Lucky Brand was not the only 2020 case in which the Supreme Court weighed in on aspects of trademark litigation. In Romag Fasteners, Inc v. Fossil, Inc., 590 US ___ (2020), the Court held that proof of willfulness is not required to disgorge profits resulting from trademark infringement. 140 S. Ct. 1492 (2020). This decision put to rest yet another messy circuit split.