packaging has generally been mixed in U.S. court cases. Specific cases denying color protection include royal blue for ice cream packages (AmBrit Inc. v. Kraft, Inc., 812 F.2d 1531 (11th Cir. 1986), cert. denied, 481 U.S. 1041 (1987)); a series of stripes or multiple colors on candy packages (Life Savers v. Curtiss Candy Co., 82 F.2d 4 (7th Cir. 1950)); green for farm implements (Deere & Co. v. Farmhand Inc. (560 F. Supp. 85 (S.D. Iowa 1982) aff'd, 721 F.2d 253 (8th Cir. 1983)); black for motors (Brunswick Corp. v. British Seagull, Ltd., 35 F.3d 1527 (Fed. Cir.), cert. denied, 115 S. Ct. 1426 (1994)); and the use of red for one half of a soup can (Campbell Soup Co. v. Armour & Co., 175 F. 2d 795 (Court of App. 3d Cir., 1949)). A successful case granting color protection involved the use of the color red for cans of tile mastic Dap Products, Inc. v. Color Tile Mfg., Inc. 821 F. Supp. 488 (S.D. Ohio 1993), and a green-gold color for dry cleaning pads (Qualitex Co. v. Jacobson Products Co., 514 U.S. 159, 165, 115 S.Ct. 1300, 1304, 131 L.Ed.2d 248 (1995)). Although scent trademarks (also known as olfactory trademarks or smell trademarks), are sometimes specifically mentioned in legislative definitions of "trademark", it is often difficult to register such marks if consistent, non-arbitrary and meaningful graphic representations of the marks cannot be produced. This tends to be an issue with all types of non-conventional trademarks, especially in Europe. United States practice is generally more liberal; a trademark for plumeria scent for sewing thread was registered in 1990. In Europe, a written description, with or without a deposited sample, is not sufficient to allow the mark to be registered, whereas such formalities are acceptable in the United States. However, even in the United States "functional" scents that are inherent in the product itself, such as smell for perfume, are not accepted for registration. One example of a shape trademark recognized in Europe is the protection granted to Toblerone, a company which manufactures chocolate bars with a distinctive triangular shape. Presenting further difficulties are entirely new types of marks which, despite growing commercial adoption in the marketplace, are typically very difficult to register, often because they are not formally recognised as a "trademark". Examples of such marks are motion trademarks (also known as animated marks, moving marks, moving image marks or