Holiday Inns, Inc. v. Limbach

Appellant argues that the royalties paid for the use of the “system” were payments to use Holiday Inns’ trademarks and service marks and that such payments are closely “akin to” income from patents and copyrights. Specifically, appellant contends that trademarks are intellectual property like patents and copyrights and that the clear intent of the General Assembly was to have the income from such property allocated to Ohio pursuant to R.C. 5733.051(G) (formerly R.C. 5733.051[A][7]). Further, appellant argues that at least part of the income received by appellee constituted technical…