Consumers Outside Zone of Interests of Lanham Act, Says Sixth Circuit

Can consumers bring a Lanham Act claim for false advertising against a company that deceived them?
In an opinion issued yesterday, the Sixth Circuit said no. Applying the Supreme Court’s 2014 Lexmark decision, the court held that only those who suffer an injury to a commercial interest are within the zone of interest of the statute. “Consumer injuries,” it held, “fall outside the Lanham Act’s zone of interests.”