In Victoria's Secret v. Victor's Little Secret, plaintiff was granted its motion for summary judgment as to trademark dilution. The Court of Appeals upheld the judgment, but the U.S. Supreme Court reversed and remanded as to whether the trademark was diluted by the mere likelihood of harm or whether Victoria's Secret had to prove the existence of the harm. This paper discusses the application of that decision in the cases that followed, and how the Trade Dilution Revision Act of 2006 may take that proof requirement back to the original Victoria’s Secret's decision.