In Lexmark Int’l, Inc. v. Static Control Components, Inc., 134 S. Ct. 1377 (2014) (No. 12-873), the Court addressed the issue of whether Static Control could bring a Lanham Act false advertising claim against Lexmark, notwithstanding the fact that Static Control and Lexmark were not direct competitors.  The Court noted that the circuit courts had developed three competing tests to determine whether a plaintiff has standing to sue under the Lanham Act:  (i) a strict, categorical test that requires that the parties be actual competitors, (ii) an approach allowing suits by any plaintiff with a “reasonable interest” to protect against the alleged false advertising, and (iii) application of the same multifactor standing test used for antitrust claims.  The Supreme Court declined to adopt any of those tests.  Instead, it applied traditional principles of statutory interpretation and held that a plaintiff may sue under the Lanham Act if it falls within the “zone-of-interests” protected by the Act and suffered injuries proximately caused by violations of the statute.  Referring to the Act’s “unusual and extraordinarily helpful” detailed statement of its purpose, the Court ruled that to fall within the zone-of-interests of the Act’s false advertising provisions, a plaintiff must allege an injury to a commercial interest in reputation or sales, which flows directly from the alleged deception wrought by the defendant’s advertising.