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13-11 | 20 July 2011

Topics: EUIPO Convergence Programme EUIPO Cooperation Fund Geographical Indications Plain Packaging

ECTA 2011 AUTUMN GAZETTE

The Publications Committee has started working on the Autumn 2011 Gazette the main theme of which will be "Study on the Overall Functioning of the European Trade Mark system" issues. Should you be interested in contributing in respect of any subject falling within this theme, please contact the Publications Committee as soon as possible by sending an e-mail to sandrine.peters garrigues.com. The deadline for submission of articles is 10 September 2011.


ECTA 2011/2012 MEMBERSHIP DIRECTORY

In preparation for the re-print of the Membership Directory, we kindly ask members to update their contact details by logging onto the "Members area" of the ECTA website using the user name and password allocated to them. Select “Member” and under "my information" select “modify” where you can check and amend (if necessary) the contact details we hold on file for you.


ECTA - WIPO - GRUR - DPMA WORKSHOP ON INTERNATIONAL REGISTRATION OF DESIGNS HAMBURG, GERMANY, 26 SEPTEMBER 2011

After successful events in London in February, Rome in March and Paris in July 2011, ECTA is pleased to invite you to attend a further workshop on international registrations of designs in order to promote the Hague System and to evidence its great advantages. This workshop, held in collaboration with our Sister Association GRUR, WIPO and DPMA, will take place in Hamburg on 26 September 2011. The language of the event will be English. ECTA and GRUR are kindly offering a free walking lunch prior to the event.

For further information see the Programme. To register kindly complete and return the Registration form.


Table of Contents

1 LAW
1.1 Trade Marks
  • OHIM Cooperation Fund – Lord Mogg and Simon White’s update – ECTA accepted candidates for Working Groups, projects packet 2
  • Proposed Australian “Tobacco Plain Packaging Bill in Australia” - EU’s comments before WTO}
1.2 Enforcement
  • Publication of reports on the outcome of the public consultation re the Commission report on the implementation of the Directive 2004/48/EC on the enforcement of intellectual property rights and public hearing of 7 June 2011 - DG MARKT
  • Annual report on customs seizures at the EU borders of products suspected of infringing IPRs- DG TAXUD
  • Joint customs operation results in major seizures in the EU
1.3 Geographical Indications
  • ECTA’s letter to OHIM
  • ECTA at the WIPO Worldwide Symposium on Geographical Indications from 22 to 24 June 2011 in Lima
2 OFFICE PRACTICE
2.1 OHIM
  • ECTA’s letter to OHIM President re Convergence Programme
  • Changes to seniority data in CTM register
  • Expert exchange on image recognition
  • IPR2 closing event in China
  • Progress to modernise Greek trade mark system
2.2 WIPO
  • 3rd session of WIPO Working Group on the Digital Access Service for Priority Documents from 12 to 15 July 2011 in Geneva
  • 9th session of WIPO Working Group on the Legal Development of the Madrid System for the International Registration of Marks from 4 to 8 July 2011 in Geneva
3 CASE LAW

Summaries and case law provided by

GENERAL COURT

T-318/09 TDI
The trade mark is descriptive and it could not be concluded that the sign had acquired a distinctive character

T-160/09 Ophtal vs. OFTAL CUSI
There is no likelihood of confusion

T-88/10 GLANZ vs.GLANSA
There is a likelihood of confusion

T-222/10 ZURCAL vs. ZUFAL
There is a likelihood of confusion

COURT OF JUSTICE

C-263/09 ELIO FIORUCCI vs. ELIO FIORUCCI
The General Court did not err in law when interpreting article 8(3) of the Italian Industrial Property Code that protects well known personal names

Case C-324/09 of 12 July 2011, L’Oréal e.a. vs. eBay International AG e.a.
Sale of infringing goods on an online marketplace - Liability of the operator

Case C-46/10 of 14 July 2011, Viking Gas A/S vs. Kosan Gas A/S
Refilling composite bottles of gas protected by trade mark registrations

4 ECTA NEWS
  • ECTA speaker at WIPO Symposium of Intellectual Property Authorities - Services for Access to Knowledge in Promoting Innovation and Creativity from 22 to 23 September 2011 in Geneva

Editorial Board: Anne-Laure Covin, Annick Mottet Haugaard, Jean-Jo Evrard, and Cathy van Vuuren


The ECTA Flash is sponsored by

TRADE MARK SERVICES


1 Law

1.1 Trade Marks

OHIM Cooperation Fund – Lord Mogg and Simon White’s update – ECTA accepted candidates for Working Groups, projects packet 2

The OHIM Cooperation Fund Manager, Simon White, informed ECTA on 7 July 2011 that 2 candidates had been accepted for the Working Groups connected to projects of the packet 2 of the Cooperation Fund (ref to FLASH 09-11):

CF 321 Common call centre:
Imogen Wiseman, Member of the ECTA Law Committee

CF 423 Harmonised counterfeiting data collection standard:
Marius Schneider, Chair of the ECTA Anti-Counterfeiting Committee

The first kick off meetings for projects of package 2 are planned for the last week of September 2011 at OHIM in Alicante. Meanwhile, the other ECTA volunteers for package 1, are working on the other projects.

Meanwhile, the Chair of the Cooperation Fund (CF) Management Board, Lord Mogg and Simon White, provided the Members of the OHIM Administrative Board and Budget Committee and Observers with an update on 19 July 2011 in their communication (including status of projects for packages 1 and 2). All projects of the CF have been launched with 2 exceptions: the Harmonised Quality Management System, and the Harmonised Forecasting Methodology, “on which launch decisions will be taken next year based on the status of the Fund and progress in other projects”. Every Trade Mark and Design Office in the EU is now involved either at Working Group or Implementation level in at least one project. During the 14/15 November ABBC meeting, an update on the status and advancement of all the CF projects will be provided.

Further details have been provided in the following Annexes:
Annex 1 - Summary slides on project progress,
Annex 2 - Programme tracking table
Annex 3 - Original Packet 2 Applications
Annex 4 - Final list of working group members per project for Packet 2
Annex 5 - National offices intent to implement project deliverables, 2011-2014
Annex 6 - National offices and User Associations’ representation in projects under Packets 1 and 2


Proposed "Tobacco Plain Packaging Bill in Australia" - EU’s comments before WTO

Australia introduced a new draft bill regulating the appearance and features of tobacco packaging. According to the "Tobacco Plain Packaging Bill 2011" draft legislation (to be debated in July 2011), all tobacco products sold in Australia would have olive-coloured plain packaging as of 1 July 2012. No logos or brand images would be permitted on the packaging. The product brand name would appear in uniform font on the front, top and bottom of the package, and graphic health warnings would continue to be displayed. The rest of the packaging would contain textual and pictorial health warnings.

The Australian Authorities notified on 8 April 2011 the draft and the public consultation on it in the document G/TBT/N/AUS/67 (containing details of the requirements) to the Committee on Technical Barriers to Trade of the World Trade Organisation (WTO) for possible comments.

The European Union made written comments regarding this notification on 1 June 2011. While the EU is considering plain packaging amongst the future policy options in the ongoing EU impact assessment, they questioned Australia on several aspects: evidence base, evaluation of alternative solutions, assessment of the impact on illicit trade, how this fits with legal obligations Australia has vis-à-vis WTO and TRIPs.

The Australian “plain packaging” bill was discussed during the meeting of the Technical Barriers to Trade of the WTO which took place on 15 and 16 June 2011.
14 Members raised trade concerns with Australia’s measure. While some Members did not challenge Australia’s public health objectives, they argued that such regulations could create an unnecessary barrier to trade, since they viewed the measure as more trade restrictive than necessary to achieve Australia’s public health objective. More details can be found HERE.

This issue was also raised at the TRIPS Council on 7 June 2011. More details can be found HERE

ECTA took part in the public consultation on the Directive 2001/37/EC1 on the approximation of the laws, regulations and administrative provisions of the Member States concerning the manufacture, presentation and sale of tobacco products, launched by DG SANCO in 2010 and submitted its comments in December 2010 expressing its serious concerns from an Intellectual Property point of view on DG SANCO’s proposal regarding possible plain packaging (see FLASH 22-10). ECTA should meet representatives of the Cabinet of Commissioner Dalli in the Autumn 2011. DG SANCO has not yet published its Impact Assessment and there are still internal discussions within the Commission regarding the proposed legislative package. The UK Government should also launch in Q4 2011 a consultation on plain packaging.


1.2 Enforcement

Publication of reports on the outcome of the public consultation re the Commission report on the implementation of the Directive 2004/48/EC on the enforcement of intellectual property rights and public hearing of 7 June 2011– DG MARKT

The Commission has recently published a synthesis report on the outcome of the public consultation conducted earlier this year regarding the Commission report on the implementation of the Directive 2004/48/EC on the enforcement of intellectual property rights.

The written comments of individuals, organisations (such as ECTA’s contribution of April 2011, see FLASH of 07-11), public authorities (such as the European Committee Parliament on legal affairs) can be found HERE.

The Commission has also published a summary report on the public hearing (which took place on 7 June 2011 in Brussels) on the Directive 2004/48/EC and the challenges posed by the digital environment.


Annual report on customs seizures at the EU borders of products suspected of infringing IPRs- DG TAXUD

The Commission published on 14 July its annual report on customs seizures at the EU borders of products suspected of infringing IPRs. According to the report, the number of shipments stopped by customs almost doubled compared to last year, rising from 43,500 in 2009 to almost 80,000 in 2010. In 2010, customs seized at the EU borders more than 103 million products suspected of violating IPRs. For the first time, the report also indicates the value of the goods detained which is estimated at over € 1 billion. The top categories of articles stopped by customs were cigarettes (34%), office supplies (9%) other tobacco products (8%), labels, tags and emblems (8%), clothing (7%) and toys (7%). 14.5% of all detained articles were household products such as shampoos, soaps, medicines or household appliances (hair dryers, shavers, computer parts) which could potentially have health and safety implications for consumers. One of the major trends this year is the growing number of detentions of postal packages.

The Commission press release and the full report can be found HERE.


Joint customs operation results in major seizures in the EU

In April of this year Joint Customs Operation “Fireblade” succeeded in confiscating more than 28,000 units of counterfeit clothing, accessories and cigarettes that were destined to enter the EU by road via the Eastern border. READ ARTICLE FROM JAMES L. BIKOFF AND SASKIA FIKKERS.


1.3 Geographical Indications

ECTA’s letter to OHIM

ECTA sent a letter to the President of OHIM, António Campinos, on 13 July in connection with the policy of the OHIM on the examination of CTMs containing or revoking GIs, the OHIM’s GI database and the possibility to have a round table in Alicante on the subject. This letter was drafted under the leadership of Florent Gevers, Jan Wrede, Benjamin Fontaine, respectively Chair, Vice Chair and Secretary of the ECTA Geographical Indications Committee and with the collaboration of Andreas Renck, Chair of the ECTA OHIM Link Committee, and Annick Mottet Haugaard, ECTA President. The letter has been posted on the website at the GIs Committee - papers section.


ECTA at the WIPO Worldwide Symposium on Geographical Indications from 22 to 24 June 2011 in Lima

Benjamin Fontaine, Secretary of the ECTA Geographical Indications Committee, attended, as the ECTA speaker, the WIPO Worldwide Symposium on Geographical Indications which took take place in Lima from 22 to 24 June 2011. All official documentation can be found HERE. READ BENJAMIN FONTAINE’S REPORT.

2 Office Practice

2.1 OHIM

ECTA’s letter to OHIM President re Convergence Programme

As part of its Strategic Plan, OHIM is initiating a comprehensive programme through which a convergence of practices in trade mark and design matters shall emerge with a view to further harmonize practices relating to the registration of these rights at the European level.
Following the OHIM President’s letter and Programme Brief of 21 June 2011 (ref to FLASH 12-11), ECTA sent a letter to António Campinos on 15 July. This letter was the result of the great work by the Chair of the ECTA Harmonization Committee, Monika Wenz and contributions from Fabio Angelini, Chair of the ECTA Law Committee, Andreas Renck, Chair of the ECTA OHIM Link Committee and António Andrade, Chair of the ECTA Design Committee.


Changes to seniority data in CTM register

OHIM has provided an update on its website regarding the project to harmonise seniority databases in the EU. OHIM is cooperating with a number of national offices to compare entries held nationally with those in the CTM Register. The project involves establishing links between entries in the national and Community databases and making the information accessible online, in order to provide better IP protection and greater legal certainty for users. As a result of the project, formatting corrections may be introduced in the CTM Register for the numbering of the registration numbers of some national trade marks in order to match the format in the national office. If there are substantial differences, or corrections are needed, the Office will carry out the corresponding Recordal and publish the information in the CTM Bulletin. For all such Recordals, owners or their representatives will receive a communication informing them about the change introduced.

The work is being carried out as part of the Cooperation Fund project, "Creation and harmonisation of seniority databases", which aims to provide a harmonised vocabulary, and the tools and resources needed to provide end users with better information on seniority claims. Andreas Renck, Chair of the ECTA OHIM Link Committee is currently taking part in this project and providing all his input for the benefits of the users.The national offices taking part are: Bulgaria, Czech Republic, Estonia, France, Hungary, Ireland, Portugal, Lithuania, Romania, Greece, and United Kingdom.


Expert exchange on image recognition

Experts from OHIM took part in a workshop on 8 July in Beijing, China which dealt with the technical issues related to image recognition in the publication of designs. The event was run under the EU-China IPR2 project and was a follow up to the comparative study on design registration already carried out by OHIM and the Chinese State Intellectual Property Office (SIPO). It is also part of the continued expert exchanges agreed by the two organisations. OHIM received details of SIPO’s image recognition database and shared information on preliminary work on the ImageSearch project planned under the Cooperation Fund.


IPR2 closing event in China

A delegation from OHIM was in Beijing on 15 July 2011 to take part in the closing event for the EU-China IPR2 project. Experts from the Chinese Ministry of Commerce, the EU Delegation to China, the European Patent Office and OHIM, joined by leading IP and industry figures in presenting the key areas of the programme, evaluating the results and discussing the lessons learned. IPR2’s four year programme of cooperation and knowledge-sharing officially will come to an end in September 2011.


Progress to modernise Greek trade mark system

The Greek Secretary General of Commerce, Stephanos Komninos, politically responsible for the Greek Trade Mark Office, visited OHIM this month as part of a modernisation drive to reform his country’s tools and practices on trade marks. The video interview can be found HERE.


2.2 WIPO

3rd session of WIPO Working Group on the Digital Access Service for Priority Documents from 12 to 15 July 2011 in Geneva

ECTA, represented by Joao Jorge, Member of the ECTA Design Committee, attended the 3rd session of WIPO Working Group on the Digital Access Service for Priority Documents which took place from 12 to 15 July 2011in Geneva. The official working documents can be found HERE. The ECTA report will be published in the next Flash.


9th session of the WIPO Working Group on the Legal Development of the Madrid System for the International Registration of Marks from 4 to 8 July 2011 in Geneva

ECTA represented by Benjamin Gevers, Member of the ECTA Internet Committee attended the 9th session of the Working Group on the Legal Development of the Madrid System for the International Registration of Marks from 4 to 8 July 2011 in Geneva. All working documents and the Summary of the Chair can be found HERE. The ECTA report will be published in the next Flash.


3 Case Law

Summaries and case law provided by Darts IP

GENERAL COURT

On absolute grounds for refusal

Case T-318/09 of 6 July 211, AUDI AG and VOLKSWAGEN AG vs. OHIM (contested decision: R 226/2007-1 of 14 May 2009)

Trade mark:

TDI

Class: 12

Decision:
1. The trade mark is descriptive since it is the abbreviation of “turbo diesel injection” or “turbo direct injection” (para. 18).
2. As the sign TDI is inherently descriptive throughout the European Union, the acquisition of distinctive character through use must be proved in respect of each of the Member States of the European Union (para. 48). The applicant has adduced insufficient evidence of the acquisition of distinctive character through use in Ireland, Denmark and the Netherlands (para. 66). For the sake of completeness, it could not be concluded that the sign TDI had been used as a mark since that sign was either used in a directly descriptive manner or appeared in advertising material along with other marks of the applicants which are distinctive (para.69).

The Board of Appeal’s decision is upheld.


On relative grounds for refusal

Case T-160/09 of 14 July 2011, Dr. Robert Winzer Pharma GmbH vs. OHIM – Alcon Inc. (contested decision: R 1471/2007-1 of 4 February 2009)

Trade marks:

Ophtal OFTAL CUSI
Earlier trade mark Community trade mark applied for

Class: 5

Decision: The trade marks are visually (para. 84 to 86) and aurally (para.87) similar. There is a remote conceptual similarity that is insufficient to outweigh the visual and aural similarities (para. 88). There is no likelihood of confusion (para. 98).
The Board of Appeal’s decision is upheld.


Case T-88/10 of 13 July 2011, Inter IKEA Systems BV vs. OHIM – Meteor Controls International Ltd (contested decision: R 529/2009-2 of 1 December 2009)

Trade marks:

GLANZ GLANSA
Earlier trade mark Community trade mark applied for

Class: 11

Decision: The trade marks are visually (para. 28 to 35) and aurally (para.36 to 42) similar. There is a likelihood of confusion (para. 48).
The Board of Appeal’s decision is upheld.


Case T-222/10 of 14 July 2011, ratiopharm GmbH vs. OHIM – Nycomed GmbH (contested decision: R 874/2008-4 of 121 March 2010)

Trade marks:

ZURCAL ZUFAL
Earlier trade mark Community trade mark applied for

Class: 5

Decision: The trade marks are visually and aurally (para.40) similar. There is a likelihood of confusion (para. 44).
The Board of Appeal’s decision is upheld.


COURT OF JUSTICE

Preliminary ruling

Case C-324/09 of 12 July 2011, L’Oréal e.a. vs. eBay International AG e.a.

The Court replies to questions referred by the High Court of Justice (England & Wales), Chancery Division, (United Kingdom), (UK) relating to the sale of infringing goods on an online marketplace and the liability of the operator.
The Court’s answers are as follows:

1. Where goods located in a third State, which bear a trade mark registered in a Member State of the European Union or a Community trade mark and have not previously been put on the market in the European Economic Area or, in the case of a Community trade mark, in the European Union, (i) are sold by an economic operator on an online marketplace without the consent of the trade mark proprietor to a consumer located in the territory covered by the trade mark or (ii) are offered for sale or advertised on such a marketplace targeted at consumers located in that territory, the trade mark proprietor may prevent that sale, offer for sale or advertising by virtue of the rules set out in Article 5 of Directive 89/104 or in Article 9 of Regulation No 40/94. It is the task of the national courts to assess on a case-by-case basis whether relevant factors exist, on the basis of which it may be concluded that an offer for sale or an advertisement displayed on an online marketplace accessible from the territory covered by the trade mark is targeted at consumers in that territory.

2. Where the proprietor of a trade mark supplies to its authorised distributors items bearing that mark, intended for demonstration to consumers in authorised retail outlets, and bottles bearing the mark from which small quantities can be taken for supply to consumers as free samples, those goods, in the absence of any evidence to the contrary, are not put on the market within the meaning of Directive 89/104 and Regulation No 40/94.

3. Article 5 of Directive 89/104 and Article 9 of Regulation No 40/94 must be interpreted as meaning that the proprietor of a trade mark may, by virtue of the exclusive right conferred by the mark, oppose the resale of goods such as those at issue in the main proceedings, on the ground that the person reselling the goods has removed their packaging, where the consequence of that removal is that essential information, such as information relating to the identity of the manufacturer or the person responsible for marketing the cosmetic product, is
missing. Where the removal of the packaging has not resulted in the absence of that information, the trade mark proprietor may nevertheless oppose the resale of an unboxed perfume or cosmetic product bearing his trade mark, if he establishes that the removal of the packaging has damaged the image of the product and, hence, the reputation of the trade mark.

4. On a proper construction of Article 5(1)(a) of Directive 89/104 and Article 9(1)(a) of Regulation No 40/94, the proprietor of a trade mark is entitled to prevent an online marketplace operator from advertising – on the basis of a keyword which is identical to his trade mark and which has been selected in an internet referencing service by that operator –goods bearing that trade mark which are offered for sale on the marketplace, where the advertising does not enable reasonably well-informed and reasonably observant internet users, or enables them only with difficulty, to ascertain whether the goods concerned originate from the proprietor of the trade mark or from an undertaking economically linked to that proprietor or, on the contrary, originate from a third party.

5. The operator of an online marketplace does not “use” – for the purposes of Article 5 of Directive 89/104 or Article 9 of Regulation No 40/94 – signs identical with or similar to trade marks which appear in offers for sale displayed on its site.

6. Article 14(1) of Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market (“Directive on electronic commerce”) must be interpreted as applying to the operator of an online marketplace where that operator has not played an active role allowing it to have knowledge or control of the data stored.
The operator plays such a role when it provides assistance which entails, in particular, optimising the presentation of the offers for sale in question or promoting them.
Where the operator of the online marketplace has not played an active role within the meaning of the preceding paragraph and the service provided falls, as a consequence, within the scope of Article 14(1) of Directive 2000/31, the operator none the less cannot, in a case which may result in an order to pay damages, rely on the exemption from liability provided for in that provision if it was aware of facts or circumstances on the basis of which a diligent economic operator should have realised that the offers for sale in question were unlawful and, in the event of it being so aware, failed to act expeditiously in accordance with Article 14(1)(b) of Directive 2000/31.

7. The third sentence of Article 11 of Directive 2004/48/EC of the European Parliament and of the Council of 29 April 2004 on the enforcement of intellectual property rights must be interpreted as requiring the Member States to ensure that the national courts with jurisdiction in relation to the protection of intellectual property rights are able to order the operator of an online marketplace to take measures which contribute, not only to bringing to an end infringements of those rights by users of that marketplace, but also to preventing further infringements of that kind. Those injunctions must be effective, proportionate, and dissuasive and must not create barriers to legitimate trade.


Case C-46/10 of 14 July 2011, Viking Gas A/S vs. Kosan Gas A/S

The Court replies to questions referred by the Danish Supreme Court relating to the refilling composite bottles of gas protected by trade mark registrations.

The Court’s answer is as follows:

Articles 5 and 7 of Directive 89/104 must be interpreted as meaning that the holder of an exclusive licence for the use of composite gas bottles intended for re-use, the shape of which is protected as a three-dimensional mark and to which the holder has affixed its own name and logo that are registered as word and figurative marks, may not prevent those bottles, after consumers have purchased them and consumed the gas initially contained in them, from being exchanged by a third party, on payment, for composite bottles filled with gas which does not come from the holder of that licence, unless that holder is able to rely on a proper reason for the purposes of Article 7(2) of Directive 89/104.


On relative grounds for refusal

Case C-263/09 P of 5 July 2011, Edwin Co. Ltd vs. OHIM – Elio Fiorucci (contested decision: T-165/06 of 14 May 2009 – See FLASH 11-09)

Trade marks:

ELIO FIORUCCI ELIO FIORUCCI
Earlier surname Contested trade mark

Classes: 3,18,25

Decision:
Article 52(2) of Regulation N° 40/94 ( now Article 53(2) of Regulation N° 207/2009) provides :
“A Community trade mark shall also be declared invalid on application to [OHIM] or on the basis of a counterclaim in infringement proceedings where the use of such trade mark may be prohibited pursuant to another earlier right, and in particular:

(a) a right to a name;
…….
under …the national law governing the protection.”

As regards the examination, in the context of an appeal, of the findings made by the General Court with regard to that national law, the Court of Justice has jurisdiction to determine, first of all, whether the General Court, on the basis of the documents and other evidence submitted to it, distorted the wording of the national provisions at issue or of the national case-law relating to them, or of the academic writings concerning them; second, whether the General Court, as regards those particulars, made findings that were manifestly inconsistent with their content; and, lastly, whether the General Court, in examining all the particulars, attributed to one of them, for the purpose of establishing the content of the national law at issue, a significance which is not appropriate in the light of the other particulars, where that is manifestly apparent from the documentation in the case file (para. 53).

The General Court did not err in law when interpreting article 8(3) of the Italian Industrial Property Code that protects well known personal names.

The General Court’s decision is upheld.


4 ECTA News

ECTA speaker at WIPO Symposium of Intellectual Property Authorities - Services for Access to Knowledge in Promoting Innovation and Creativity from 22 to 23 September 2011 in Geneva

ECTA, represented by Shane Smyth, Member of the ECTA Design Committee, will attend the WIPO Symposium of Intellectual Property Authorities - Services for Access to Knowledge in Promoting Innovation and Creativity. It will take place in Geneva on 22-23 September 2011. Shane will take part in the session: “Industrial Designs Infrastructure- Mapping out the global infrastructure for industrial designs: Databases, image search tools, moving image files. What databases, tools, search technologies and platforms are necessary?”

The programme can be found HERE

Enforcement, Geographical Indications, Trade Mark OHIM, WIPO