Dewberry Group, Inc. v. Dewberry Engineers Inc.

The Court applied the Lanham Act's plain text to reject aggregation of profits across legally distinct affiliates. Although Dewberry Group and its related entities shared common ownership, the statute's reference to "defendant's profits" encompasses only the named defendant's own earnings; separate legal entities retain distinct liability boundaries and cannot be collapsed for disgorgement purposes without satisfying traditional piercing-the-corporate-veil doctrine. The district court's view that the entities functioned as a unified enterprise could not override the statutory language or the principle that corporate separateness creates distinct liability shields. Accordingly, Dewberry Group's minimal profits—not the larger empire's earnings—defined the disgorgement ceiling, reversing the Fourth Circuit's inflation of the award through affiliation.