The International Comparative Legal Guide to: Trade Marks 2012 First Edition A practical cross-border insight into trade mark work Published by Global Legal Group, with contributions from: Abreu Advogados Kasznar Leonardos Anderson Mori & Tomotsune Law Offices of Patrinos & Kilimiris Arochi, Marroquín & Lindner Loyens & Loeff, avocats à la Cour Avvocati Associati Franzosi Dal Negro Setti Nixon Peabody LLP Baker & McKenzie Pachiu & Associates Banwo & Ighodalo Papacharalambous & Angelides L.L.C Bereskin & Parr LLP Patpol Sp. z o.o. Boga & Associates Pepeljugoski Law Office Bristows Pham & Associates CCPIT Patent and Trademark Law Office Quevedo & Ponce Danubia Patent & Law Office Dewey & LeBoeuf LLP Subramaniam, Nataraj & Associates, Patent & Trademarks Attorneys DM Kisch Inc SyCip Salazar Hernandez & Gatmaitan Law Offices ELZABURU Tay & Partners Hengeler Mueller ThomannFischer Jadek & Pensa Law Office Tiplo Attorneys at Law The International Comparative Legal Guide to: Trade Marks 2012 General Chapter: 1 The Significance of Actual Trademark Use and “Use in Commerce” Under U.S. Trademark Law – Kristen Mollnow Walsh & Jeffrey L. Costellia, Nixon Peabody LLP Contributing Editors Paul Walsh & Dominic Murphy, Bristows Account Managers Dror Levy, Maria Lopez, Florjan Osmani, Oliver Smith, Rory Smith, Toni Wyatt 1 Country Question and Answer Chapters: 2 Albania Boga & Associates: Renata Leka & Ened Topi 6 3 Belgium Baker & McKenzie: Pierre Sculier & Elisabeth Dehareng 14 4 Brazil Kasznar Leonardos: Filipe da Cunha Leonardos & Claudio Roberto Barbosa 24 5 Canada Bereskin & Parr LLP: Daniel R. Bereskin, Q.C. & Wynnie Chan 34 6 China CCPIT Patent and Trademark Law Office: Chumeng (Jessica) Xu 41 Fiona Canning 7 Cyprus Papacharalambous & Angelides L.L.C: Eleni Papacharalambous 48 Editor 8 Ecuador Quevedo & Ponce: Alejandro Ponce Martínez & Roque Albuja Izurieta 56 Bristows: Paul Walsh & Dominic Murphy 62 Sub Editor Suzie Kidd Senior Editor 9 Penny Smale 10 France Dewey & LeBoeuf LLP: Gaëtan Cordier 70 Managing Editor 11 Germany Hengeler Mueller: Dr. Wolfgang Kellenter & Dr. Andrea Schlaffge 83 12 Greece Law Offices of Patrinos & Kilimiris: Maria Kilimiris & Manolis Metaxakis 91 Richard Firth 13 Hungary Danubia Patent & Law Office: Michael Lantos 99 Published by 14 India Subramaniam, Nataraj & Associates, Patent & Trademarks Attorneys: Hari Subramaniam 105 15 Italy Avvocati Associati Franzosi Dal Negro Setti: Vincenzo Jandoli 112 16 Japan Anderson Mori & Tomotsune: Yasufumi Shiroyama & Ai Nagaoka 120 17 Kosovo Boga & Associates: Renata Leka & Ened Topi 127 18 Luxembourg Loyens & Loeff, avocats à la Cour: Véronique Hoffeld 134 19 Macedonia Pepeljugoski Law Office: Professor Dr. Valentin Pepeljugoski & Ana Pepeljugoska 142 20 Malaysia Tay & Partners: Su Siew Ling & Joanne Kong 152 21 Mexico Arochi, Marroquín & Lindner: María Teresa Eljure 161 22 Nigeria Banwo & Ighodalo: Femi Olubanwo & Chinasa Uwanna 168 Alan Falach Group Publisher Global Legal Group Ltd. 59 Tanner Street London SE1 3PL, UK Tel: +44 20 7367 0720 Fax: +44 20 7407 5255 Email: info@glgroup.co.uk URL: www.glgroup.co.uk GLG Cover Design European Union F&F Studio Design GLG Cover Image Source iStockphoto Printed by Ashford Colour Press Ltd May 2012 23 Philippines Copyright © 2012 Global Legal Group Ltd. All rights reserved No photocopying SyCip Salazar Hernandez & Gatmaitan Law Offices: Enrique T. Manuel & Vida M. Panganiban-Alindogan 175 24 Poland Patpol Sp. z o.o.: Anna Zakrocka & Bartłomiej Kochlewski 182 25 Portugal Abreu Advogados: João Veiga Gomes & João Gonçalves Assunção 192 ISBN 978-1-908070-27-2 ISSN 2049-3118 26 Romania Pachiu & Associates: Remus Ene & Gabriela Ivancu 202 27 Slovenia Jadek & Pensa Law Office: Eva Gostiša 213 28 South Africa DM Kisch Inc: Nola Bond & Julia Stephens 220 29 Spain ELZABURU: Fernando Ilardia & Luis Baz 227 30 Switzerland ThomannFischer: Daniel Plüss 237 31 Taiwan TIPLO Attorneys-at-Law: J. K. Lin & H. G. Chen 244 32 United Kingdom Bristows: Paul Walsh & Dominic Murphy 254 33 USA Nixon Peabody LLP: Kristen Mollnow Walsh & Gina M. McCreadie 263 34 Vietnam Pham & Associates: Pham Vu Khanh Toan 271 Stategic Partners Further copies of this book and others in the series can be ordered from the publisher. Please call +44 20 7367 0720 Disclaimer This publication is for general information purposes only. It does not purport to provide comprehensive full legal or other advice. Global Legal Group Ltd. and the contributors accept no responsibility for losses that may arise from reliance upon information contained in this publication. This publication is intended to give an indication of legal issues upon which you may need advice. Full legal advice should be taken from a qualified professional when dealing with specific situations. www.ICLG.co.uk Chapter 1 The Significance of Actual Trademark Use and “Use in Commerce” Under U.S. Trademark Law Kristen Mollnow Walsh Nixon Peabody LLP Actual use of a trademark is central to both the establishment of, and ownership of, trademark rights in the United States both at common law and for registration purposes under the Trademark Act of 1946, known as the Lanham Act, codified at 15 U.S.C. §1051 et seq. In most cases, “use in commerce” is a requirement for obtaining and maintaining federal trademark registration in the United States. U.S. trademark law in these areas differs in key respects from trademark law in many other jurisdictions, particularly civil law jurisdictions with “first to file” systems. As such, foreign trademark owners and their counsel must be mindful of the role of actual trademark use in the United States, as discussed below, in formulating a trademark protection strategy for the United States. Jeffrey L. Costellia in the ordinary course of trade in the marketplace. Typically, such use is shown through actual sales of the branded goods or use of the mark in connection with the actual provision of the branded services. The following types of activities are generally not sufficient to create trademark rights: So-called “token” or “de minimis” use designed merely to reserve rights in the mark, such as nominal sales of the branded goods to relatives, personal friends, or related companies, will not support trademark rights because such transactions are not the result of arm’s length transactions in the marketplace. Intra-company sales or deliveries of the branded goods and other secretive or non-public transactions (such as shipping samples or prototypes for evaluation or shipping goods from one company to another during the manufacturing process) will not support trademark rights because, in such situations, the branded goods are not exposed to the public. I. Establishment and Priority of Trademark Rights at Common Law In the United States, actual use of a designation in the marketplace as an indicator of a source of particular goods and services informs both the establishment of trademark rights and ownership of such rights. A. Use of a designation in preparing to do business is typically insufficient to create trademark rights. See Aycock Eng’g, Inc. v. Airflite, Inc., 560 F.3d 1350, 1360 (Fed. Cir. 2009). This category would include the following types of activities: using a designation in a business plan, financial statement, or prospectus for a stock offering; using a designation in a concept for an advertising campaign or in an advertising copy (not disseminated); using a designation in designs for business cards or company letterhead; using a designation in new business announcements, pre-sale product presentations, and pre-sale promotion and/or advertising; using a designation in communications with builders, prospective suppliers, or governmental officials prior to opening a commercial establishment; reserving a domain name; and incorporating under a particular name. Establishment of Trademark Rights Trademark rights arise from actual use of a trademark in connection with the offering of goods or services to the public. Trademark rights are not created by invention or by mere adoption: neither the first person to conceive of the idea of using a particular designation as a mark, nor a person who decides to use a particular designation as a mark in the future, acquires any trademark rights. Rather, to acquire trademark rights, the owner must actually use the designation in the marketplace to identify the source of its goods or services, and to distinguish them from those offered by others. As stated by the United States Supreme Court in 1879: The ordinary trademark has no necessary relation to invention or discovery. The trademark recognized by the common law is generally the growth of a considerable period of use, rather than a sudden invention . . . . The trademark may be and, generally, is, the adoption of something already in existence as the distinctive symbol of the party using it. At common law the exclusive right to it grows out of the use of it, and not its mere adoption . . . . It requires no fancy or imagination, no genius, no laborious thought. It is simply founded on priority of appropriation. Trade-mark Cases, 100 U.S. 82, 94 (1879). A “use” sufficient to support trademark rights must be a bona fide use in connection with the actual offering of the goods or services B. Trademark Ownership and Priority of Use With regard to ownership, the general rule in the United States is that trademark ownership is determined by priority of use in the United States. Ownership rights flow only from prior use, either actual or constructive. To establish ownership of a mark, the prior use must be continuous. See, e.g., Tally-Ho, Inc. v. Coast Cmty Coll. Dist., 889 F.2d 1018, 1022-23 (11th Cir. 1989) (“actual and continuous use is required to acquire and retain a protectable interest in a mark”); La Societe Anonyme des Parfums Le Galion v. Jean Patou, Inc., 495 F.2d 1265, 1272 (2d Cir. 1974) (“the proponent of the trademark must demonstrate that his use of the mark has been deliberate and continuous”). More than sporadic, or de minimis, sales are required. Similarly, an initial use, followed by a long period of non- ICLG TO: TRADE MARKS 2012 © Published and reproduced with kind permission by Global Legal Group Ltd, London WWW.ICLG.CO.UK 1 Nixon Peabody LLP Trademark Use & “Use in Commerce” Under U.S. Trademark Law use, would likely constitute an abandonment and, as such, would not be a sufficient basis to establish priority. In some cases, modest levels of pre-sale advertising or promotion, a small volume of sales, or even a single use in trade, may sustain a claim of priority if followed by continued commercial use of the mark by the brand owner. For inherently distinctive marks, ownership (and priority) accrues to the first to use the designation as a mark. For noninherently distinctive marks where proof of secondary meaning is required, ownership generally accrues to the first to acquire secondary meaning. See, e.g., Bass Pro Trademarks, L.L.C. v. Sportsmans Warehouse, Inc., 89 U.S.P.Q.2d 1844 (TTAB 2008). As explained in the following sections below, “use” requirements for priority are not necessarily congruent with “use” requirements for registration. The “use” necessary to establish priority must occur in the United States. Prior use in a foreign nation does not establish priority of use in the United States (except, perhaps, for foreign marks that are “well-known” or “famous” in the U.S. pursuant to the well-known marks doctrine of the Paris Convention Article 6bis). Similarly, to avoid abandonment of a mark, use must be in the United States, not abroad. In most circumstances, the foreign activities of a party are not relevant in a priority dispute concerning U.S. trademark rights. C. Scope of Common Law Trademark Rights Common law trademark rights (i.e., rights based on use rather than a federal registration) are limited to the geographic area or market in which the trademark owner is actually using the mark, that is, the territory where it is selling or distributing the goods, or the territory where it is providing the services. Common law rights are thus geographically restricted—which is one of the most compelling reasons to secure a federal registration where possible. II. “Use in Commerce” Under the Lanham Act A. “Commerce” and “Use in Commerce” Defined The Lanham Act requires not only a use in trade, but also a use in commerce. To qualify for registration under the Act, a mark must be “used in commerce”, where “commerce” is defined as “all commerce which may lawfully be regulated by Congress”. 15 U.S.C. §§ 1051(a)(1), 1127. Such commerce includes interstate commerce within the United States, and commerce between the U.S. and a foreign country. Purely intrastate commerce lies outside the purview of Congress and, as a result, use of a mark in connection with purely intrastate commerce does not constitute a “use in commerce” for purposes of the statute. Similarly, use of a mark exclusively outside the U.S. does constitute a “use in commerce”. Foreign use will not establish trademark rights in the U.S., either at common law or for purposes of the Lanham Act. Lastly, use of a mark in advertising in the United States for goods or services that are provided outside of the U.S. is generally not considered a “use in commerce”. See Buti v. Impressa Perosa, S.R.L., 139 F.3d 98 (2d Cir.), cert. denied, 525 U.S. 826 (1998) (no Lanham Act priority was established where the service mark was for restaurant services offered exclusively in Italy, even though the restaurant operator had distributed marketing material within the U.S.); Mother’s Rests., Inc. v. Mother’s Other Kitchen, Inc., 218 U.S.P.Q. 1046 (TTAB 1983) (broadcast of advertisements for a restaurant located in Canada, and distribution of promotional materials in southern Ontario tourist routes into the U.S., did not constitute “use in commerce”). 2 Under the Lanham Act, a “use in commerce” is defined as a “bona fide use of a mark in the ordinary course of trade, and not made merely to reserve a right in a mark”. 15 U.S.C. § 1127. For goods sold or transported in commerce, a mark is deemed to be used in commerce when the mark is placed on the goods, their containers, or associated displays (such as trade show booths, mail order catalogues, or Internet website catalogues through which the branded goods can be ordered), or on tags or labels affixed thereto, or, if the nature of the goods makes such placement impracticable, on associated documents, such as shipping documents. Id. Use of a mark in advertising for goods, standing alone, does not constitute a “use in commerce” for purposes of the statute. For services, a mark is deemed to be used in commerce when the mark “is used or displayed in the sale or advertising of services and the services are rendered in commerce, or the services are rendered in more than one State, or in the United States and a foreign country, and the person rendering the services is engaged in commerce in connection with the services”. Id. As stated above, token uses, non-public uses, and business preparation activities do not typically satisfy the “use in commerce” requirement for purposes of the Lanham Act. B. “Use in Commerce” Requirements Applicable to Federal Trademark Filings There are four filing bases in the Lanham Act upon which a foreign national may apply to obtain a trademark registration in the United States: (1) actual use of the mark in commerce under Section 1(a); (2) a bona fide intent to use the mark in commerce under Section 1(b); (3) ownership of a foreign registration under Section 44(e); and (4) through an extension of protection to the United States of an International Registration under the Madrid Protocol pursuant to Section 66(a). As discussed below, “use in commerce” is a requirement of (1) and (2), but not of (3) or (4). 1. Filing Bases Requiring Proof of “Use in Commerce” If the application is based on Section 1(a) of the Lanham Act, the applicant must be actually using the applied-for mark in commerce on or in connection with each of the goods and services listed in the application. 15 U.S.C. §1051(a). As part of the application, the applicant must provide the date of its first use of the mark, the date of its first use of the mark in commerce, and a specimen showing the mark as used in commerce. If the applicant is not, in fact, actually using the applied-for mark on each of the listed goods and/or services, the application and resulting registration could be vulnerable to challenge on the grounds of fraud or non-use. To cure such a problem, the applicant could delete from the application those goods and/or services on which it is not using the mark, or amend the filing basis of the application from Section 1(a) (actual use) to Section 1(b) (intent to use). See Grand Canyon West Ranch, LLC v. Hualapai Tribe, 78 U.S.P.Q.2d 1696 (TTAB 2006). If the application is based on Section 1(b) of the Lanham Act, the applicant must assert that it has a bona fide intention to use the applied-for mark in commerce on, or in connection with, each of the goods and services listed in the application, but is not required to submit first use dates and proof of use at the time of filing. 15 U.S.C. §1051(b). The applicant will, however, need to provide such proof prior to registration through either an Amendment to Allege Use or a Statement of Use. The bona fides of the stated intention may be the subject of a later challenge to the validity of the resulting registration on the grounds of fraud or non-use. The Lanham Act does not define the term “bona fide intention to use”. However, legislative history indicates that the term “bona fide intention to use” is meant to eliminate “token” uses, to preclude those who would file a large number of WWW.ICLG.CO.UK © Published and reproduced with kind permission by Global Legal Group Ltd, London ICLG TO: TRADE MARKS 2012 Nixon Peabody LLP Trademark Use & “Use in Commerce” Under U.S. Trademark Law applications without a serious or real intention ever to use them, and to require a good faith intention on the part of the applicant, based on an objective view of the circumstances, to eventually use the mark in a real and legitimate commercial sense. See generally, 3 McCarthy J. Thomas, McCarthy on Trademarks and Unfair Competition, § 19:14. Otherwise stated, the intent to use a mark must be genuine. Objective evidence supporting such an intention will usually consist of an applicant’s documentation, such as a written business plan or research and development documents, created at the time of the filing of the application, of realistic plans to go forward with use of the mark. See Boston Red Sox Baseball Club Ltd. P’ship v. Sherman, 88 U.S.P.Q.2d 1581, 1587 (TTAB 2008) (evidence of intent to use must relate to time of filing of application). A “bona fide intention to use” can be definite, but contingent upon the happening of some event. For example, a trademark applicant could file several ‘intent to use’ applications, but then proceed with only one after conducting market testing or consumer reaction studies. Proof of “use in commerce” is required to maintain a federal trademark registration for the full ten-year initial term of registration, and to renew a federal trademark registration for subsequent ten-year renewal terms. 15 U.S.C. § 1068. Under Section 8 of the Lanham Act, a trademark owner is required to file a use declaration during the fifth year of registration, and then in every tenth year after registration, asserting that it is using the registered mark in commerce on, or in connection with, each of the goods and/or services listed in the registration. A good faith use in the ordinary course of trade, not merely to reserve a right in the mark, is required. 15 U.S.C. § 1127. If, at the time a Section 8 declaration is due, the registrant is not actually using the registered mark on or in connection with all of the listed goods or services, the registrant should, as part of the required filing, delete from the registration those goods and/or services on, or in connection with, which use is not being made. Otherwise, the registration will be vulnerable to attack as to those goods and/or services. 2. Filing Bases Not Requiring Proof of “Use in Commerce” Under Section 44(e), a qualified foreign applicant who owns a trademark registration in its country of origin may obtain registration in the United States without having to satisfy the “use in commerce” requirement applicable under Sections 1(a) and 1(b). To seek the special statutory benefits of Section 44, the applicant must be a foreign entity whose country of origin is a party to any trademark convention or treaty to which the United States is a party (e.g., the Paris Convention), or that extends reciprocal rights to United States citizens. In the application, the Section 44(e) applicant must identify the registration date, registration number, and country of the foreign registration; provide a copy of the foreign registration; and verify that it has a bona fide intention to use the applied-for mark “in commerce”. Significantly, the applicant is not required to show “use in commerce” prior to obtaining registration. As stated by the Trademark Trial and Appeal Board of the U.S. Patent and Trademark Office (“USPTO”), “as a result of treaty provisions and Section 44, foreign applicants are given substantial advantages over U.S. citizens, most particularly the right to obtain U.S. registrations for goods and services for which they have not yet used the marks in commerce”. In re Societe d’Exploitation de la Marque Le Fouquet’s, 67 U.S.P.Q.2d 1784 (TTAB 2003). This can indeed be a distinct advantage. As with applicants under Section 44(e), the owner of an International Registration who seeks registration in the United States through a request for extension of protection under the Madrid Protocol (an “in-bound Madrid application”) under Section 66(a) is not required to show use of the applied-for mark “in commerce”. Such an application must, however, include a verification by the applicant that it has a bona fide intention to use the applied-for mark “in commerce”. Following registration, the foreign trademark owner must start using the registered mark in commerce within a reasonable time, or the protection provided by a Section 44(e) or Section 66(a) registration will be subject to cancellation on the grounds of abandonment. Under the Lanham Act, non-use of a mark for three consecutive years is prima facie evidence of abandonment. 15 U.S.C. § 1127. In addition, foreign trademark owners of registrations based on Section 44(e) or Section 66(a), like all registrants, must comply with the “use in commerce” requirements discussed in Section II.B.1 above to maintain and renew their U.S. registrations. See 15 U.S.C. § 1058 (for Section 44(e) registrations), id. at § 1141k (for Section 66(a) registrations). As stated above, if, at the time a post-registration declaration of use is due, the foreign trademark owner is not using the registered mark in commerce in the United States on, or in connection with, all of the listed goods or services, it should, as part of the required filing, delete from the registration those goods and/or services on, or in connection with, which use is not being made. Otherwise the registration will be vulnerable to attack as to those goods and/or services. See supra, Section II.B.1. C. Constructive Use Federal registration of a mark constitutes constructive use of the mark throughout the United States, and gives the registrant priority against later adopters of confusingly similar marks, even in geographic areas where the registrant has not actually used the mark. 15 U.S.C. § 1057(b). This is one of the principal benefits that flows from federal registration. Since 1989, under Section 7(c) of the Lanham Act, the filing date of a federal trademark application constitutes a constructive use, conferring a right of nationwide priority, contingent upon final registration. 15 U.S.C. §1057(c). For the owner of an intent to use application under Section 1(b), this is a boon because, when the registration is ultimately issued, such owner obtains a priority date for nationwide constructive use that corresponds to the filing date of the intent to use application, which is usually earlier than the first actual use of the mark in commerce. The statutorily created concept of constructive use is subject to several important exceptions—it does not apply against: (1) a prior common law user; (2) an owner of an application that is pending or has resulted in registration that was filed prior to the applicant’s filing date; or (3) a foreign owner of an application that is pending or has resulted in registration that includes a convention priority date under Section 44(d) that precedes the applicant’s filing date, provided, in each case, that abandonment has not occurred. 15 U.S.C. § 1057(c). Thus, under Section 7(c), the rights of prior nonregistered common law trademark owners are preserved, and not wiped out by the issuance of the federal registration. Constructive use can always be defeated by another’s evidence of a prior actual use. In the case of registrations resulting from applications containing a proper convention priority claim under Section 44(d), constructive use in the United States is triggered as of the filing date of the foreign trademark owner’s qualifying foreign application, that is, the convention priority date. 15 U.S.C. §1126(d). In the case of registrations resulting from in-bound Madrid applications under Section 66(a), constructive use in the U.S. is triggered, in most cases, as of the international registration date, or the convention priority date of the international registration, if any. 15 U.S.C. § 1141f(b). ICLG TO: TRADE MARKS 2012 © Published and reproduced with kind permission by Global Legal Group Ltd, London WWW.ICLG.CO.UK 3 Nixon Peabody LLP Trademark Use & “Use in Commerce” Under U.S. Trademark Law III. Priority Disputes It is in the context of this general overview of United States trademark law relating to trademark use set out above in Sections I and II that competing common law trademark rights and/or constructive use priority rights must be construed. The general rule in the United States is that, as between competing users in the same geographic market, the exclusive right to use the mark belongs to the first to establish trademark rights in that market, whether that use is actual or constructive. Starting with common law, where there are two common law users of the same mark in remote geographic areas, each may accrue exclusive rights, or priority, in its respective area. When the geographic areas are the same or overlap, the first to establish trademark rights (that is, the senior user) has exclusive rights in that market. See Hanover Star Milling co. v. Metcalf, 240 U.S. 403 (1916). In determining priority as between two common law users, courts consider evidence of the following: actual use of the mark (including advertising, sales volume, revenue, pattern of sales, and number of customers), business presence and reputation of each user (including consideration of whether the business attracts customers from different locations, the nature and extent of advertising, the geographic distribution of advertising, and the geographic origins of sales orders and customer inquiries), the intent (as in, good faith or bad faith) of each user, and, in some cases, a “zone of expansion” encompassing geographic areas into which use is likely to expand. See generally Natural Footwear Ltd. v. Hart, Schaffner & Marx, 760 F.2d 1383 (3d Cir.), cert. denied, 474 U.S. 920 (1985); Sweetarts v. Sunline, Inc., 380 F.2d 923, 929 (8th Cir. 1967), subsequent opinion, 436 F.2d 705 (8th Cir. 1971). In a priority dispute between a senior common law user and a second-in-time owner of a federal registration, the senior common law user will prevail, but only in the geographic area where it is using its mark. In a priority dispute between the owner of a pending intent to use application filed under Section 1(b) and a common law user who, after the filing date of the intent to use application, was the first to actually use the mark, the applicant will not be able to enjoin the conduct of the common law user unless and until its application matures into a registration. The intent to use applicant has no right of exclusion, and cannot rely on constructive use under Section 7(c), prior to registration. Priority disputes involving United States registrations issued to foreign trademark owners under Section 44 or Section 66(a), without actual use of the mark in the U.S., can be complicated. Consider, for example, where the senior user is a foreign trademark owner asserting constructive use resulting from a Section 44(e) registration and the junior user is a common law user. If the foreign trademark owner has not actually used its mark in commerce in the 4 United States, there will not be any likelihood of confusion in the United States to trigger a finding of infringement. Thus, while the foreign trademark owner might technically have priority, he will not be able to make offensive use of the Section 44(e) registration unless or until he uses the mark in the junior common law user’s market in the United States. Defensively, however, a Section 44(e) registration can be used by the USPTO as a basis to refuse registration of a later-filed third-party application for a confusingly similar mark on the grounds of likelihood of confusion. Use or registration of a confusingly similar mark can also be stymied by proof of “use analogous to trademark use”. For example, under Section 2(d) of the Lanham Act, a mark cannot be registered if it is confusingly similar to either a previously registered mark or to “a mark or trade name previously used in the United States by another and not abandoned . . . .”. 15 U.S.C. §1052(d). Some form of pre-sales activity can constitute “trade name” use, referred to as “use analogous to trademark use”, to establish priority so as to prevent registration of a mark to another. See West Florida Seafood, Inc. v. Jet Rests., Inc., 31 F.3d 1122, 1128 (Fed. Cir. 1994) (“Nothing more than trade name use is required to bar registration of a mark.”). As stated by the USPTO’s Trademark Trial and Appeal Board, “[u]se analogous to trademark use . . . is non-technical use of a trademark in connection with the promotion or sale of product under circumstances which do not provide a basis for an application to register, usually because the statutory requirement for use on or in connection with the sale of goods in commerce has not been met. Although never considered an appropriate basis for an application to register, such use has consistently been held sufficient to establish priority rights as against subsequent users of the same or similar marks”. Shalom Children’s Wear Inc. v. In-Wear A/S, 26 U.S.P.Q.2d 1516, 1519 (TTAB 1993). For pre-sales activities to constitute “use analogous to trademark use” sufficient to create proprietary rights, such activities must have been directed at potential purchasers, such that an association was created in the minds of the purchasing public between the mark and the petitioner’s goods. See Herbko Intern., Inc. v. Kappa Books, Inc., 308 F.3d 1156, 1162 (Fed. Cir. 2002). So-called “analogous use” priority has been applied in priority disputes by the TTAB and by some federal courts. IV. Conclusion As shown above, understanding the roles of actual use and “use in commerce” in U.S. trademark law is crucial in creating and implementing effective trademark protection and enforcement strategies within the United States. WWW.ICLG.CO.UK © Published and reproduced with kind permission by Global Legal Group Ltd, London ICLG TO: TRADE MARKS 2012 Nixon Peabody LLP Trademark Use & “Use in Commerce” Under U.S. Trademark Law Kristen Mollnow Walsh Jeffrey L. Costellia Nixon Peabody LLP 1300 Clinton Square Rochester, New York 14604 USA Nixon Peabody LLP Suite 900, 401 9th Street, N.W. Washington, D.C. 20004 USA Tel: Fax: Email: URL: Tel: Fax: Email: URL: +1 585 263 1065 +1 866 947 1121 kwalsh@nixonpeabody.com www.nixonpeabody.com Kristen Mollnow Walsh practices in the field of intellectual property law, with a focus on trademark and copyright-related matters. As counsel in the firm’s Brands & Creations group, Kristen has extensive experience in assisting clients with creating, protecting, and managing their brands. Kristen’s work for clients includes: comprehensive brand management advice concerning the adoption of new trademarks; creation and implementation of filing strategies to protect marks both within the U.S. and abroad; creative strategies for protecting non-traditional marks; portfolio management; counseling and implementation of enforcement strategies; handling of complex intellectual property due diligence projects; and copyright counseling, registration, and enforcement. Kristen has particular experience with domain name enforcement proceedings under the Uniform Domain Name Dispute Resolution Policy. She is also engaged in trademark, copyright, unfair competition, and false advertising matters before various federal courts and the United States Patent and Trademark Office. +1 202 585 8207 +1 866 947 0904 jcostellia@nixonpeabody.com www.nixonpeabody.com Jeff Costellia works with U.S. and international companies to develop effective, global intellectual property protection strategies, involving all phases of patent and trademark prosecution and enforcement protection. Jeff has extensive experience in all aspects of patent prosecution before the U.S. Patent and Trademark Office and has worked closely with hightech companies to protect their developments in electronic circuits, semiconductors, LCD and electroluminescent displays, chemical composites and polymers, locomotive and other transportation monitoring and sensing technologies, large scale product conveying equipment, mining technologies, microwave food packaging technologies, and consumer products. His indepth trademark experience includes trademark selection, registrability, and infringement counseling, particularly those involved with software, cosmetics, transportation monitoring and sensing technologies, product conveying equipment, sporting goods, and consumer products and services. Jeff also has considerable experience in trademark litigation in the United States federal courts, and trademark cancellation and opposition before the Trademark Trial and Appeal Board. Nixon Peabody LLP helps clients navigate complex challenges in litigation, real estate, corporate law, and finance. With approximately 700 attorneys throughout the U.S., Europe, and Asia, their focus is on working collaboratively to serve clients ranging from large corporations and financial institutions to entrepreneurs and private individuals. Employing innovative and clientcentred approaches, the firm helps to anticipate and capture opportunities, prepare for and manage risks, protect intellectual property, and forecast and overcome obstacles. Nixon Peabody is committed to the clients it serves, the communities in which it serves them, and the diverse professionals who have helped make it a “Best Law Firm” and a “Best Place to Work”. ICLG TO: TRADE MARKS 2012 © Published and reproduced with kind permission by Global Legal Group Ltd, London WWW.ICLG.CO.UK 5 Other titles in the ICLG series include: Business Crime Cartels & Leniency Class & Group Actions Commodities and Trade Law Competition Litigation Corporate Governance Corporate Recovery & Insolvency Corporate Tax Dominance Employment & Labour Law Enforcement of Competition Law Environment & Climate Change Law Gas Regulation Insurance & Reinsurance International Arbitration Litigation & Dispute Resolution Merger Control Mergers & Acquisitions Patents PFI / PPP Projects Pharmaceutical Advertising Private Client Product Liability Project Finance Public Procurement Real Estate Securitisation Telecommunication Laws and Regulations 59 Tanner Street, London SE1 3PL, United Kingdom Tel: +44 20 7367 0720 / Fax: +44 20 7407 5255 Email: sales@glgroup.co.uk www.iclg.co.uk