Snowman scarf or hat, while others prefer not to risk leaving supplies out doors where they could easily be stolen or become stuck under melting ice. There are variations to these standard forms; for instance, the popular song "Frosty the Snowman" describes a snowman being decorated with a corncob pipe, button nose, coal eyes and an old silk hat (usually depicted as a top hat). These other types range from snow columns to elaborate snow sculptures similar to ice sculptures. One book describes classic snowman attachments as a black felt top hat, red scarf, coal eye pieces, carrot nose, and corn
Frosty Treats, Inc. v. Sony Computer Entertainment America, Inc. Safety Clown are so dissimilar that no reasonable trier of fact could conclude that they are confusingly similar." Additionally, the court noted that the safety clown could not be protected because it was functional; it directed children to cross behind the van rather than in front of it. Frosty Treats appealed the dismissal to the Eighth Circuit Court of Appeals on June 15, 2005. The Eighth Circuit affirmed the dismissal, holding that the name was indeed generic. Judge Morris S. Arnold wrote that, although the Eighth Circuit rejected the finding that the safety clown was functional, they held that it