tion should be disapproved. The inter-departmental confusion of the Guerlain era, then, would not be repeated.
The case had shown that the felt need for new solutions to the problem of genuine imports was a compelling one. It was a need which had led Duracell to seek relief in a nontraditional forum; it had led the majority to endorse a fundamentally new vision of the purposes of trademark law; and it had led Stern to reaffirm the increasing significance of trademarks' quality assurance function.
Osawa Precision Industries, Ltd. and Mamiya Camera Co., Ltd., each a corporation of Japan are authorized to use the trademark. Therefore, merchandise manufactured and/or sold by these foreign firms bearing the genuine trademark "MAMIYA" may be imported by anyone.
U.S. Customs Service, Policies and Procedures Manual, Supp. No. TMK-2(4) ( Oct. 24, 1980) (copy attached as Exhibit A to Defendant MASEL's Memorandum of Law in Opposition to Plaintiff's Motion for Temporary Restraining Order and Preliminary Injunction).
This emphasis on authority to use a trademark appears to have been a remnant of the 1953-1959 period, when licensees, as "related companies," were barred from using section 526. Certainly it seems inconsistent with the regulations then in force, which emphasized ownership and control and did not automatically prohibit the use of section 526 by firms with a licensor-licensee relationship. See generally supra chap. 4.
In May 1982, possibly after recognizing this inconsistency, Customs changed its position to prohibit the importation of the cameras and instructed its officers to amend their records "by deleting all reference to the foreign authorized users of the trademark." U.S. Customs Service, Policies and Procedures Manual, Supp. Nos. 82-101, 82-102 ( May 6, 1982).