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Student ID Number: G20618148 Seminar Tutor: S.Fletcher

Module Title: International Intellectual Property Programme Title: LLM International Business
Module Code: LA4925 Year of Study: 1

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 ID No.G20618148

Part A

There is a misunderstanding among Thomas Vengarbron’s (Venga) fans that he has made an

endorsement with Macho Modes Plc for a vest which features his image. Consequently,

Venga is making claims for passing off under English law.

In the current case, Venga is the claimant while Macho Modes Plc is the defendant. In the

Douglas v. Hello1 , it was held that in England there is no image right to celebrities, as result

no action for breach of Venga’s privacy can be initiated against the independent

photographer who took the photograph and licensed it with Macho Modes Plc.

Passing off is the common law of action that protects traders against misrepresentations

made by their others. For an action in passing off, it must be proved that customer

confusion has taken place.

In ‘JIF Lemon2’ case, Lord Oliver sets three basic elements known as the ‘classic trinity’

which are essential for an action in passing off:

1. Goodwill

2. Reputation –the act of misrepresentation by the defendant which deceives.

3. Damage or in a quia timet action, the likelihood of damage.

1
[2007] UKHL 21
2
Reckitt & Coleman Products Ltd v. Borden Inc (No. 3) [1990] 1 WLR 491, 499,
In the Advocaat3 case, Lord Diplock stated five elements4 necessary to bring a passing off

action - a misrepresentation made by a trader to potential customers which causes damage

to the goodwill another trader who bring an action for a passing off. In the same case, Lord

Fraser highlighted on the importance of goodwill existing in England and explained that the

business of trade of the goods must be traded in England. There must be a goodwill

attached to that name and the claimant is the proprietor of the goodwill of strong value in

England. Due to the act of the defendant, his goodwill has suffered or is likely to suffer.

Another important aspect with regards to passing off action is ‘the common field of activity’.

In the case of ‘Uncle Mac’5, it was held that there should be a common field of activity

between the defendant and the claimant for a passing off action to succeed. However, in

the cases of Henderson v. Radio Corporation Pty Ltd6 and the Advocaat7 case, it was stated

that there is no need for a common field of activity between the claimant and the defendant

for a passing action to succeed.

In Rihanna v. Topshop8, three important elements of the ‘classic trinity’ that is goodwill,

misrepresentation and damage which must be proved by the claimant has been elaborated.

3
Erven Warnick BV v. J Townend & Sons (Hull) Ltd [1979] AC 731
4
Quoted from Erven Warnick BV v. J Townend & Sons (Hull) Ltd [1979] AC 731: ‘1. A misrepresentation; 2. Made by a
trader in the course of trade; 3. To prospective customers of his ultimate consumers of goods or services supplied by him;
4. Which is calculated to injure the business or goodwill of another trader; 5. Which causes actual damage to a business or
goodwill of the trader by whom the action is brought or (in a quiat timet) action will probably do so.’

5
Mc Culloch v. Lewis A May (Produce Distributors) Ltd [1947] 2 All ER 845
6
[1969] RPC 218
7
Erven Warnick BV v. J Townend & Sons (Hull) Ltd [1979] AC 731
8
[2013] EWHC 2310 (Ch)
The Judge Mr Justice Birss clearly pointed out in this case that if these elements are not

proved

Rihanna cannot refuse the sale of her image on the t-shirts.

Lord Mac defined goodwill in the case of IRC v. Muller & Co’s Margarine9 as being a good

reputation attached to a business which attracts customer. 10 It is important to also point out

that passing off is a tort which protect intangible ownership of goodwill. In English court,

claim for passing off outside England jurisdiction will not be acknowledged. The general

rule is that there should be ‘customers within that jurisdiction’- the goods must have been

sold or must be available for sale to customers within that jurisdiction. ‘Thus, the claimant

must have a ‘market’ in England for its goods to have the requisite goodwill.’ 11

Misrepresentation is the second most important element in a passing off action.

Misrepresentation must be actionable that is which deceives a substantial number of

customers which eventually causes damage to the claimant. In the case of Woolley v.

Ultimate Products Ltd 12, it was stated that misrepresentation must lead to confusion to a

substantial number of the public, however, ‘substantially’ does not mean counting the

number of head but it is rather relative to the product and the market. As pointed out in

9
[1901] AC 217, 233-4
10
Quoted from IRC v. Muller & Co’s Margarine [1901] AC 217, 233-4: ‘a benefit and advantage of the good name,
reputation and connection of a business. It is the attractive force which brings in custom… However widely extended or
diffused its influence may be, goodwill is worth nothing unless it has the power of attraction sufficient to bring customers
home to the source from which it emanates.’
11
Anheuser-Busch Inc v. Budejovickly Budvar NP [1984] FSR 413.

12
EWCA Civ 1038 at para 5
Stringfellow13, an actionable misrepresentation which cause damage or likely to cause

damage to the claimant’s goodwill is important for a successful action in passing off.

The tort cover different categories of misrepresentations and one of the most common

types of actionable misrepresentations is that the claimant has endorsed the defendant’s

goods. In case of false endorsement, much protection has been allowed to claimants and

this has been confirmed in the case of Irvine v. Talksport Ltd14. In Irvine15 Laddie J explains

that in an endorsement of a good or service, someone associates his name to the good or

service which acts as an encouragement to the public to purchase the good or service. By

this act, the person tells the public that he has approved the product and he is happy to be

associated with it. Laddie J further states that for a successful action in passing off in a case

of endorsement, the three elements – goodwill, misrepresentation and damage must be

met.

Damage is the third element which Lord Oliver identified as important to establish an action

in passing off in the case of ‘Jif Lemon’16. According to him, the claimant must prove that he

has suffered or is likely to suffer from the misrepresentation of the defendant that the

goods or services of the latter is similar to those of the claimant. The role of damage in a

passing off action consists of two general principles namely:

1. The damage must be a result of the defendant’s misrepresentation

13
Stringfellow v. Mc Cain Foods (GB) Ltd [1984] RPC 501
14
[2002] EWHC 67 (Ch).
15
Irvine v. Talksport Ltd[2002] EWHC 67 (Ch)
16
Reckitt & Coleman Products Ltd v. Borden Inc (No. 3) [1990] 1 WLR 491, 499
 2. There is no need for actual damage, as long as the claimant can show that there is

likelihood of damage.

The damage must also be on the claimant’s goodwill. ‘The courts frequently assume that

there is damage, or a likelihood of damage, if the claimant is able to prove that there is

goodwill and a misrepresentation’17. There are five categories of damages in passing off:

i. Direct loss of sales

ii. Loss of reputation or control over reputation

iii. Dilution

iv. Loss of licensing opportunity

v. Damage for false endorsement.

Defense:

The Flaming V logo which represents Venga’s branding is used on his different authorized

products. However, some authorized products neither bear the logo nor the word ‘Venga’.

Although the logo is not used for certain authorized products, it does not amount to the

assumption of customers that Venga has not authorized the products.

Being a seller of inexpensive fashionable clothes, it is probable that no endorsement

agreements for clothing are signed with celebrities like Venga. Consequently, it can be

assumed that there will be no belief in Macho Modes’ customers mind that the vest has
17
C.Wadlow, The Law of Passing Off: Unfair Competition by misrepresentation (3 rd edn, London: Sweet & Maxwell, 2004),
p244; Stringfellow v. Mc Cain Foods (GB) FSR 175, [1984] RPC 501; Harrods, as per Millet LJ at p 714.
been authorized by Venga who normally has endorsement agreements with top luxury

brands.

Since the products of Macho Modes Plc are sold in UK and there is a ‘market within the

jurisdiction’18 in England, Venga can initiate legal proceedings in English Court.

Considering the goodwill which Venga has as a fashion icon and boxer, Macho Modes Plc

ran a competition where the winner would have a personal shopping experience with

Venga. Upon seen wearing or approving an item of clothing on social networks, teenagers

view this as an endorsement by Venga. Being a world famous boxer and a fashion icon,

Venga has sufficient goodwill in England. Considering the facts of this case, Venga has

sufficient goodwill to succeed in a passing off action.

Referring to last year’s competition run by Macho Modes Plc, a personal shopping

experience with Venga was the first prize. This competition would have had a significant

impact on Venga’s fans. This connection between the two parties would have helped to

accentuate on the association between Venga and Macho Modes Plc in the mind of Venga’s

fans.

18
Anheuser-Busch Inc v. Budejovickly Budvar NP [1984] FSR 413.
In same breathe; the message of Venga’s visit to Macho Modes Plc ‘Venga has just…’ onto

an Internet Micro blogging by Macho Modes Plc staff would have a considerable impact on

Venga’s fans. Since teenagers are mostly fans of Venga, they should be connected to blogs

following their fashion icon, Venga. Such a message will certainly enhance the belief of

Venga’s fan that the sale of the vest has been authorized by Venga. Furthermore, Macho

Modes Plc has taken full of advantage of Venga’s public position as a fashion icon and this

would boost its sales.

Since Venga has various endorsement contracts with luxurious top brands products it is

important to consider his market value as a fashion icon. With reference to the case of

Irvine v. Talksport Ltd19 importance has been given to the image and market value of Mr

Irvine who had previously entered into endorsement agreements with famous brands 20.

Laddie J correctly set the level of damages at what the defendants would have to pay ‘to do

lawfully what was done unlawfully.’

Due to the fact that Venga has endorsement agreement with luxury top brand it is relevant

to consider the judgment of Irvine21 case. In view to ascertain the preservation of Venga’s

image as a fashion icon and his market value, it will be appropriate for Macho Modes Plc to

19
(Damages) [2002] EWHC 539 (Ch), [2003] EMLR 6,
20
Quoted in Irvine v. Talksport [2003] FSR 35 (CA), 60: ‘…although I am relatively keen to endorse products, there is and
was in 1999 a price below which I would not consider endorsing the products. This is because I would want it to be known
that my endorsement fee was a low figure. Word would soon get around and it could devalue my image and market
value’.
21
Irvine v. Talksport Ltd (Damages) [2002] EWHC 539 (Ch), [2003] EMLR 6,
pay Venga the amount it would have paid in circumstance where an endorsement

agreement would have been entered.

Part B
Thomas Vengarbron- Venga can consider protecting the following aspect of the new

aftershave:

a) the smell of the aftershave; and

b) the distinctive, red V-shaped bottle.

c) The words ‘Sent by Venga’

The Community Trade Mark (CTM) is a single mark which can be represented graphically 22

and which can be legally be used within the European Union and the application can be

made through the UK Intellectual Property Office or to the Office for Harmonisation in the

Internal Market (OHIM) in Alicante.

Article 7 of the Regulation elaborates on absolute grounds for refusal of a CTM registration.

The grounds include signs which cannot be represented graphically; signs lacking distinctive

characters; trademark which can deceive public; shape objections; trademarks contrary to

public policy or morality.23

22
Article 4 of the Council Regulation (EC) No 207/2009 of 26 February 2009: A community trade mark may consist of any
signs capable .of being represented graphically, particularly words, including personal names, designs, letters, numerals,
the shape of goods or of their packaging provided that such are capable of distinguishing the goods or services of one
undertaking from those of other undertakings.

23
Article 7 of Regulation (EC) No 207/2009 of 26 February 2009 on the Community trade mark
Article 7 of the Regulation - Absolute grounds for refusal
1. The following shall not be registered:
(a) signs which do not conform to the requirements of Article 4;
(b) trademarks which are devoid of any distinctive character;
(c) trademarks which consist exclusively of signs or indications which may serve, in trade, to designate the kind,
quality, quantity, intended purpose, value, geographical origin or the time of production of the goods or of
rendering of the service, or other characteristics of the goods or service;
(d) trademarks which consist exclusively of signs or indications which have become customary in the current language
or in the bona fide and established practices of the trade;
(e) signs which consist exclusively of:(i) the shape which results from the nature of the goods themselves;(ii) the
shape of goods which is necessary to obtain a technical result;(iii) the shape which gives substantial value to the
goods;
(f) trademarks which are contrary to public policy or to accepted principles of morality;
(g) trademarks which are of such a nature as to deceive the public, for instance as to the nature, quality or
geographical origin of the goods or service;
Article 4 of the Regulation seems to leave open the possibility that any sign which can be

represented graphically can be registered. However, the decision of the Court of Justice of

the European Union (CJEU) in the case of Dyson24 shows that not all signs may constitute a

trademark. This open-ended definition of registrable signs give rise to question as to

whether marks which cannot be perceived visually such as smell known as ‘olfactory marks’,

sounds and taste can be registered. In various cases, it has been seen that the registration

of intangible signs encounter certain difficulties.

In Sieckmann25 an application was filed in Germany for the registration of a smell. The

application described chemical formula which created the smell and included a sample of

the smell. The dispute as to any of the details provided constituted ‘graphic representation’

was referred to the European Court of Justice (ECJ). The ECJ stated that the details provided

was inadequate and further elaborated that although a smell cannot be visually perceived, it

can be registered as trademarks if it can be represented graphically – by means of images,

lines or characters. These should be ‘clear, precise, self-contained, easily accessible,

(h) trademarks which have not been authorised by the competent authorities and are to be refused pursuant to
Article 6ter of the Paris Convention for the Protection of Industrial Property, hereinafter referred to as the ‘Paris
Convention’;
(i) trademarks which include badges, emblems or escutcheons other than those covered by Article 6ter of the Paris
Convention and which are of particular public interest, unless the consent of the competent authority to their
registration has been given;
(j) trademarks for wines which contain or consist of a geographical indication identifying wines or for spirits
(k) which contain or consist of a geographical indication identifying spirits with respect to such wines or spirits not
having that origin;
2. Paragraph 1 shall apply notwithstanding that the grounds of non-registrability obtain in only part of the
Community.
3. Paragraph 1(b), (c) and (d) shall not apply if the trade mark has become distinctive in relation to the goods or
services for which registration is requested in consequence of the use which has been made of it.

24
– Dyson Ltd v. Registrar of Trade Marks – Case C-321/03 [2007] ECR I-687
25
Sieckmann v. Deutsches Patent- und Markenamt Case C-273/00 [ 2002] ECR I- 11737
intelligible, durable and objective’. However, the application of this test will be difficult to

smells, particularly with the need for the representation to be ‘intelligible.’

26
The OHIM allowed the registration for the ‘smell of new-mown grass’ in respect of tennis

balls. Following the Sieckmann27 the tennis balls registration has lapsed as there is not

sufficient means to represent a smell.

The formula devised in the Sieckmann28 about adequate graphic representation 29 also

applies to other intangible signs such as colors. The ECJ dealt with the question as to

whether a single color can be registered and be graphically represented in the case of

Libertel Groep BV v. Benelux – Merkenbureau 30 where an application was made to register a

trade mark for the colour orange. The application contained an orange rectangle and the

word ‘orange’ without any reference with regard to any color code. The application was

initially refused on the ground that the mark was devoid of distinctive character and would

not be registered without proof that it had acquired distinctiveness through use. On appeal

the ECJ explained that to be registrable, a color per se must be represented graphically in a

way that is ‘clear, precise, self-contained, easily accessible, intelligible, durable and

objective’. An international recognized identification code such as the Pantone Classification

system can be used to satisfy the ‘objective’ condition. The representation of a color on its

own or a description in words is inadequate as words are unclear and representation fades

with time. A color per se help to distinguish goods or services of one trader to another and
26
Quoted from Intellectual Property Law, Tim Press, Oxford University Press 2013, P.159
27
Sieckmann v. Deutsches Patent- und Markenamt Case C-273/00 [ 2002] ECR I- 11737
28
Sieckmann v. Deutsches Patent- und Markenamt Case C-273/00 [ 2002] ECR I- 11737
29
Quoted from Sieckmann v. Deutsches Patent- und Markenamt Case C-273/00 [ 2002] ECR I- 11737- ‘…clear, precise, self-
contained, easily accessible, intelligible, durable and objective…’

30
C-104/01 [2003] ECR I-3793
importance must be given not to unduly restrict the accessibility of colors available for use

by all traders. Consequently, the ECJ held that it will be necessary for an applicant for the

registration of a color per se to prove acquired distinctiveness through use.

A shape mark which has acquired distinctiveness can be registered as per the Regulation.

However, Article 7(1)(e) of the Regulations set ground whereby these signs cannot be

registered as trademarks. In the case of Lego Juris A/S v. OHIM31 it was held that for a

shape to fall within the ground of refusal:

a. ‘the necessary elements of the mark must fulfill a technical function;

b. it does not matter that the technical function could be achieved by a different shape;

c. the essential elements of a mark are its most important elements – and this must be

decided on a case to case basis.’

In the case of Tynant Spring Water Ltd32, an application was made to register a blue bottle of

optical character. Although the application stated the description of the colour ‘cobalt blue’

and thickness of the wall as 3mm33, the application was refused. This case explains that

colours represented in purely words will be considered as too vague to form a graphical

representation. Consequently, it should be represented as per widely and readily available

colour standard. The shape of the bottle must also be precisely defined to avoid referring to

any shape of bottle.

31
(C-48/09 P) [2010] ETMR 63
32
Ty Nant Spring Water Ltd's Trade Mark Application [2000] RPC 55
33
Quoted from Ty Nant Spring Water Ltd's Trade Mark Application [2000] RPC 55- “The trade mark consists of a blue bottle
of optical characteristics such that, if the wall thickness is 3mm, the bottle has, in air, a dominant wavelength of 472 to 474
nanometres, a purity of 44 to 48%, an optical brightness of 28 to 32%”
 34
In Nestlé Waters France v. OHIM – Case T-305/02, a CTM application for a three-

dimensional shaped bottle was made. The application included a full description of the

shape.35

Albeit, registration was refused as the bottle was considered to be of common shape and

was not distinctive. Nestlé argued that the bottle was distinctive and the CFI explained that

the aspect of distinctiveness should be assessed on the general public perception. The CFI

was satisfied that the bottle differentiated the products from other manufacturers. Thus,

this shape was registrable and it has been noted that stringent test should not be applied to

three dimensional marks rather the conventional registration (graphical representation and

not devoid of distinctive character) should be considered.

Article 8 of the Regulation establishes circumstances where an owner of a registered

trademark may prevent the registration of a later sign. This article states the relative

grounds of refusal for an application and this can be categorized into:

(a) prior registered trademarks - these include identical marks on identical goods;

either marks or goods not identical but there is confusion as to the trade origin;

similar marks

with similar goods or dissimilar causing unfair advantage of, or detriment to the

mark.

34
Case T-305/02
35
Quoted from Nestlé Waters France v. OHIM– Case T-305/02: “the bottle comprises a main section with, at its base, a
recess, in the shape of a slightly truncated cone with, in its flat section, a stylised star in relief. In the lower part of the main
section, which is nearly cylindrical from bottom to top, there is an initial series of wavy grooves and, in the upper part,
which is of slightly smaller diameter and bobbin-shaped, there are spiralling grooves which form lozenges when seen
through the bottle. The top section, which is the shape of a slightly truncated cone, ends in a cylindrical neck with a blue
cap.”
 (b) Prior unregistered rights- passing off; copyrights in words, images or shapes. 36

A trade mark will not be registered if it is ‘identical’. Marks are considered to be identical if

the differences are so insignificant that they will go unnoticed 37. There are blocking powers

of prior marks where there is confusion. According to the ECJ in Sabel v. Puma38, confusion

would be one where the confusion is concerned to the trade origin of the goods either that

the goods come from the same manufacturer or from economically linked agreements.

Therefore, a single global test as per the 11 th recital of the Directive must be done. Another

important type of harm which is covered by Article 8 is unfair advantage.

36
Article 8- Relative grounds for refusal
1. Upon opposition by the proprietor of an earlier trade mark, the trade mark applied for shall not be registered: (a) if it is
identical with the earlier trade mark and the goods or services for which registration is applied for are identical with the
goods or services for which the earlier trade mark is protected; (b) if because of its identity with, or similarity to, the earlier
trade mark and the identity or similarity of the goods or
services covered by the trade marks there exists a likelihood of confusion on the part of the public in the territory in which
the earlier trade mark is protected; the likelihood of confusion includes the likelihood of association with the earlier trade
mark.
2. For the purposes of paragraph 1, ‘earlier trade marks’ means: (a) trade marks of the following kinds with a date of
application for registration which is earlier than the date of application for registration of the Community trade mark,
taking account, where appropriate, of the priorities
claimed in respect of those trade marks:(i) Community trade marks; (ii) trade marks registered in a Member State, or, in
the case of Belgium, the Netherlands or Luxembourg, at the Benelux Office for Intellectual Property; (iii) trade marks
registered under international arrangements
which have effect in a Member State; (iv) trade marks registered under international arrangements which have effect in
the Community; (b) applications for the trade marks referred to in subparagraph (a), subject to their registration; (c) trade
marks which, on the date of application for registration of the Community trade mark, or, where appropriate, of the
priority claimed in respect of the application for registration of the Community trade mark, are well known in a Member
State, in the sense in which the words ‘well known’ are used in Article 6bis of the Paris
Convention.
3. Upon opposition by the proprietor of the trade mark, a trade mark shall not be registered where an agent or
representative of the proprietor of the trade mark applies for registration thereof in his own name without the proprietor's
consent, unless the agent or representative justifies his action.
4. Upon opposition by the proprietor of a non-registered trade mark or of another sign used in the course of trade of more
than mere local significance, the trade mark applied for shall not be registered where and to the extent that, pursuant to
the Community legislation or the law of the Member State governing that sign: (a) rights to that sign were acquired prior to
the date of application for registration of the Community trade mark, or the date of the priority claimed for the application
for registration of the Community trade mark; (b) that sign confers on its proprietor the right to pro prohibit the use of a
subsequent trade mark.
5. Furthermore, upon opposition by the proprietor of an earlier trade mark within the meaning of paragraph 2, the trade
mark applied for shall not be registered where it is identical with, or similar to, the earlier trade mark and is to be
registered for goods or services which are not similar to those for which the earlier trade mark is registered, where, in the
case of an earlier Community trade mark, the trade mark has a reputation in the Community and, in the case of an earlier
national trade mark, the trade mark has a reputation in the Member State concerned and where the use without due cause
of the trade mark applied for would take unfair advantage of, or be detrimental to, the distinctive character or the repute
of the earlier trade mark.
37
S.A Societe LTJ Diffusion v Sadas Vertbaudet SA [2003]
38
C-251/95 [1997]
Going back to Venga’s case, the potential for registration are as follows:

 Venga being a legal person has the right to apply for the registration of the

trademarks as per Article 5 of the Regulation. The application must be made in good

faith- Venga must use the trade mark and there must not be any third party right to

the mark.39

 The Smell of the new aftershave - with reference to Sieckmann40, it is evident that

the smell cannot be graphically represented and consequently the smell cannot be

registered.

 Since the distinctive, red, V-shape bottle is not contrary to public policy or public

moral and there is no potential to cause deception to the public the application can

be made. However, with regards to the description of the distinctive, red, V –Shape

Bottle, due consideration must be given. The application must be made in good

faith- Venga must use the trade mark and there must not be any third party right to

the mark.41

As referred in the case of Sieckmann42, the graphical representation of the color

must be ‘clear, precise, self-contained, easily accessible, intelligible, durable and

objective’. The Pantone Classification system can be used to satisfy the ‘objective’

39
Ferrero SpA’s Trade Marks [2004] RPC 29
40
Sieckmann v. Deutsches Patent- und Markenamt Case C-273/00 [ 2002] ECR I- 11737
41
Ferrero SpA’s Trade Marks [2004] RPC 29
42
Sieckmann v. Deutsches Patent- und Markenamt Case C-273/00 [ 2002] ECR I- 11737
 condition.43 To be registered per se the proposed red colour must be acquired

distinctiveness through use.

As prescribed in the Nestlé Waters France v. OHIM44, the application for the red V-

shaped bottle must include full description of the shape of the bottle and the

standard set for the red colour. In addition, the V-shaped bottle must differentiate

Venga’s product from other manufacturers.

 The words ‘Sent by Venga’- Referring to Article 4 of the Regulation, the words’ Sent

by Venga’ can be registered as a trade mark as there is no ground for refusal for this

sign. The word ‘Sent by Venga’ is neither contrary to public moral or policy nor

causing deception to the public.

Based on the assumption that no prior mark similar to that proposed by Venga has

been registered earlier, no ground for refusal under Article 8 of the Regulation is

present in this case.

Upon registration of the trademarks, these marks will consist of Venga’s personal

rights. These registered rights will have two distinct powers: firstly, a defensive one-

the power to block registrations of later marks; secondly, an offensive power- to

prevent the use of the marks by others.

43
Libertel Groep BV v. Benelux – Merkenbureau C-104/01 [2003] ECR I-3793
44
Case T-305/02
Bibliography

Tanya Aplin & Jennifer Davis, Intellectual Property Law: Text, Cases and Materials, 2 nd

Edition, (2013, Oxford University Press)

Tim Press, Intellectual Property Law, Impression 1, (2013, Oxford University Press)

Ray August, Don Mayer, Michael Bixby, International Business Law: Text, Cases

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https://oami.europa.eu/ohimportal/en/- Last accessed 23.02.2014