LANHAM ACT - Standing to sue

Justice Scalia, for a  unanimous court: 

In sum, the question this case presents is whether Static
Control falls within the class of plaintiffs whom Congress
has authorized to sue under §1125(a). In other words, we
ask whether Static Control has a cause of action under the
statute.
 …
 We thus hold that to come within the zone of interests in
a suit for false advertising under §1125(a), a plaintiff must
allege an injury to a commercial interest in reputation or
sales. A consumer who is hoodwinked into purchasing a
disappointing product may well have an injury-in-fact
cognizable under Article III, but he cannot invoke the
protection of the Lanham Act—a conclusion reached by
every Circuit to consider the question. See Colligan v.
Activities Club of N. Y., Ltd., 442 F. 2d 686, 691–692 (CA2
1971); Serbin v. Ziebart Int’l Corp., 11 F. 3d 1163, 1177
(CA3 1993); Made in the USA Foundation v. Phillips
Foods, Inc., 365 F. 3d 278, 281 (CA4 2004); Procter &
Gamble Co., 242 F. 3d, at 563–564; Barrus v. Sylvania, 55
F. 3d 468, 470 (CA9 1995); Phoenix of Broward, 489 F. 3d,
at 1170. Even a business misled by a supplier into pur­
chasing an inferior product is, like consumers generally,
not under the Act’s aegis.

Per Tom Goldstein: "The cause of action extends to the zone of interests protected by the Lanham Act and whose injury was proximately cause."