Keel v. Axelrod

MEMORANDUM OPINION

Goldberg, District Judge

This case centers around a short passage in a book authored by David Axelrod, titled Believer: My Forty Years in Politics. Plaintiff Frank Keel (“Keel”), a Pennsylvania based political and media consultant, initiated this lawsuit against Defendants Axelrod and Penguin Random House, LLC (“Penguin”) pursuant to 15 U.S.C. § 1125(a) of the Lanham Act and Pennsylvania’s law on unfair competition.1 The passage in question describes a political strategy devised and implemented during the 2003 reelection campaign of former Philadelphia Mayor John F. Street.…