Court Upholds MillerKnoll Ownership of Iconic Bubble Lamp Design

Abstract

In Nelson v. MillerKnoll, No. 25-1940 (6th Cir. July 7, 2026), the Sixth Circuit affirmed a district court’s judgment against the heirs of furniture designer George Nelson, finding that furniture company MillerKnoll was authorized under a 2006 royalty agreement to use and own the intellectual property in Nelson’s Bubble Lamp design. The court further determined that the Nelson family ratified its arrangement with MillerKnoll by continuing to accept royalty payments after learning of MillerKnoll’s ownership claims.  

Background and the District Court Decision

George Nelson worked as a furniture designer for furniture company Herman Miller, Inc., now MillerKnoll. During his employment, Nelson designed the now-famous “Bubble Lamp” light fixture. Royalties for the lamp were governed first by a verbal and then a written agreement but in 2006, Nelson’s widow, Jacqueline agreed to a superseding written royalty agreement.

The 2006 royalty agreement provided royalty payments in exchange for rights relating to certain “licensed” Nelson-designed products “to which HMI owns the right[s].” While it did not cover the Bubble Lamp expressly, it provided that the parties could add additional products in the future. A later addendum expanded the 2006 royalty agreement to expressly include “Nelson branded Lamp products” and all “Nelson branded products not covered,” under the original 2006 agreement.

Meanwhile, another furniture company obtained trademarks and trade dress registrations relating to the George Nelson wordmark and the Bubble Lamps wordmark and trade dress. Litigation followed. When the case settled, the Nelson family ultimately obtained the “George Nelson” marks, but MillerKnoll received the Bubble Lamp-related intellectual property.

Years later, the Nelson family sued MillerKnoll to establish ownership of the Bubble Lamp intellectual property. The district court rejected its claims, concluding that the parties’ agreements authorized MillerKnoll’s ownership and use of the Bubble Lamp intellectual property and that the Nelson family had accepted millions of dollars in royalty payments under those same agreements, ratifying them. The Nelson family appealed.

Sixth Circuit Appeal

The Sixth Circuit agreed that the parties’ agreements authorized MillerKnoll to own and use the Bubble Lamp intellectual property. The court determined that despite the agreements’ reference to “licensed” products, the 2006 agreement and the subsequent addendum, when taken together “unambiguously authorize” MillerKnoll to own and use the Bubble Lamp IP, not merely receive a license to the IP. The agreements provided that MillerKnoll held “exclusive right, title, and interest” in products covered by the agreements, leaving little doubt the agreement reflected ownership rights. And while the original 2006 agreement did not expressly cover the Bubble Lamp intellectual property, it allowed the parties to add new products, which they did through the addendum.

The Sixth Circuit also agreed with the district court’s alternative basis to find for MillerKnoll: that the Nelson family ratified MillerKnoll’s use and ownership of the Bubble Lamp intellectual property by accepting royalty payments per the terms of the agreements. Specifically, after learning that MillerKnoll claimed ownership of the Bubble Lamp intellectual property, the Nelson family continued to receive and accept MillerKnoll’s royalty payments for the sales of Bubble Lamps for thirteen years. The court determined that the Nelson family’s acceptance of the royalty benefits under the contract constituted ratification of the contract as to the Bubble Lamp products.

Strategy and Conclusion

The case serves as a reminder of the importance of clear language—the tension between “license” and “ownership” language in the 2006 agreement created the potential for ambiguity that required litigation to resolve. In addition, parties should be aware that continued acceptance of benefits under an agreement can waive future claims. Once a party learns of conduct it believes is incorrect under an agreement, continuing to accept benefits associated with that conduct may constitute ratification of the contract.

Further Information

For further information, see the Court’s full decision here.