Naked Cow-people Bring Tiff to Court

July 23, 2010

In addition to the more formal entertainments on offer in and around Times Square, New York, there are three scantily dressed buskers. One who calls himself the Naked Cowboy and a further two, each of which calls herself the Naked Cowgirl.

These entertainers wear cowboy hats and boots and sing to the accompaniment of their guitars.

The Naked Cowboy, Robert John Burck, was born on December 23, 1970 in Cincinnati, Ohio.  He can be viewed on his website: www.nakedcowboy.com. In his performances,  he wears a pair of y-fronts, and holds the guitar sufficiently low to conceal the garment, giving the impression that he is nude – hence the name.

Louisa Holmlund, wears a micro-skirt and a pair of little mirrors on her nipples. Both earn tips by crooning the crowds and by providing photo-shoots. Apparently, she pays royalties of $500 a month or $5000 a year to the Naked Cowboy. She can be seen on her website here: www.nakedcowgirlny.com

There is now a second Naked Cowgirl; Sandra Brodsky who calls herself Sandy Kane. She  wears a starred and striped bikini and matching cowboy hat and refuses to pay a franchise fee.   She is in her 50s.

It seems that the Naked Cowboy is the original act, that inspired or was plagiarized by the Naked Cowgirls. Both have been somewhat lapse with their trademarking, with the Naked Cowboy’s mark lapsing and being refiled, and the Naked Cowgirl’s mark also lapsing.

As the Naked Cowgirl Kane has refused to take out a ‘francise’ from the Naked Cowboy – what I suppose would be called ‘protection money’, the Naked Cowboy has sued for infringement of his IP rights.

According to Burck, Kane is ripping off his intellectual property, he also claims her act is “un-American” and makes a “mockery of the system and the trademark infringement laws.”

Having entered the silly season (onat hamalafafonim - the “cucumber season” in Hebrew), this epic battle of the sexes has been picked up by the various newspapers as well as the IP Blogs – including our friends, the IPKAT.  With a dirth of real IP stories to discuss, and with the Israel Courts in recess, I have decided to analyze this case. Noone seems to have actually commented on the legal issues. So here goes.

I don’t think that being un American is a crime, even in Time Square. The issue of trademark infringement is something that can sensibly be discussed however. I thing that both trademark registrations are limited to the combination of Naked Cow+boy and Naked Cow+girl. Both marks are somewhat descriptive, perhaps the naked cowgirl with udders on show, is even more so.

I don’t think either mark should be interpreted to give wider protection than exact copying.  In other words, the fact that both use he words Naked and Cow does not imply copyright infringement or passing off. the words Boy and Girl are opposites.

For the same reason that North Face is not infringed by South Butt, I don’t believe that the word mark Naked Cowboy is infringed by Naked Cowgirl.  I don’t think that there is a likelihood of confusion either. Male body builders look different than female strippers. It’s probably something biological.

That said, and although perhaps aiming largely at a different segment of the crowd, with the Naked Cowboy getting tips from women tourists and homosexual men, and the Naked Cowgirl attracting heterosexual men, one could argue that there is a problem in setting up a competing business on someone else’s patch.  This raises various issues. For example, does a busker, who does not invest capital in premises but who clearly invests time and energy in becoming a tourist attraction in his own right, create rights?

Ms Kane seems a little past her prime. It could be that she does have a negative impact on the trade. Is this a crime?

In Jewish Law, one cannot simply open a business opposite a competitor. the issue seems to be more one of drawing away trade than passing off. However, this halachah is not the law in New York. It seems that the State does allow one to open up souvenir shops, coffee shops, restaurants and hotels opposite similar establishments, and I am skeptical that merely because Times Square is the Naked Cowboy’s patch, that other buskers can’t perform there.

Arguably, all the cowpeople are part of the scene that keeps tourists visiting Time Square.  I don’t believe that the newspaper and postcard vendors that benefit from the buskers attracting the crowds should pay them, nor do I think that the buskers should pay the theatres for bringing the crowds.

The franchise issue is an interesting one, but I would argue that noone would assume that there is a franchise for buskers and one does not order their services, but simply tips the individual if entertained. The tip is generated by the behavior of the individual at the time that the tip is made. It is not something related to the chain.

A waitress working in a chain of restaurants would not be expected to share her tips, so why should a busker?

Singing songs created by Burck would be copyright infringement. The combination of a cowboy hat, boots and underwear is not.  As is often the case, there is a confusion between an idea and the expression of the idea. Dance steps, routines, songs and the like can be protected with copyright. I don’t think the basic idea of the act can be.

Burke claims that Kane’s performances have caused “confusion” with the public and may put “a potentially permanent devaluation on a real American Brand and Icon.”

It is not the first time that Burke has gone to court to protect his trademark. In February 2008 he sued Mars Inc. in federal court in Manhattan, alleging that a blue M&M character, dressed in underpants and boots that appeared in the candy’s advertisements, violated his trademark. That suit was resolved in November that year. Neither party gave a reason for the dismissal with prejudice, which prevented Burck from re-filing his lawsuit.

The M&M advertisment was one of a series, which included an M&M dressed as the Statue of Liberty and an M&M as King Kong climbing the Empire State Building.

U.S. District Judge Denny Chin, who presided over the earlier lawsuit, ruled that Mars had to face Burck’s false- endorsement claim,wherein he claimed that there was a potential for consumers to believe Burck supported the ads. However, Burke’s right-of-publicity claim against M&M was refused.

Louise Holmlund had a stronger case of claiming trademark infringement as she’d held a mark for Naked Cowgirl. Unfortunately, however, it died in 2007.

Likelihood of confusion with Burke, not convincing. His second claim seems to be one of dilution. Here he may have a point. I think the case should be thrown out. Both sides will probably gain from the publicity in the meantime though.

1 Comment | Copyright, Fair Use, passing off, plagiarism, trademarks, Uncategorized | Permalink
Posted by Dr Michael Factor

Teva Suspends Litigation to Invadidate Eisai’s Compound Patent for Drug Aricept

July 21, 2010

Teva Pharmaceuticals USA Inc. has agreed to suspend litigation over a compound patent for Eisai Co. Ltd.’s popular Alzheimer’s drug Aricept, thereby ending Teva’s attempts to manufacture and market a generic version of the drug before the patent expires in November.

Judge Garrett E. Brown Jr. of the U.S. District Court for the District of New Jersey signed off on the agreement Monday, and called for the case to be dismissed after the patent expires. However, the March 2008 preliminary injunction prohibiting Teva from manufacturing drugs including ingredients covered by the patent remains in effect.

Teva filed an abbreviated new drug application with the U.S. Food and Drug Administration in 2008, and, when sued by Eisai, initially claimed that the patent was invalid due to obviousness, and later changed defence to claim inequitable conduct.

Teva had asked for communications not related to the patent-in-suit, but to seven co-pending patent applications that it claimed Eisai failed to disclose to the patent examiner in charge of the application that led to its Aricept patent-in-suit.

In December, Magistrate Judge Esther Salas denied Teva’s motion to compel discovery for its inequitable conduct defense. Teva, which sought communications between Eisai and the U.S. Patent and Trademark Office, appealed to Judge Brown, but he affirmed Judge Salas’ order in June, that concluded that the generics maker’s discovery request was too broad and unduly burdensome.

Teva also sought discovery of communications between Eisai and the USPTO related to any abandoned patent applications that involved derivatives of benzylpiperidine, the active chemical in Aricept, on the grounds that they also might contain information to support the inequitable conduct defense. But Judge Salas said the patent applications were outside the scope of the companies’ current dispute and that expanding the search to include abandoned patent applications would “be a burden that outweighs the benefits to Teva.”

The patent-in-suit is U.S. Patent Number 4,895,841.

The case is Eisai Co. Ltd. et al. v. Teva Pharmaceuticals USA Inc. et al., case number 05-cv-05727, in the U.S. District Court for the District of New Jersey.

Leave a Comment » | drugs, Intellectual Property, Israel, pharmaceuticals, pharmaceuticals and Biotechnology, Teva, US | Permalink
Posted by Dr Michael Factor

Competing Marks for Play Condoms – a Strange Decision

July 20, 2010

Apparently LRC Products Ltd. (Durex) and Ansell Limited (Life Style) both filed trademarks for condoms that included the word Play.

Durex filed two marks: IL 174678 for the word mark Play, and IL 174730 for the word mark DUREX PLAY. 

Life Styles filed application number IL 178348 for Life Style Play, as a graphic mark :

 

 As these marks were all competing marks, as evidenced by the opening line of the decision: “Before me are competing applications”, one would expect that the filing dates and classes were of some importance. Apparently not, since these were not reported in the decision.

For those interested, the word mark application for Play - IL 174678 was filed on 12 September 2004 in class 10 (Medical Devices) for the following list of goods: Condoms; contraceptive, hygienic or prophylactic devices; massage apparatus, instruments and appliances; electric and electronic message apparatus, instruments and appliances; body massagers; personal massagers; vibrators; marital aids; sex aids; parts and fittings for all the aforesaid goods; all included in class 10.

Lifestyle’s mark was filed on 8 February 2005 for condoms in the same class.

Two companies cannot both be awarded the same mark for the same goods as trademarks are supposed to be indications of origin. Once a mark is awarded to one party, a second party can only register the same mark if the first mark is canceled.

In cases of competing marks, where a second similar mark is filed after a first mark is applied for but before the first mark is allowed, the regulations determine which mark is to be examined, using a first-to-file principle.  The chronological hierarchy is, however tempered by the extent of usage of the mark and by issues of equitable behavior. The law regarding Competing Marks is found in Section 29 of the Trademark Ordinance.

Current Case Law establishes that a mark that is first filed and in use prior to examination, that was applied for without evidence of inequitable behavior, should be examined first.  The grounds for deciding are:

  1. Date of application
  2. Usage of the mark
  3. Equitable behavior

Trademark applications are ex partes procedures. Only if and when a mark is allowed, i.e. after the examiner establishes that the mark is sufficiently distinctive from other, earlier marks, and not too generic to be allowed, or with disclaimers for generic elements, etc. the mark publishes for opposition purposes, which is an inter partes procedure where other parties can claim that the mark belongs to them, or is generic, etc. 

Judge Gronis ruled in the case of Sabon Shel Paam, that despite the occasional uncomfortable feelings arising from awarding a mark in accordance with trademark regulation 29a, to one party, with the other side losing, such is the nature of trademark rulings. Deciding such cases results in one side winning and the other losing.

Judge Gronis’ decision was cited in the ruling in this case, so was clearly known to the Deputy Commissioner Noach Shalev Shmulovich who ruled in this case.

The situation is that a subsequent filing of a second mark should not prevent the first mark from being examined on its merits. At least so we thought…

Perhaps because they had no grounds under the regulations or the case-law to prevail, Lifestyles, represented by Adv. David Wahlberg, decided to focus their arguments on the substantive issue of whether the word Play could be considered distinctive in the context of condoms and vibrators, etc.

Surprisingly, instead of pointing out that the question of apparent distinctiveness was for examination by the trademark examiner and, if necessary, for appealing in an opposition proceedings, having decided which mark should be examined, the Deputy Commissioner, Noach Shalev Shmulovich decided to relate to that issue, ignoring the legal issue before him.

There is some precedence for so doing, e.g. the Eshel decision, where both Tnuva and Yotvata filed marks for the word eshel, seen as generic for the product -  a sort of fromage frais. 

Nevertheless, in a later decision, relating to the issue of “Kochav Nolad” (literally A Star is Born), it was clearly stated that in cases of competing marks, the registerability of the mark is not an issue, merely which party is considered as taking precedence. 

Shmulovich hypothesized that the examiner would probably have ruled that the term Play was too broad and would have rejected the word mark Play and accepted the Durex Play mark with a disclaimer from the word play, leaving the way open to Lifestyles to then have their mark examined. He therefore refused IL 174678 and allowed both IL17430 and IL 178348.

In other words, both Durex and Lifestyle can continue to sell condoms under the name Play, provided that the manufacturer continues to be clearly indicated.

To add insult to injury, Shmulovich awarded costs to Lifestyle as he’d cancelled the simple Play mark applied for by Durex. But if no opposition was filed, why should Lifestyle receive costs? 

The fact that a product has historically been sold by line name and brand name together, should not necessarily be taken as sufficient to prevent the line name from being registered. At least not whilst the patent office is allowing such secondary marks to be registered and generating a not inconsiderable income whilst so doing.

If sexual intercourse with condoms is considered as playing, the term Play may be too generic to be registered for condoms in and of itself. So be it. That decision is separate from the issue of that of competing marks.

Publishing decisions should help clarify the law and create a corpus of case-law that makes clear what the relevant considerations are. This decision contradicts earlier rulings and seems to clarify that there are no rules and no guidelines.

Could be worse though. Following the decision in Hamastan to not allow trademarks to be registered for alcoholic drinks, the trademark office could have taken a tough approach against birth control, particularly condoms which have been particularly frowned upon by the Rabbis, and prevented registration on morality grounds

ADDITIONAL COMMENTS

The BBC has a satellite channel called Lifestyles. There are other users of the name that don’t necessarily sell condoms and the like.

Catholics and others may take exception to using a brand name including the word  ’life’ with a contraceptive. I merely note the irony.

Finally, we note that Warner Brothers are suing the swedish condom manufacturer MagicX for trademark infringement regarding their Harry Popper brand of prophylactics which they see as tarnishing the teenage wizard’s reputation.  See http://www.telegraph.co.uk/culture/harry-potter/7953878/Harry-Popper-condoms-sued-by-Warner-Brothers.html

Leave a Comment » | Israel Patent Office Rulings, Israel Trademark, trademarks, Uncategorized | Permalink
Posted by Dr Michael Factor

So that’s how Syria will avoid granting trademarks to Israeli Entities!

July 18, 2010

Apparently the Syrian Trademark Office has been recently requesting Powers of Attorney (PoA) to be legalized by Syrian consulates abroad, and then obtaining the Syrian Interior Ministry’s approval and super-legalization on this document by the Syrian Ministry of Foreign Affairs.

This practice comes in compliance with the Syrian Interior Ministry’s regulations to obtain clearing approval on the Powers of Attorney for all Intellectual Property applications in Syria (trademarks, designs, patents, recordals…).

We suspect that this practice will be applied to Israeli entities, who, lacking Syrian consulates, will be unable to comply with the regulations.

Ah well, I suppose any trademark registrations would be canceled due to lack of use, so no harm done…

of WIPO at a trademark seminar in Jerusalem, Israel, last week, there is no provision for preventing trademark registration on basis of country of origin, only on substantive grounds such as previously filed, similar mark to a third-party, etc. NtamackAs of 1 September 2010, Israel will be party to the Madrid Protocol and Israeli entities will be able to file for multinational trademark registration via a simple check-list.  One of the countries that is party to Madrid is Syria. As confirmed by Andre

Leave a Comment » | Arab IP, Intellectual Property, trademarks | Permalink
Posted by Dr Michael Factor

Yeda Fails to Obtain Supplementary Protection Certificate in UK

July 16, 2010

To obtain a Supplementary Protection Certificate (SPC), enabling patent protection beyond 20 years from filing, for up to five additional years, a drug has to have received regulatory approval for marketing.

Yeda,  the technology transfer arm of the Weizmann Institute in Rehovot, Israel, applied for such a Supplementary Protection Certificate in the UK for a combination of a novel monoclonal antibody with anti-neoplastic drugs.

However, the Intellectual Property Office (UK Patent Office) refused the request and the British High Court has upheld the decision that the patent was not entitled to a supplementary protection certificate (SPC) under the SPC Regulation (469/2009/EC) because the relevant marketing authorisation was for the monoclonal antibody alone.

However the court also rejected a second application for an SPC for the monoclonal antibody alone, because even though the two components could be separately administered, it was clear that the claimed invention was for the combination, so that the application for an SPC for the monoclonal antibody was also rejected as failing the current UK case-law governing the interpretation of the SPC Regulation in relation to combination drugs. 

 Case: Yeda Research and Development Company Ltd v Comptroller General of Patents [2010] EWHC 1733 (Pat), 12 July 2010.

Leave a Comment » | drugs, Intellectual Property, IPO, Israel, Israel Trademark, Patents, pharmaceuticals | Permalink
Posted by Dr Michael Factor

Trademark for IP Translator Refused by the UK Intellectual Property Office

July 16, 2010

An application by the Chartered Institute of Patent Attorneys for the trade mark IP TRANSLATOR in class 41, was rejected by the UK Intellectual Property Office. – Embarassing isn’t it?

I wonder what sort of service IP Translator provides and whether the name is at least a tinsy bit generic?

There will be a follow-up to this as the Appointed Person has referred to the European Court of Justice about getting trademark protection for category headings.

Leave a Comment » | IPO, trademarks | Permalink
Posted by Dr Michael Factor

Finjan – developer turned troll?

July 16, 2010

Israel based software company Finjan has sued five rival security companies, including Symantec and McAfee, Webroot Software, Websense and Sophos.

In a lawsuit filed Monday in the U.S. District Court of Delaware, Finjan, claims that products of the defendants including McAfee’s Web Gateway and VirusScan software, Symantec’s Brightmail Gateway and Norton Antivirus all infringe core technology patents for antivirus products and security services that are held by Finjan.

Formerly a technology vendor, Finjan has sold out to M86, another security company, but still owns a patent portfolio, of about a dozen patents that are related to computer security. The company is now trying to claim royalties from these patents.

In 2008, Finjan won a jury verdict of 9.2 million dollars against Secure Computing which is now owned by McAfee.Having demonstrated that Secure Computing’s software packages Webwasher and CyberGuard TSP were infringed, A federal judge then increased the damages awarded to $13.8 million.

The company has asked the court to award unspecified financial damages and an injunction preventing the companies from selling their products.

COMMENT

Since the company no longer manufacturers, there is no longer the mutual destruction arrangement favoured by the high-tech world as an in-built mechanism to prevent companies going after injunctions. That said, it is clear that as they no-longer have a market share, Finjan have no interest in preventing others from using their patents. They simply want a reasonable royalty. It seems to me that it is not non-practicing entities that are the problem , but that there is no simple means to calculate fair royalties and to ensure that alleged infringers swiftly identify if they do indeed infringe, and, if so, that they enter into licensing negotiations in good faith.

I think that the cost of litigation in the US is the real problem, not that entities enforce their patents. Identifying and buying up patents to enforce (trolling) is not morally different from a litigating law firm working such cases on a percentage, or a university – which is typically a non-profit organization that benefits from the tax-payer and from philanthropic donations – from filing and then licensing its patents. These business models are acceptable in a free market.  Patents are not licenses to manufacture. They merely provide exclusion rights and using them for that purpose is legitimate. Trading in patents is based on the exclusion right being enforceable.  The ownersof this patent, if they manage to collect royalties, will no-doubt invest the money back into the economy. Transferrring patent rights to those that need it by licensing, and reinvesting resources is the basis of business. Good luck to them. Shame I don’t have shares.

Leave a Comment » | infringement, Israel, Israel Related, Licensing, NPE, software Patents, telecommunications | Permalink
Posted by Dr Michael Factor

Israel Patent Office Holds Madrid Protocol Seminar

July 15, 2010


I went along to a Madrid Protocol seminar yesterday, that was organized and hosted by the Israel Patent and Trademark Office. There were feelings of deja vu, with the speakers and most of the audience overlapping with those at a similar event held 3 years ago, when Israel was supposed to implement Madrid, but didn’t due to technical problems due mostly to computerization and meeting the stringent deadlines.

Dr Meir Noam the Commissioner of Patents and Trademarks, and Ms. Nurit Maoz, Head of the Trademark Department, both briefly spoke, followed by Andre Ntamack, Head of International Trademark Examination at WIPO who was the main speaker.

After endearing himself with the audience by using a smattering of Hebrew phrases, he mentioned that it was his second visit and presentation on the subject, so apparently he was also experiencing deja vu.  Ntamack then went on to explain about Madrid and how to file and prosecute international applications. The chocolate croissants were delicious. The coffee was Elite Instant and Turkish (Botz), and there was no tea.

The lecture hall was comfortable though, and apart from the usual internet hiccups and problems with the microphone, etc. the event went smoothly. Andre Ntamack gave Jerusalem as an example of a location in Israel, which, for a UN employee, was quite refreshing. I am not sure if he knew that Malcha, where the Patent Office is, was under Jordanian Occupation prior to 1967.

When asked, he stated explicitly that there were no provisions for rejecting an application that was also ratified in Israel, or where applicant was domiciled or incorporated in Israel or of Israel nationality. Somehow I suspect that Iran, Syria and other members of the Madrid Protocol that do not recognize Israel’s existence, and apply a third-party boycott, will no doubt create some wiggle-room.

Ntamack estimated that the overall effect of Madrid would be more not less work for local practitioners. What is certain is that it offers local industry and exporters with a cost-effective way to get protection for their trademarks, that they’d be advised to utilize.

As is typical of these events, it offered a good opportunity to exchange greetings with other practitioners.

The Israel Patent Office and WIPO are to be congratulated for puttign together a professional event.

Leave a Comment » | Israel IP, Israel Patent Office, Israel Trademark, trademarks, WIPO | Permalink
Posted by Dr Michael Factor

Lower PCT Fees from September

July 11, 2010

The cost for filing a PCT application will drop significantly in September. The International filing fee is being reduced from $1300 to $1147 from 1 September 2010, and, as of 15 September 2010, the Search fees using the European Patent Office as the International search Authority will cost $2185 instead of $2485. Additional page fees – past the first 30 (including forms) will be reduced from $15 a page to $13 a page.

The official fees for a PCT application, will, therefore be about 15% cheaper which is good news for applicants!

Leave a Comment » | Intellectual Property, Patents, PCT, WIPO | Permalink
Posted by Dr Michael Factor

Chinese Commissioner of Patents Speaks in Tel Aviv

July 8, 2010

Minister Tian Lipu, Commissioner of the State Intellectual Property Office of China spoke to a select group of patent attorneys and industrialists in a meeting held at the Dan Hotel, under the joint auspices of the Israeli Ministry of Foreign Affairs and the High Tech Industry Association (HTIA).

After Opening Remarks delivered by Mr. Oded Hermoni, CEO of the High Tech Industry Association, a representative of the Ministry of Foreign Affairs, and by Dr. Meir Noam, Head of the Israeli Patent Authority and Commissioner of Patents Designs and Trademarks, we were treated to a short and informative talk about IP in China delivered by Adv. Ehud Hausman, a patent attorney and Senior Partner of Reinhold Cohn.

Then Amir Gal-Or, Founder & Managing Partner of the Infinity Group/Infinity I-China spoke about investment and return on investment in China. All the above, spoke in English, despite none of them being native English speakers.

Tian Lipu, the head of the Chinese Patent Office introduced himself briefly in English, but then spoke via an interpreter, which is not a bad idea for non-English speakers.

Apart from the competence of the diminutive lady translating, which made the translation not unpleasant, I actually enjoyed hearing the deep twangy intonations of the Chinese – although I couldn’t understand a word.

Tian Lipu spoke of the fast changes being implemented in China, a country with no tradition of Intellectual Property. the commissioner pointed out that of the 1.2 Billion Chinese in 1979 when he started in the field, perhaps 12 people knew what a patent was, 4 could assess infringement and none could examine.

We learnt that the Chinese patent Law dates from the nineteen eighties and that the first Chinese term for IPR was first coined in 2000.

Commissioner Tian Lipu generously acknowledged both Israeli and Jewish long traditions of IP. We learned that Israel and China had signed a memorandum on cooperation, which indicates the mutual respect and importance held by the two patent offices and of Israeli and Chinese industries.

Commissioner Tian Lipu acknowledged a thousand year history of peaceful commerce between the Jews and the Chinese and expressed hopes that this could be built upon for the next millenium. We learned a little about the scale of things in China, and contemplated what extraordinary good money a Chinese patent is.

Most of the presentation related to the development of Chinese intellectual property system, current Chinese Patent Law and why IPR protection important to independent innovation. Commissioner Lipu took questions and answered fairly, admitting that there were still problems with enforcement and with the quantity of fake goods coming out of China, but pointed out where the system started only 25 years ago, and that there were a lot of people requiring education about IP rights. It is clear that Chinese system is leading towards an advanced pro IP regime, similar to those common in the West.

Lipu argued, and her is correct, that the Chinese cannot be fairly considered responsible for every fake good or infringing product manufactured in China, where the goods are ordered by suppliers from abroad.

We learned, that in addition to checking goods imported into China, the country was unique in checking goods exported abroad for IP infringement. The commissioner put a fair case that statistics on infringement and cost of infringing goods should be compared to the billions that China invests in royalties to Western countries, that get’s less coverage.

The chocolate eclairs where good, and, as is well-known, no calories on a thursday! The organizers and sponsors are to be congratulated for throwing together the event so quickly.

Leave a Comment » | China, Intellectual Property, News, Uncategorized | Permalink
Posted by Dr Michael Factor

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