Eva's Bridal Ltd. v. Halanick Enterprises, Inc., No. 10-2863 (7th Cir. May 10, 2011) contains a short but interesting discussion by Judge Easterbrook about the proper way to look at "quality control." The mark owner trusted the licensee and felt confident he was maintaining high standards, but the agreement between the parties contained no quality control provisions whatsoever and the owner took no steps to monitor the good and services or how the mark was used. Judge Easterbrook said that quality control doesn't mean feeling confident that the licensee is maintaining high quality. Rather, it's about the owner taking steps to insure that the quality is consistent and predictable.
The court affirmed the finding of abandonment through naked licensing.