateful for this decision,” added SFO Airport Director Ivar C. Satero. “This ruling is ultimately a win for Bay Area travelers. My thanks go out to the City Attorney for their commitment to this issue.”