I think the issue before the court wasn't the sales generated, it was the trademark infringement. Lands' End is a registered trademark. It is incumbent upon the trademark's owner to defend the trademark against infringement. Not to do so, the company could lose their trademark.

Furthermore, although these affiliates were making sales for Lands' End, if Lands' End didn't challenge this, there would be a precedent set and other such sites could infringe on the trademark and not divert to the Lands' End official site.

Lastly, the affiliates' agreements with Lands' End apparently forbid unauthorized/unapproved sites from associating themselves with Lands' End.

The affiliates should have gotten approval from Lands' End.

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