Trademarks including another person’s name

On February 18 of this year, it was reported that the Florida House of Representatives passed a bill by a vote of 81 to 30 to rename Palm Beach International Airport as “Donald J. Trump International Airport” (CNN, February 19, 2026). Prior to this, on February 13, a trademark application for “DONALD J. TRUMP INTERNATIONAL AIRPORT” was filed with the USPTO, drawing considerable attention.

There are airports named after individuals all over the world. Well-known examples include John F. Kennedy International Airport in the United States and Charles de Gaulle Airport in France. Many other airports are also named after individuals, such as George Bush Intercontinental Airport in Houston, Genghis Khan International Airport in Mongolia, Sultan Mahmud Badaruddin II International Airport in Indonesia, Don Miguel Hidalgo y Costilla International Airport in Mexico, and Douglas–Charles Airport in the Commonwealth of Dominica. It is remarkable how many airports bear the names of individuals.

Turning to airport names in Japan, Kochi Airport is nicknamed “Kochi Ryoma Airport.” It is said to be the only airport in Japan that includes the name of a person. In the past, a trademark application for the mark “Kochi Ryoma Airport” in Class 33 (designating sake and related goods) resulted in a final refusal. The application appears to have been refused solely under Article 4(1)(15) of the Japanese Trademark Act on the grounds that it was likely to cause confusion with the business of another person.

Although this issue is not limited to airport names, if an individual or corporation files a trademark application containing the name of a famous historical figure, such as Sakamoto Ryoma, the application will generally be rejected for violating public order and morals under the Japanese Trademark Act and the Examination Guidelines. In other words, granting exclusive rights to a trademark consisting of the name of a famous historical figure is considered an attempt to exploit the figure’s reputation and customer appeal, to undermine fair competition, and to be contrary to public order and generally accepted standards of morality. Accordingly, such trademarks are not registrable.

On the other hand, with respect to trademark applications containing the names of living individuals, the registration requirements were relaxed under the 2023 amendments to the Trademark Act (effective April 1, 2024).

Before the amendment, a trademark containing the name of another person could not be registered without that person’s consent, regardless of whether the name was well known.

After the amendment, such a trademark may be registered without consent if all of the following requirements are satisfied:
(1) The name of the other person is not well known among consumers;
(2) There is a reasonable relationship between the name included in the applied-for trademark and the applicant; and
(3) The application was not filed in bad faith.

If any of these requirements is not satisfied, the trademark cannot be registered without obtaining the consent of the person concerned.