A Standard Clause setting out a sample legal argument in favor of a likelihood of confusion finding for use by a trademark owner claiming infringement in a case where Second Circuit law applies. It includes case support and can be incorporated into legal briefs supporting court filings, opinion memoranda for clients, cease and desist correspondence, or any other substantive documents addressing the likelihood of confusion issue. It must be modified to fit the circumstances of the allegedly infringing use and the facts of the case.