Watts v. Amazon Studios — Court Dismisses ‘The Love Zone’ Trademark Suit Over Amazon’s ‘Cross’ TV Series

Background

Maurice “The Voice” Watts has hosted “The Love Zone,” a romantic R&B and soul music radio program, on WHCR-90.3FM in Harlem for decades. In 2024, a storyline in Amazon’s crime thriller series “Cross” — based on the James Patterson novels — featured a fictional radio show also called “The Love Zone.” Watts sued Amazon Studios and Paramount Television Studios for trademark infringement, arguing that the series’ use of the identical name constituted a false designation of origin and would confuse viewers into associating the fictional show with his real radio program.

Amazon moved to dismiss the complaint, arguing that fictionally depicting a radio show of the same name within a drama series is not trademark infringement because no viewer would believe the fictional program and Watts’ actual WHCR radio show are commercially affiliated.

The Court’s Holding

Judge J. Paul Oetken granted the motion and dismissed the case on June 11, 2026. The court found that Watts had failed to allege — let alone show — that Amazon’s use of “The Love Zone” in the fictional context of “Cross” deliberately misled viewers about the source or origin of his actual radio show. Trademark law protects against confusion about commercial origin, but using a trademarked name as a fictional cultural reference within a scripted television drama does not, without more, constitute infringement. The court concluded there was no plausible showing that viewers of “Cross” would believe Watts was the source of the fictional radio show or that he had endorsed or licensed it.

Key Takeaways

• Trademark law does not prevent TV shows and movies from referencing real-world trademarked names when the reference is fictional and non-commercial — courts require evidence of deliberate consumer deception about source or origin.
• The Lanham Act’s false-designation-of-origin claim (15 U.S.C. § 1125(a)) requires a showing that consumers would be misled; incidental use of a name in a scripted narrative typically does not meet that threshold.
• Content creators have substantial latitude to use real-world names — including trademarked show titles — in fiction, as long as they are not trading on the brand or implying a sponsorship or affiliation that does not exist.
• Radio personalities and small-market media brands face an uphill battle asserting trademark rights against major streaming platforms when the only overlap is the name itself in a fictional context.

Why It Matters

Entertainment companies frequently incorporate real-world brand names, businesses, and media programs into scripted content as a shorthand for authenticity or cultural setting. This ruling — dismissing the case at the pleading stage — reinforces that such references are not actionable trademark infringement absent evidence that viewers were actually deceived about the commercial source or affiliation of the work. For radio hosts, podcasters, and other media personalities with registered trademarks, the case is a reminder that trademark law generally does not prohibit a streaming giant from naming a fictional show the same thing as their real-world program — unless the fictional use causes genuine consumer confusion about who is behind the content.