05
December
2022
NFT’s battle: 1-0 for Juventus!
There is no need to introduce Juventus anymore, even for those who don’t know anything about soccer!
If Juve, for the intimate, fights every day on the soccer fields, it is not left behind when it comes to defending its rights in court, and with some success.
In one of the first decisions in the European Union in this area, Juve won outright against digital playing cards authenticated by NFT.
Short summary of the competition
In 2021, Blockeras s.r.l. has obtained the agreement of various active and retired footballers to launch the Coin Of Champion project, which consists of the production of playing cards bearing their likeness and authenticated by NFT.
One of the cards represented the former center forward Bobo VIERI wearing his old Juve jersey.
In 2022, Blockeras launches the marketing of its cards driving the Juventus attack.
Indeed, the latter is the owner of numerous trademarks including the word marks JUVE, JUVENTUS and a figurative mark representing its famous jersey with black and white stripes bearing 2 stars.
Juve discovered the production (mintage), advertising and sale of the cards authenticated by NFT containing its trademarks without its authorization, so it brought an action before the Court of First Instance of Rome in the context of a “preliminary injunction”. It considers that these cards constitute acts of infringement of its trademarks and unfair competition.
In its defense, Blockeras argues, among other things, that the trademarks invoked were not registered for downloadable virtual goods!
Scoreboard
The Court of First Instance of Rome notes that the trademarks concern the most successful Italian soccer team that has won the most competitions.
In addition, Juve has a widespread merchandising activity in different sectors (clothing, games, etc.) both on the web and in physical stores in different Italian cities.
Thus, the use of the image of Bobo VIERI, wearing his Juve jersey, entails a use of trademarks without authorization from Juventus. This is purely commercial purposes and the authorization of Bobo VIERI to use his image wearing his Juve jersey should also have been requested from the famous soccer club since the reputation of its trademarks contributes to the value of the digital card authenticated by NFT.
As for Blockeras’ argument that the marks are not protected in class 9 for virtual goods, the court dismisses it out of hand. In fact, it noted that the marks designate different products, notably in class 9, which are related to “downloadable electronic publications”.
In addition, it states that Juve is active in the world of crypto games, crypto currencies and NFTs especially through agreements with the French company Sorare.
It therefore concludes that the creation and marketing of the digital cards by Blockeras infringes Juve’s trademarks.
Comment (non-sporting)
Last June, the European Intellectual Property Office (EUIPO) published its “guidelines” for NFTs in which it considers that they fall under class 9 “because they are treated as digital content or images”. This raises a presumption that trademarks for physical goods must also be registered for virtual goods if their owners wish to be protected for the latter.
This decision of the Court of First Instance of Rome also seems to point in this direction since it recognizes the similarity between the virtual cards authenticated by NFT with the “downloadable electronic publications” to which products designated by the Juventus trademarks are linked. It is true that the court also considers the marked activity of Juve in the field of crypto games and crypto currencies to reinforce the risk of confusion in the public mind.
Nevertheless, if Juve’s trademarks had not designated products related to downloadable electronic publications, we can wonder if the court would have had the same reasoning despite the soccer club’s activity in these new technologies.
Given the current uncertainties related to NFTs, it is therefore strongly recommended to extend the protection of one’s trademarks to virtual products, at least as a precaution.
Please feel free to contact us to discuss and set up a branding strategy adapted to your needs!
Jean-Charles Nicollet
European Trademark and Design Attorney
05
August
2020
BREXIT and European intellectual property rights: United Kingdom is in transition until December 31, 2020, but what’s next?
The United Kingdom left the European Union on January 31, 2020. However, from an intellectual property point of view, the United Kingdom is still part of the European Union since a transition period has been put in place until December 31, 2020.
The TAoMA News team closely follows these changes and explains the impact of Brexit on your rights.
TRADEMARKS
First of all, if you were wondering whether your European Union trademarks are still valid in the United Kingdom, the answer is YES but only until December 31, 2020!
We explain hereafter the situation of European Union trademarks according to different scenarios.
1st situation: European Union trademarks registered until January 1st, 2021
No change to be expected until December 31, 2020, for:
The registered European Union trademarks;
The European Union trademarks currently under pending registration and the trademarks filed by the end of the transition period and which will be registered by December 31, 2020;
The European Union trademarks expiring before December 31, 2020, and duly renewed before that date (or within the grace period).
For all these trademarks, the UK Office will automatically create equivalent national trademarks on its register. These British equivalencies will be completely independent from the initial EU trademarks but will retain the corresponding filing and priority dates.
The good news is that no action and no cost should be incurred by trademarks owners.
The owners will not be notified by the UK Office and will not receive new registration certificate of their equivalence, but they will be able to access the details of their new trademarks on the UK Office website indicating the EU trademark number, preceded by the reference “UK009”.
Furthermore, these trademarks will have to be renewed before the UK Office when they expire as any national UK trademarks.
If an EU trademark owner does not want to obtain an equivalence, opt-out measures (renunciation to obtain an equivalence) will be possible as of January 1st, 2021, (the corresponding form which will be available on the website gov.uk should not be published before that date).
2nd situation: European Union trademarks in the process of being registered on January 1st, 2021
For the European Union trademarks filed before but not yet registered on January 1st, 2021, applicants will enjoy a period of 9 months (from that date, i.e. until October 1st, 2021) to request the maintenance of their rights in the United Kingdom and have their original European filing date retained.
However, contrary to the registered trademarks, trademarks under pending registration at the end of the period of transition:
Will only be transposed as national trademarks at the request of the owner within 9 months (otherwise, no equivalence will be created);
Will be examined by the UK Office as any new trademark application;
Will be subject to the payment of fees (in the order of £170 for 1 class and £50 for each additional class).
3rd situation: European Union trademarks expiring between January 1st and June 30, 2021
The equivalent trademarks transposed by the UK Office that expire between January 1st and June 30, 2021, will have to be renewed, as will the corresponding European trademark.
The UK Office will send, as far as possible, a reminder to the holder of the expiring equivalent trademark, inviting him to pay a renewal fee.
Given the circumstances, trademark owners will enjoy an additional period of 6 months from the receipt of the reminder from the UK Office to renew their trademarks in the United Kingdom (without surcharge).
Finally, the UK Office already specified that the early renewal of the European trademarks with the EUIPO before December 31, 2020, will not affect the equivalent British trademarks and will not exempt the owners from payment of the British renewal fees.
4th situation: International trademarks designating the European Union
Equivalent measures should be provided for international trademarks designating the European Union.
However, a particularity is to be expected since the British equivalence will be independent of the international trademark. The WIPO will soon provide us with details on the measures planned for these trademarks and the possible actions required by the owners concerned.
5th situation: What about the use and reputation of the European Union trademarks?
Finally, we close this paragraph on trademarks by specifying that the use and the reputation of the trademarks in the European Union, even outside the United Kingdom, in the 5 years preceding the end of the transition period, i.e. December 31, 2020, may be validly invoked in the United Kingdom.
DESIGNS
The same measures will be transposed to the designs, including unregistered Community designs for which a specific register will be created by the UK Office.
This measure is reassuring for the owners of such rights since, unlike conventional registered designs, an unregistered Community design confers a (more limited) protection for a non-renewable period of 3 years from the date of its first publication to the public on the territory of the European Union.
OTHER CONSEQUENCES
However, the Brexit could have a significant impact on contracts (coexistence agreements, engagement letters, licenses), on pending legal actions in United Kingdom as on the the date of January 1st 2021 based on an EU trademark or design, on opposition proceedings before the EUIPO on the basis of UK trademarks, or for .eu domain names registered on behalf of British owners, etc.
Consequently, we recommend you proceed with audits of your current portfolios, contracts and procedures in order to anticipate at best as possible the consequences of the effective exit of the United Kingdom from the European Union.
The entire TAoMA team is mobilized on these issues and remains at your disposal to support you during this transition period.
Marion Mercadier
Juriste
Laura Fretaud
Stagiaire juriste
06
May
2020
Trademarks: New actions available before the INPI since April 1st, 2020
Author:
teamtaomanews
Under the impulsion of the European Union’s (EU) legislation, French trademark law has recently undergone a fundamental change, aimed at harmonizing the different national legislations of the Member States. One of the main effects of the adoption of the government decree No. 2019-1169 of November 13, 2019 is that, since April 1st, 2020, cancellation proceedings of French trademarks or of French designations of International Registrations have been considerably simplified and made much cheaper.
These proceedings are invalidity actions based on relative grounds, including for violation of earlier rights (the owner of earlier rights considers being the first to “occupy the ground”), or on absolute grounds (the trademark is invalid per se because it is descriptive or contrary to the public order) and revocation actions, including when the owner does not genuinely use its trademark or when the latter has become a common name in the trade for a product or service for which it was registered (for example, the trademark “Escalator” for mechanical stairways):
Whereas before the reform judicial courts had exclusive jurisdiction over these actions resulting in the application of dispositions of the Code of Civil Procedure and the obligation to be represented by a lawyer, this competence is from now on shared with the National Institute of Industrial Property (INPI).
The purpose of this article is to present the new rules and the advantages of this reform.
1/ Where does it take place now, and what new can be done?
The reform transferred jurisdiction from the judicial courts to the INPI and the interest to act is not required anymore for some actions, thus increasing the possibilities of obtaining the removal of a trademark from the registers. At the same time, the reform provides new possibilities for the owner of the challenged trademark to defend itself against the applicant of the invalidity action.
New rules on jurisdiction: where to bring the action?
Revocation actions for non-use, which allow to obtain the cancellation from the registers of a trademark registered but not used by its owner, now have to be brought directly before the INPI, whereas previously the action could only be brought before one of the ten courts having jurisdiction corresponding to the domicile of the trademark owner.
The same applies to invalidity actions based on relative or absolute grounds.
The table below summarizes the new jurisdiction rules and those kept unchanged:
These new rules of jurisdiction may give rise to litigation strategies and choices of appropriateness: if the jurisdiction of judicial courts is sought, it may be obtained by adding in the writ of summons claims relating to infringement, or by adding to the basis of the earlier trademark an earlier copyright: in this case, the court’s jurisdiction wins over the INPI’s jurisdiction.
Conversely, to save money, a party could, if it considers that it is in its interest, waive its infringement claims and simply request the cancellation of a trademark directly before the INPI, thus saving itself procedural costs that are higher before judicial courts.
New rules on interest to act: who can bring proceedings?
Litigation strategies will also be influenced by the fact that principal claims for revocation, passing from the judicial courts to the INPI, are no longer subject to an interest to act. The applicant who wants to obtain the revocation of a trademark that it considers not used by its owner will no longer have to prove, for instance, that it has an earlier right to an identical or similar sign and for identical or similar goods to those for which it is seeking revocation.
With the exception of actions based on absolute grounds and actions for revocation, all other actions and claims, whether brought before the INPI or before a judge, involve the demonstration of an interest in bringing proceedings, including the counterclaim for revocation, i.e. the reply made by a defendant to the owner of a trademark who acts in infringement proceedings before a court:
In other words, a party wishing to obtain the cancellation of a trademark will now be able to apply for it before the INPI without being the owner of any earlier right and will be able to target the total cancellation of the trademark even when it owns an earlier mark for only a few goods or services also designated by the contested trademark.
Defenses: what can the owner of the challenged trademark do?
In defense, the owner of the contested trademark may raise several defenses:
It may first challenge the applicant’s interest to act, when such interest is required.
It may then raise the time-limitation (but only if an earlier well-known trademark is invoked) or the foreclosure by acquiescence for invalidity actions based on earlier rights.
It may also request that the action be declared inadmissible:
If the earlier trademark lacked distinctiveness at the date to which the challenged trademark was applied-for, even if distinctiveness was acquired afterwards;
In the absence of notoriety of the earlier trademark at the date to which the challenged trademark was applied-for, when the basis invoked is a well-known trademark, even if the notoriety was acquired afterwards.
Such inadmissibility is not automatic but must be raised in defense by the owner of the contested trademark.
Last but not least, the defendant may require the applicant for a declaration of invalidity of a trademark based on relative grounds to prove that its earlier trademark has been genuinely used during the five years preceding the application for a declaration of invalidity. Furthermore, if the earlier trademark has been registered for more than five years prior to the filing or priority date of the challenged trademark, it shall also be required to furnish proof of use of that earlier mark in the five years preceding the filing or priority date of the contested trademark.
In such a case then, the applicant may be compelled to prove use of its earlier trademark during two different, sometimes overlapping or merging, reference periods.
For instance, if the owner of a trademark registered in 2002 applies on May 15, 2020 for the invalidity of a trademark filed on June 15, 2012, the owner of the earlier trademark will have to prove, upon request of the defendant, the genuine use of its trademark between May 15, 2015 and May 15, 2020, and between June 15, 2007 and June 15, 2012. If the earlier trademark was filed much earlier than the subsequent trademark, the period for which use must be proven is reduced accordingly.
In the case of a subsequent trademark filed on April 15, 2019 and an application for a declaration of invalidity filed on May 15, 2020, the periods overlap since the first is between May 15, 2015 and May 15, 2020 and the latter between April 15, 2014 and April 15, 2019. This results, in practice, in a “continuous period” between April 15, 2014 and May 15, 2020:
All of these defenses will be addressed by the INPI in its final decision.
2/ How does it work and for how long can these proceedings last?
The procedural rules governing new actions brought before the INPI are not the same as the ones applicable before the judicial courts. They should allow a faster treatment of the proceedings.
Introduction of the action
Invalidity or revocation action before the INPI are initiated by the filing of an online form identifying:
The challenged trademark,
The earlier rights claimed, in case of an application for a declaration of invalidity based on relative grounds,
The identity of the applicant,
And the scope of the requested cancellation (all goods and services or only some of them).
The applicant must also attach proof of payment of the official fee of 600 euros (this amount does not include the attorney’s fees) to which may be added 150 euros for each additional prior right invoked in an invalidity action based on relative grounds. No new right may be invoked after the action has been filed, it is therefore necessary to think carefully from the outset about all the rights that may be invoked. However, it is possible to withdraw some of these rights as well as some of the goods and services covered by the application for cancellation, throughout the proceedings.
In any case, apart from the revocation action for non-use, for which it is not mandatory, the applicant shall also attach observations setting out the grounds for cancellation of all or part of the trademark (specifying, for instance, how the earlier trademark is similar or identical, as regards its sign and its goods and services, to the subsequent trademark).
Finally, the action before the INPI can only be either an invalidity action or a revocation action. It is impossible to cumulate the grounds within a single action, whereas it was possible until recently before the judicial courts, with litigants requesting invalidity based on earlier rights and revocation for non-use, for example, and not necessarily one in the alternative to the other, without this constituting a cause of inadmissibility.
Therefore, this change encourages applicants to better define their strategies upstream, even if the reform does not prevent them from bringing two parallel actions on two different grounds, which is even more encouraged by the fact that the cost of these actions is very limited.
Conduct of the proceedings – adversarial phase
Once the application has been filed, the INPI has one month to examine the admissibility of the action and to notify the owner of the challenged trademark, which triggers a series of time limits: a first two-month deadline for the owner to submit its first observations in reply, followed by several one-month time periods allowing the parties to exchange written observations and supporting documents, if they wish to: two sets of observations for the applicant and three for the owner; with the last observations not being able to raise any new ground or attach any new proof of use.
If one of the parties decides not or no longer to make use of its right to submit observations, the adversarial phase can be concluded quickly – with the proviso that the owner of a trademark for which revocation for non-use is sought will still be allowed to submit two sets of observations and proofs of use, even in the absence of a response from the applicant.
At any time, each of the parties, or the INPI itself, may request an oral hearing, which will take place at the end of the adversarial phase.
Finally, the parties may suspend the proceedings at any time, by mutual agreement, for three time periods of four months.
Decision and appeal
The INPI has three months to render its decision following the end of the adversarial phase. In case the INPI does not meet the deadline, the action is deemed rejected.
The proceedings before the INPI can then theoretically last between six months and a year, if no suspension is requested.
The decision may charge the losing party with part or all the costs of the proceedings, at the request of the winning party, but only if the action is totally won or lost: the costs are at each party’s expense if, for example, the decision cancels only part of the goods and services targeted by the applicant.
If no appeal is filed, the decision rendered by the INPI is enforceable. If the trademark is cancelled because of the applicant’s prior right, the cancellation is retroactive and takes effect on the date of filing of the cancelled mark: it shall be deemed to have never existed.
Retroactive cancellation has an effect on third parties (an “erga omnes” effect): for example, if an infringement action was initiated earlier by the owner of the cancelled trademark against a third party, this action may become moot.
On the contrary, the revocation shall take effect on the date of the application for revocation or, at the request of the applicant, on the date on which the ground for revocation arose.
Appeal phase
Once the decision has been rendered, the parties have one month (excluding extended deadlines for DROM-COMs and for foreign residents) to bring an appeal before the one of the ten specialized courts of appeal that is territorially competent, that is to say the one of the domicile of the party bringing the appeal (or before the Paris court of appeal for the appellants residing abroad). Legal representation is mandatory.
Unlike appeals against decisions in opposition proceedings, appeals against decisions in cancellation proceedings are de novo: the parties can provide new supporting documents (including proofs of use) and raise new grounds.
The appeal proceeding in itself follows the usual time limits, and it should be possible to reach a final decision approximately one year after the case has been referred to the court. The appeal proceeding will therefore take longer than the procedure before the INPI.
A writ of certiorari against the appeal decision can of course be filed before the French Supreme Court (Cour de Cassation), even by the INPI.
Instead of appealing the decision, is it possible to re-file the same claims before the INPI?
In the event that a trademark has been validated following a cancellation action, this trademark does not, for all that, become indisputable.
The rule is as follows: when a cancellation action is brought 1° between the same parties having the same quality, 2° with the same object and cause of action and 3° when a final decision has already been rendered either by the INPI or by a judicial court, then the action is inadmissible (“res judicata” principle).
In contrast to this rule, it therefore seems theoretically possible, after a final decision validating a trademark of which invalidity was sought on the basis of an earlier trademark, to bring a new invalidity action on the basis of another right, for example, a domain name, or to bring a revocation action for non-use or loss of distinctiveness.
Similarly, a revocation action which has given rise to a decision to maintain the contested trademark does not preclude the bringing of a new revocation action at a later date, since the reference period during which the owner must have used the mark will not be the same and it remains possible to revoke the rights of an owner that has, in the past, used its mark but is no longer using it.
Many other complex situations may arise and create difficulties in the context of these new actions.
To summarize, here are the advantages of these new actions, available since April 1st, 2020:
The cost for the filing of an invalidity or revocation action is only 600 euros, excluding attorneys’ fees and, in the case of a revocation action, it is not even compulsory to submit observations in reply, which further reduces the procedural costs;
The invalidity action, even on relative grounds, has become imprescriptible since the enactment of the PACTE law (unless the owner of the subsequent trademark can prove that the applicant has tolerated its use in good faith for five years);
The revocation action and the invalidity action based on absolute grounds may be brought before the INPI by anyone, even without an interest to act;
Invalidity actions brought before the INPI are handled within a relatively short period of time, allowing applicants to obtain a decision much more quickly than before the courts;
The invalidity action based on prior rights may be seen as a second chance for earlier owners who would not have initiated opposition proceedings, since the costs and modalities of both procedures are now very similar.
TAoMA Partners, Attorneys-at-law and Intellectual Property Attorneys, is at your disposal should you wish to find out more or take advantage of these new opportunities.
Malaurie Pantalacci
Trademark and Design Attorney, Partner
Jérémie Leroy-Ringuet
Attorney-at-law
Special thanks to Blandine Lemoine, Lawyer, and to Jean-Charles Nicollet, Trademark and Design Attorney, Head of the Trademark and Design Legal Department, for their assistance in the preparation of this article.
06
May
2020
Major changes in the French Trademark Prosecution
Author:
teamtaomanews
The long-awaited upheaval in French trademark law is finally here!
Directive (EU) 2015/2436 of the European Parliament and of the Council of 16 December 2015 to approximate the laws of the Member States relating to trademarks has been transposed in France, at last, following the adoption of an order dated November 14, 2019.
This transposition entails a major overhaul of French trademark law and practice in certain aspects and notably regarding the application and renewal of trademarks.
=> The end of the requirement of graphical representation
Until now, to be eligible to a protection under trademark law, a sign needed to be capable of being represented graphically. Such condition has been abandoned by the new regulation. This abonnement does not necessarily open protection to non-traditional trademarks that were previously refused, such as olfactive or gustative marks, as the legislation still requires the sign applied for to be represented on the Register in a manner which enables anyone to determine precisely and clearly the subject matter of the protection afforded to its proprietor.
Yet, some non-conventional trademarks that were rarely accepted in the past will likely be adopted more easily now, as new formats of representation will become available. For instance, with respect to sound trademarks, it will now be possible to submit audio files, while for the representation of motion trademarks or hologram trademarks, the applicant will be able to furnish video files, gifs, etc.
If opening the trademark filing to new representation formats seems to be good news for future applicants, this will necessarily generate practical issues, in particular in the context of litigation. From now on, how should be compared a traditional verbal mark and a sound mark represented by an audio file? In this specific case, what will become of the visual comparison?
This new disposition will, no doubt, change significantly the office’s practice, which would have to get creative in developing new reasonings.
=> New official taxes
While the old system provided for a single flat fee for the filing of a trademark from one up to three classes, with an additional class fee from the third class onwards, the reform abandoned it in favor of a system of one fee per class.
The same system has been adopted for the renewal of trademarks.
=> Examination
The new disposition broadens the list of grounds for refusal, especially, the number of signs that can constitute opposable prior rights to the filing of a new trademark application. This will make it even more necessary to carry out prior right searches before considering filing any trademark application, as the sign for which registrations will be sought is likely to face more types of obstacles.
Now the following applications can be refused by the French Office:
Signs consisting exclusively of “the shape or other characteristic of the product imposed by the nature of the product itself, necessary to obtain a technical result or which confers substantial value on the product”. The reference to “another characteristic of the product” is new and broadens the ground for refusal specific to shape marks, which can now be applied more broadly and to all marks, and in particular to atypical marks whose filing is facilitated.
A trademark including “appellations of origin and geographical indications, traditional wine names and guaranteed traditional specialities” protected by national or European Union legislation or by international agreements.
A trademark consisting of the name of an earlier plant variety.
A trademark that has been filed in bad faith by the applicant.
The new provision also makes the lack of distinctiveness a proper and independent ground for refusal when, in the past, it was closely link to the condition of non-descriptiveness. Distinctiveness and non-descriptiveness are now two different conditions that a mark should comply with in order to be registered.
=> A new deadline for the renewal of trademark registrations
If, in the past, a trademark could be renewed up to the last day of the expiration month, the renewal would have to be filed, from now on, before the end of the expiration date. An additional period of six months is still allowed to proceed with such a renewal, subject to the payment of an additional fee. The starting point of this 6-month grace period is no longer the day after the expiration month but the day that follows the expiration date.
Our team is at your disposal to assist you and help you to better understand all the workings of this reform.
Blandine Lemoine
Lawyer
Jean-Charles Nicollet
European Trademark & Design Attorney
Head of Legal Department
28
April
2020
Pacte Law: The trademark opposition procedure new generation
Author:
teamtaomanews
We have been waiting for it for several years and France has finally transposed the European Directive 2015/2436 of 16 December 2015, approximating the laws of the Member States on trademarks by the Pacte Law.
One of the major changes in French law concerns the reform of the opposition procedure before the INPI against a trademark application infringing the prior rights of a third party. This new-generation opposition applies only to French trademarks, or international trademarks designating France, filed on or after December 11, 2019. For trademarks filed before this date, the old procedure remains applicable.
We therefore offer you a comparison between the new and the old opposition proceedings.
Grounds for opposition
The old opposition was characterized by the obligation to invoke only one prior right per procedure. Thus, if a holder wished to base his opposition on two trademarks, he had no choice but to file two oppositions.
The new procedure makes it possible to invoke several earlier rights in the same opposition. Similarly, the earlier rights that can be used to support the opposition procedure have been extended.
The official tax has changed and is now of €400 for the fist prior right invoked and of €150 for any additional rights invoked.
Course of the procedure
If the deadline to file an opposition is still of two months from the publication of the contested trademark, it is now possible to file a formal opposition. The brief setting out the arguments in support of the action must be submitted within 1 month of the expiry of the opposition period.
The adversarial principle has also been strengthened since the parties can exchange several sets of written submissions in order to make their case. In return, the opposition procedure is lengthened and can last up to 10 months before the final decision is taken, as opposed to a maximum of 6 months under the old procedure.
As part of his defense, the applicant of the contested mark may require the opponent to provide proof of genuine use of the earlier marks invoked which have been registered for more than 5 years. Such a possibility was already available in the old opposition proceedings.
However, the INPI now has the power to exercise a thorough control of the evidence to be provided by the opponent. It will therefore be necessary for the latter to be in a position, prior to the initiation of opposition proceedings on the basis of a trademark registered for more than 5 years, to provide proof of genuine use of the trademark for all the goods and/or services invoked in the context of the proceedings.
The new generation opposition procedure is therefore a major step forward for holders of prior rights by providing them with a broader basis for action and a strengthened adversarial principle. The other side of the coin is the need to demonstrate the genuine use of its trademarks registered for more than 5 years, at the request of the defendant, for all the goods and/or services invoked in support of the opposition.
Jean-Charles Nicollet
European Trademark and Design Attorney
Head of Legal Department
14
April
2020
A new chance for the European Union trademark application “FACK JU GÖTHE”
The word mark “FACK JU GÖTHE” can be registered as a European Union trademark, decided the Court of Justice of the European Union in a decision dated February 27, 2020. This decision overrules the European Union intellectual property office (EUIPO) decision, confirmed by the General Court, that this applied-for mark was contrary to the Article 7, (1), (f), of Regulation No.207/2009 [1], namely, contrary to principles of morality which.
As we have seen in our previous news concerning the opinion of the Advocate General Bobek (read our TAoMA News of July 18, 2019 in French), the company Constantin Film Produktion Gmbh, filed in 2015 the European Union Trademark Application “FACK JU GÖTHE” before the EUIPO. If this sign is intended to designate various goods or services of daily life, it is also the title of a German comedy movie which enjoyed great success in German-speaking countries and had several sequels.
The EUIPO, approved by the General Court, refused registration of this word sign on the ground that the first words “FACK JU” were phonetically identical to the English insult “FUCK YOU” and that the sign taken as a whole was therefore an expression of bad taste, offensive and vulgar, by which the writer Johann Wolfgang Goethe was posthumously insulted [2], and this, notwithstanding the applicant’s arguments as to the context surrounding the release of the film bearing the same name.
Constantin Film Produktion GmbH then brought an appeal before the Court of Justice against the latter decision, alleging, inter alia, errors in the interpretation and application of Article 7(1)(f) of Regulation No 207/2009, which excludes from registration trademarks “contrary to public policy or to accepted principles of morality”.
Following the reasoning of Advocate General Bobek, the Court, in its decision of 27 February 2020, annuls the decisions of the General Court and the EUIPO.
According to the Court, the EUIPO and the General Court disregarded the standards required by Article 7(1)(f) of Regulation No 207/2009, in the light of which it is necessary to carry out an analysis of all the elements specific to the case in order to determine precisely how the relevant public would perceive the sign in question.
Indeed, the EUIPO, as well as the General Court, relied solely on an abstract assessment of that mark and of the English expression to which the first part is assimilated. But the Court considers that they should have examined more carefully the social context and the factual elements invoked by the applicant and should have explained more conclusively the reasons why these elements had been left out of its analysis.
Among these factual elements, there was more than convincing evidence: in particular, the great success of the comedy movie of the same name and the fact that its title does not appear to have caused controversy among the German-speaking public. In addition, the young audience had been allowed to see the film when it was released and was the primary target. Finally, the Goethe Institute, which is a reference in the promotion of the German language on a national and worldwide level, used it for educational purposes.
Furthermore, the Court underlines the fact that the perception of the English expression “FUCK YOU” by the German-speaking public is not necessarily the same as its perception by the English-speaking public. While it is true that this expression is well known to the non-English-speaking public, its semantic content may be slightly different or even diminished in a foreign language. It is especially true in the present case because the first part of the trademark application at issue does not consist of the English expression as such, but of its phonetic transcription in German, accompanied by the element “Göthe”.
In the light of all these factors, the Court considers that the EUIPO and the General Court misinterpreted and misapplied Article 7(1)(f) of Regulation No. 207/2009 and, accordingly, cancels the corresponding decisions.
Finally, as we indicated in our previous TAoMA News, Constantin Film Produktion GmbH also invoked freedom of expression as an element to be taken into account in the assessment of Article 7(1)(f) of Regulation No. 207/2009. While the Court is less affirmative than its U.S. counterpart (the U.S. Supreme Court has recently ruled that the US Trademark Act on immoral, misleading or scandalous trademark is contrary to the freedom of expression guaranteed by the US Constitution, see our TAoMA News of July 4, 2019 in French), it acknowledges, for the first time to our knowledge, that freedom of expression must be taken into account when applying this provision of trademark law in order to ensure respect for fundamental rights and freedoms, in particular in accordance with Article 11 of the Charter of Fundamental Rights of the European Union [3].
The future of the trademark “FACK JU GÖTHE” is now in the hands of the EUIPO which will, for the second time, have to proceed with its examination. Full of learnings, the decision of the Court should probably influence the latter and lead to the registration as a trademark.
Baptiste Kuentzmann
Lawyer
Read the decision on CURIA.
[1] Article 7 (1)(f) Regulation (EU) 207/2009: “1. The following shall not be registered: (…) f) trademarks which are contrary to public policy or to accepted principles of morality”. Applicable provision in this case, now replaced by Regulation (EU) 2017/1001 ;
[2] EGC, January 24, 2018, T-69/17, Constantin Film Produktion/EUIPO (Fack Ju Göthe) ; Fifth Board of Appeal of the EUIPO, December 1, 2016, R 2205/2015-5, (Fack Ju Göthe) ;
[3] Article 11 of the Charter of Fundamental Rights of the European Union: “1. Everyone has the right to freedom of expression. This right shall include freedom to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers.”
07
April
2020
Impact of revocation for non-use on an infringement action based on the revoked trademark
Author:
teamtaomanews
The complex trademark SAINT GERMAIN was registered in France on May 12, 2006 by the company AR for alcoholic beverages, ciders, digestives, wines and spirits. For its part, the company COOPER International Spirits distributed, under the name “St-Germain”, a liqueur manufactured by the companies St Dalfour and Etablissements Gabriel Boudier.
On June 8, 2012, AR sued these three companies for trademark infringement before the Paris court of first instance. However, in parallel proceedings, the Nanterre court of first instance ruled that AR’s rights to the complex SAINT GERMAIN trademark would be revoked for non-use as of May 13, 2011, first day following the grace period. The owner of the revoked registration nevertheless maintained its infringement action targeting now acts committed during the period prior to revocation, i.e., between June 8, 2009 and May 13, 2011, a period during which the mark was not yet subject to prove use.
In 2015, all its claims were dismissed by the Paris court of first instance; the judgment was upheld by the Paris Court of Appeal, on September 13, 2016. The Court held that AR could not claim infringement of the SAINT GERMAIN trademark by an identical sign in competition with it, while it did not present any probative evidence of the trademark’s genuine use. The judges therefore seem to have subordinated the potential conviction for infringement to the proof, missing here, that its owner was exploiting it, even though the five-year period for starting the use of the trademark was still running.
The French supreme court, before which a writ of certiorari was filed, decided to stay proceedings and to refer the matter to the Court of Justice of the European Union (CJEU) for a preliminary ruling. In essence, the question referred to the CJEU was to determine whether the owner of a trademark which has been revoked due to a lack of genuine use, nevertheless retains the right to claim compensation for damages suffered as a result of the use by a third party – prior to the effective date of revocation – of a similar sign which creates a likelihood of confusion with its trademark.
Possibility of compensation for damages prior to the effective date of revocation for non-use
The Court points out first of all that, according to its own case-law, the owner of a trademark which has not yet been put to genuine use – that is to say, before the end of the five-year period following its registration – may very well bring an infringement action on the basis of the goods and services designated, without having to prove that it is using its trademark (CJEU, 21 December 2016, Länsförsäkringar, C-654/15).
However, the situation is different in the present case. The difficulty lies precisely in the scope of the owner’s rights on the trademark at the end of the period of grace, even though the revocation has already been ordered. In a nutshell, can such a revocation affect the owner’s ability to claim for damages, after the expiration of the period of grace, for infringements of its trademark during that period?
The CJEU gives a positive response, holding that the Member States have“the option of allowing the proprietor of a trade mark whose rights in that mark have been revoked on expiry of the five-year period from its registration because he or she failed to make genuine use of the mark in the Member State concerned in connection with the goods or services for which it was registered to retain the right to claim compensation for the injury sustained as a result of the use by a third party, before the date on which the revocation took effect, of a similar sign in connection with identical or similar goods or services that is liable to be confused with his or her trade mark”.
Indeed, it recalls that Directive 2008/95 left it to the Member States to determine the extent of the effects of the revocation of a trademark and that the French lawmaker has chosen to make the revocation effective as from the expiration of the grace period and not earlier. France has therefore not chosen to allow the alleged infringer to raise the objection of lack of use during the grace period to exempt itself from liability for acts of infringement.
Thus, the owner of a mark which has been revoked for lack of genuine use retains the right to claim compensation for the damages suffered as a result of the use, by a third party, prior to the effective date of revocation, of a similar sign creating a confusion with its mark.
Considering the lack of genuine use during the grace period in the calculation of the damages
The CJEU then specifies the scope of its own decision, stating that the lack of genuine use during the grace period is still an “an important factor to be taken into account in determining the existence and, as the case may be, the extent of the injury sustained by the proprietor and, accordingly, the amount of damages that he or she might claim”.
Thus, the prejudice suffered by the owner of a trademark that does not use it is restricted to the infringement to the right of ownership and excludes compensation for loss of earnings and for unfair profits. Moral damages are equally relative.
Taking into account the lack of use takes its last ammunition from the owner of a revoked trademark. If French law allows it to assert its trademark for acts anterior to the effective date of revocation, it would indeed be inappropriate for the owner to be able to claim substantial damages. This would indeed amount to the legitimization of the practice of “trademark trolls“, those trademark owners that do not exploit their portfolios and use them only to extort money from third parties wishing to use them, through licensing agreements or infringement actions.
The clarification of the EUCJ tempers its answer to the preliminary ruling request and allows to sanction such practices: the owner of a revoked trademark may claim compensation for acts infringing its trademark before the date on which the revocation took effect but, if it did not exploit it, its compensation will be limited.
Synthia TIENTCHEU TCHEUKO
Trainee Attorney
Jérémie LEROY-RINGUET
Attorney-at-law
Reference and date: Court of Justice of the European Union, March 26, 2020, C‑622/18
Read the decision on Curia
13
February
2020
ECJ’s « Sky » decision: a whistle in the wind?
Author:
teamtaomanews
Failing to force holders to restrict the goods/products designated by their trademarks, is the ECJ whistling in the wind?
The British satellite and cable television operator Sky, who holds several eponymous trademarks, took legal action, in the United Kingdom, for infringement of those trademarks against the Cloud service provider SkyKick, who had registered the trademark “Skykick” and variations thereof. The startup counterclaimed that the registration of the trademarks relied on by Sky was wholly or partially invalid on the grounds that (i) the lists of goods and services in respect of which the trademarks were registered lacked clarity and precision and (ii) the applications for registration had been filed in bad faith. Indeed, the trademarks had been filed to protect “software”, “communication systems” and “television” services, when in reality only one activity was considered: the sale of a satellite pay-TV package.
From a strategic point of view, the stakes of this case are essential since it deals with a major issue in trademark legislation. It is indeed important, when applying for a trademark, to have a forward-looking vision and to consider whether new products/services could be marketed under this sign. However, this logic must not lead to the monopolization of signs for a very broad list of goods and services when their owners have no intention of using the aforementioned signs for all of them.
The High Court of Justice (England and Wales), before which the proceedings were brought, decided to stay the proceedings and to refer a number of questions to the European Court of Justice (ECJ) for a preliminary ruling.
Lack of clarity and precision of goods and services for which the trademark is registered: an absolute ground for invalidity?
As a reminder, in 2012[1], the ECJ delivered a resounding judgment[1] in which it ruled that an applicant for a trademark must designate the goods and services for which protection is sought with sufficient clarity and precision, failing which the application must be dismissed.
SkyKick attempted to extend this logic to registered trademarks, but the Court held that a trademark of the European Union or a national trademark “cannot be declared wholly or partially invalid on the ground that terms used to designate the goods and services in respect of which that trade mark was registered lack clarity and precision“, since this requirement is not part of the exhaustive list of absolute grounds for invalidity provided for in the texts.
Overly broad range of good and services at the time of application: ground for invalidity based on bad faith?
While a trademark may be declared invalid if the applicant was acting in bad faith when submitting the application, this notion is not defined by the texts.
The European judges had already had the occasion to offer some possible interpretations, holding that bad faith is established when it is apparent from relevant and concordant indicia that the proprietor of a trademark has filed the application for registration not with the aim of engaging fairly in competition, but with the intention of undermining , in a manner inconsistent with honest practices, the interests of third parties, or with the intention of obtaining, without even targeting a specific third party in particular, an exclusive right for purposes other than those falling within the functions of a trademark, in particular the essential function of indication of origin[2] (see our TAoMA News of November 4, 2019).
With regard, more specifically, to the registration of a trademark without any intention of using it for the goods and services covered by the registration, the ECJ considered that it is likely to constitute an act of bad faith, which may affect all of the goods and services covered by the registration or only some of them. However, such bad faith can only be established if there are objective indications that the applicant intended to harm the interests of third parties in a manner contrary to honest practices or to obtain an exclusive right for purposes other than those falling within the functions of a trademark at the time of filing.
Finally, the ECJ declares that EU law does not preclude a provision of national law from requiring an applicant for registration of a trademark to state that this trademark is used in connection with the registered goods and services, or that he has a bona fide intention to do so, n so far as the infringement of such an obligation does not constitute, in itself, a ground for invalidity of a trade mark already registered.
Although this decision is a first step towards cleaning up the registers of European offices, which are cluttered with unused trademarks, it does not mark the 180° shift that some had expected and endorses a kind of status quo of the current trademark system under EU law, leaving a heavy burden on third parties to challenge the good faith of an owner.
If the recent Trademark Package – and its implementation into French law – does not directly address this issue, the single fee for trademark registration (the cost of which did not vary between one and three classes) it introduced could be an incentive for applicants to think twice before registering their trademarks for too many goods and services.
Date and reference: European Court of justice, January 29th 2020, decision C‑371/18
Read the decision on Curia
Synthia TIENTCHEU TCHEUKO
Trainee-Lawyer
Anita DELAAGE
Lawyer
[1] ECJ, june 19th 2012, C-307/10 « Chartered Institute of Patent Attorneys » known as IP Translator decision
[2] ECJ, september 12th 2019, C-104/18 « Koton Mağazacilik Tekstil Sanayi ve Ticaret/EUIPO »
04
November
2019
EU Court of Justice “cottoned” on to trademarks and bad faith
Author:
teamtaomanews
An applicant, holder of earlier semi-figurative trademarks KOTON designating the European Union territory, filed an opposition before the EUIPO against the application for registration of the trademark STYLO & KOTON filed-for in classes 25,35 and 39. As for the earlier trademarks, the term KOTON included a cotton flower which both vowels were stylized.
The opposition was successful only in classes 25 and 35 which allowed the registration of the STYLO & KOTON trademark for the services of the class 39.
As a consequence, the applicant filed a cancellation action against the trademark for the services of the class 39 but also for the goods and services of the classes 25 and 35 on the basis of a filing in bad faith, according to Article 52(1)(b) of the European regulation No.207/2009 that was applicable at the time when the application was filed.
The cancellation division and then the EUIPO board of appeal having rejected the cancellation action, the applicant appealed to the General Court of the European Union which also reject the argument of a filing in bad faith.
The European regulation n°207/2009 of 26 February 2009 does not offer a definition of “bad faith” but strictly refers to a filing made by an applicant “of bad faith” (EUTMR, art.59(1)(b)).
The Court of Justice of the European Union (“CJEU”) has tried to define it, in particular in the Chocoladefabriken Lindt & Spüngli judgment of 11 June 2009 (ECJ, 11 June 2009, C-529/07, pt. 53) stating that the bad faith of the applicant must be assessed globally taking into account all the factors relevant to the circumstances of the case and existing at the time of filing, and in particular:
the fact that the applicant knows or must know that a third party uses, in at least one Member State, an identical or similar sign for an identical or similar product or service which creates a risk of confusion with the applied-for sign;
the intention of the applicant to prevent that third party from continuing to use such a sign;
the degree of legal protection enjoyed by the sign of the third party and the applied-for sign.
According to the General Court, the judgment of 11 June 2009, Chocoladefabriken Lindt & Sprüngli does not mean that the existence of bad faith can only be found in the hypothesis, which the Court was then questioned on, where there is use on the internal market of an identical or similar sign for identical or similar goods which are confusing with the applied-for sign. This is only a relevant factor among others to be considered (points 51-55).
By following this approach, the General Court refrained from taking into consideration, in its overall assessment, all the relevant factual circumstances as they arose at the time the application was filed. This, it should have been taken into account that the trademark owner had requested the registration of a sign bearing the stylized word ‘KOTON’ as an EU trademark not only for services in class 39, but also for goods and services in classes 25 and 35 which corresponded to those for which the applicant had registered trademarks bearing that stylized word (points. 59-60).
Moreover, the General Court raised, only for the sake of completeness, the fact that there had been commercial relations between the trademark owner and the applicant and that they had been broken by the applicant; it also refrained from examining whether the application for a trademark containing the stylized word “KOTON” for goods and services in classes 25, 35 and 39 presented a commercial logic with regard to the activities of the trademark owner (point 62).
As the EUCJ decided to cancel the judgment of the General Court and the decision of the Board of Appeal, it is for the EUIPO board having jurisdiction to take a new decision on the basis of an overall assessment which takes into account the application for the contested trademark as filed for goods and services not only in class 39, but also in classes 25 and 35.
Alexis Valot
Lawyer
Anne Messas
Attorney at law, partner
Read the decision here