Generic or highly generalized names are not protected from misappropriation under the doctrine of unfair competition unless a secondary meaning has been established.

It can, by acquiring a secondary meaning - become a valid trademark -.

The defendant argued that he was not guilty of trademark infringement since the names in question had become generic, or alternatively were descriptive but had not acquired secondary meaning.

Descriptive marks must acquire distinctiveness through secondary meaning - consumers have come to recognize the mark as a source indicator - to be protectable.

Descriptive marks may become distinctive (acquire secondary meaning) through 5 years of use in commerce, or through evidence of heavy advertising and market recognition.