The Ninth Circuit today held the term "disinfectable" on nail files generic under the Lanham Act and therefore unprotectible as a trademark. The court pointed out that a valid mark answers "who-are-you" and that an invalid one tells "what-are-you". Rudolph Int’l, Inc. v. Realys, Inc. , No. 05-55065 (9th Cir. Apr. 12, 2007).