is synonymous with “handbag.” See id. Furthermore, an unknown proportion of respondents may have qualified only because they had bought a “handbag” or “purse or wallet” costing more than the required amount “in the past year or two,” but were not likely to do so in “the next year or so.” It is well-established that only potential future purchasers, not past purchasers, are relevant to a confusion study. See Universal City Studios, Inc. v. Nintendo Co., Ltd., 746 F.2d 112, 118 (2d Cir.1984) (“[T]he survey utilized an improper universe in that it was conducted among individuals who had already purchased or leased Donkey Kong machines rather than those who were contemplating a purchase or lease.”); American Footwear Corp. v. General Footwear Co., 609 F.2d 655, 660-661, n. 4 (2d Cir.1979) (<HOLDING>); Jordache Enterprises, Inc. v. Levi Strauss &
holding that former municipal judge did not have property interest in continued employment holding trial court erred when it permitted jury to consider ucc impliedwarranty theories where evidence was insufficient to prove defective product at issue was sold holding that to prevail on strict liability claim for a defective product plaintiff must show the product was defective when it left the defendants possession and control holding that issue preclusion extends to a matter that the court must necessarily albeit implicitly have decided holding that a survey was defective where survey participants although former purchasers of the product at issue did not necessarily have any present purchasing interest in the particular matter being surveyed