Thursday 28 April 2016

Anonymous

A pronouncement on image rights in Uganda – finally.

Following in the heels of Al Hajji Nasser Sebagala versus MTN, H.C.C.S No. 283 of 2012 (see here) and Agaitano versus Uganda Baati, H.C.C.S No. 298 of 2012 (see here), the High Court has come out in Asiege v. Opportunity Bank (U) Ltd & Maad Ltd H.C.C.S No. 756 of 2013, to set a precedent on image rights in Uganda, carefully steering away from the law of Copyright.

In the Sebagala case of 2012, the plaintiff sued MTN claiming that the defendant had used his voice in creating call/ring tunes without his authorization. Although it was apparent that it was his voice on the call tunes, as Justice Madrama rightly held, the Plaintiff did not own copyright to the creativity. This is because he was not the author of the call tunes. Nonetheless, the case left ordinary folks puzzled as to how different persons can gain from an individual’s personality and still get away with it. In the various classes that I teach copyright law, the issue that resonated with everyone was as to whether Sebagala would have had a better case if he had avoided relying on copyright law and sued for unfair enrichment derived from his image rights. There are no clear legislative provisions that can help one establish a claim in that category of rights. Some have been arguing that celebrities have a better right to their images than ordinary Toms, Dicks and Harrys. Others argue that even a non-celebrity should have the right to stop anyone from using his or her image for personal gain. Agaitano as opposed to Sebagala (a Ugandan celebrity in his own right), is such an ordinary person. He sued his employer, Uganda Baati Ltd, for using his image on their brochures and other promotional material. But, just like Sebagala, he too lost the case because he was not the author of the expression of the work. Agaitano had actually been informed by his employer that they would be taking pictures of staff members for promotional purposes. These two cases clearly spelt out that copyright law and image rights are not necessarily the same thing.

In comes Asege Winnie v. Opportunity Bank (U) Ltd & Another, H.C.C.S No. 756 of 2013. In this case, the matter of image rights in Uganda has been put to rest. Briefly, the plaintiff sued the defendant for using her image in     large promotional billboards, advertising flyers, brochures and calendars that the Bank used in different parts of the country. Her claim was for a breach of her constitutional right to privacy, passing off, misrepresentation and false endorsement, breach of confidence and unjust enrichment in the unauthorized use of her image.

She argued that she had never commissioned or licensed the defendant to use her image on their promotional materials and that the same was obtained without her authorization hence invading her constitutional right to privacy. The Bank denied the Plaintiff’s claim and stated that it obtained her images from the second defendant (a third party in the proceedings) whose professional services had been sought as an advertising company. Maad Limited, on its part, claimed that it lawfully obtained the plaintiff’s photo images from an internet based website known as Shutter Stock Inc as well as from the New Vision Printing and Publishing Company Ltd. The Plaintiff rebutted these arguments by pointing out that the New Vision and Shutter Stock Companies did not acquire any copyright in her image because when the picture was taken, it was for a single usage only and not transferable for recurrent usage.

Justice Henry Adonyo pointed out how the issue of image rights is a grey area in Uganda hence the reliance on common law principles of personality rights. He opined that publicity rights fall under the tort of “passing off” with the notion that every individual should have a right to control how, if at all, his or her “persona” is commercialized by third parties who intend to help propel their sales or visibility based on such product or services. In his wisdom, basing on the common law jurisprudence, Justice Adonyo established three basic elements that have to be present for one to succeed in an action for infringement of image rights:

a)     The Plaintiff must be identifiable.
b)    The defendant’s action was intentional.
c)     The defendant must have acted for the purpose of commercial gain.

In addressing these elements, Justice Adonyo navigated outside of copyright law in stating that the Plaintiff’s claim is not established under the Ugandan copyright Statute but under a common law remedy resulting from the unlawful use of her image.

Relying on evidence adduced during the court proceedings, all three elements were proved to the satisfaction of court. As for the third element, it was also evident that the plaintiff’s image was used by the Bank to promote their so called “Agro Save Account” hence commercial promotion.


Justice Adonyo concluded by asserting that “every individual has a right to his/her personality which extends to the name of the individual and image and has a right to control the use of either.” The Defendant and Third party were thus found to have infringed upon the Plaintiff’s image rights and damages, totaling 150,000,000 (One hundred and fifty million Uganda Shillings) were awarded in her favor. Corporations and individuals will now think twice before unauthorized usage of other people’s images.
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Wednesday 27 April 2016

Darren Olivier

Lessons from "Please Call Me" Concourt Judgment

Trending yesterday on Twitter in South Africa on World IP Day were two entrepreneurs, each with a great idea. One had just spent fifteen years trying to get compensation from a large telecoms company that had stolen it and had made billions of Rand, and the other was launching three new brands to sit aside alongside a record breaking success in 2015. Both were celebrating.

One’s success highlights what can happen when there is little or no IP or contractual protection in place for an idea, the other the advantage of having a strong sense of IP. Afro-IP blogged on Ali Gregg’s success on Sunday here. Now for Mr Makate and his fight against Vodacom.

The almost hundred page judgment from the constitutional court yesterday makes for exciting, and laborious reading. Exciting in the sense that it documents a brilliant idea coming from a modest yet determined man in the accounting department of a telecoms behemoth and his fifteen year battle for justice all the way to constitutional court, and laborious to anyone not interested in 80 pages dedicated to the difference between estoppel and ostensible authority, if indeed there is one.

In short, Mr Makate invented a concept whereby one could send a message on a cell phone to someone to “please call me” at little charge and which was especially useful in the lucrative prepaid mobile phone market especially when one ran out of airtime, which was often the case. He relayed that to his manager and then to his head of product development asking for 15% of profits compensation for the idea. The company agreed to let the CEO determine the compensation, if there was no agreement on that.

The company then celebrated his idea and made billions then refused to pay him claiming that the idea was theirs, that his claim had prescribed and that the head of product development had had no authority to bind the company.

The case was dismissed in the High Court in an equally exciting and laborious judgment (see earlier Afro-IP post here), leave to appeal to the Supreme Court of Appeal was rejected and Mr then sought justice in the Constitutional Court. Yesterday that court handed down a decision vindicating Mr Makate, castigating Vodacom and ordering that the company abide by its agreement to pay Mr Makate, and negotiate in good faith to determine the exact amount necessary to be paid.

Despite the very long judgement and the hype around this case the lessons to be learnt from it are fairly simple. If you have a great idea outside the course and scope of your employment:

a. document it
b. get an sense of whether it can be patented or how the five different forms of IP can be used to protect it (most lawyers will not charge you for this)
c. use a properly drafted NDA when you disclose it
d. speak to the right person (and even take your attorney along)
e. don’t be naïve – sense the opportunity to reveal your entire idea at the right time

This post here provides further tips for entrepreneurs seeking to protect and exploit their idea. A link to this blogger's discussion on this case on PowerFM on Victor Kgomoeswana's show with Maclean Sibande (CEO of the Innovation Hub) will be inserted as soon the podcast is on their site. You can now view this here.
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Sunday 24 April 2016

Afro Leo

Philanthropy's Purple Rain as Africa's Pallotta Launches 2016 SleepOut™ Event

Last year Ali Gregg founder of the SleepOut cause in South Africa invited this blogger to be a trustee of the CEO SleepOut Trust which is appointed by her company to monitor the SleepOut record-breaking philanthropic concept in South Africa. Part of this responsibility entails preserving the intellectual property associated with that cause, a task that requires one to carefully navigate the business of brand building in the philanthropic space.

On Tuesday the CEO SleepOut Trust reports at the media launch for the 2016 event. Well over 200 people have signed up to attend and that daunting fact alone is causing me to reflect a little deeper on the nuances associated with the role. Why was it that a trade mark lawyer was the very first person that Ali called when she returned from Australia to launch her brand in South Africa? True story. Oh and then, I am almost certain, followed up by a call to her priest.

The front page headline in the Wall Street Journal a few years ago stated boldy “Charity Brawl: Nonprofits Aren’t So Generous When a Name’s at Stake” referring to the stinging criticism received by a celebrated charity for enforcing their rights over part of their name. The palaver prompted a retort from Dan Pallotta, renown philanthropist who is evangelical about the need to change the mindset about how we see charity and for charities to change their perception of themselves (see his post in Harvard Business Review entitled “Is it Wrong To Sue a Charity? and his fabulous Ted Talk here). His post was followed by an insightful article published in Boston College Law Review by Lauren Behr entitled Trademarks for the Cure: Why Nonprofits Need Their Own Set of Trademark Rules.

In short, the WSJ and its commentary illustrate the difficulties of protecting a brand name built up through sheer hard word in the philanthropic space, both from a legal and PR point of view. Without the brand, the philanthropic’s ability to communicate, mobilise and ultimately do good, can be severely compromised. Yet protecting it could ultimately threaten the integrity of the philanthropic altogether.

“To say that public reaction was vitriolic would be an understatement. To give you a flavour one anonymous critic wrote to me that I was evil, adding, “No wonder your partner killed himself.” (My partner had committed suicide a year and half earlier.)” Dan Pallotta (left) in his post in HBR, referring to reaction when his business decided to take legal action against another charity.

...enough to turn anyone to prayer.

It’s not just an issue in the States, last last year the UK IP court adjudicated on who had rights in the name OPEN COLLEGE NETWORK and OCN between two educational charities. Prof Jeremy Phillips emotively describes the spat as “..the most perfect example of a disgraceful waste of utter stupidity in branding and squandering of charitable funds for no constructive purpose this Kat has yet to see it.   While this Kat is a keen supporter of charities in general and educational charities in particular, he would be most reluctant to see so much as a penny's worth of his hard-earned cash go to any charity that adopted a logo as confusingly similar to that of another charity, whatever its alleged reason or justification.”

www,wrestlingforum.com
The lethargic but acrimonious fight between the WWF (wrestlers and the wildlife fund) over the last decade (and more) has been well documented and in Romania recently an international charity offering guidance and assistance in the areas of religion and relationships had to step in and protect its ALPHA trade mark against ALPHA CLINICS. In Israel, a recent decision not to recognise the goodwill in a charity because it was not “in business” illustrates some of thinking that Dan Pallota is guarding against and closer to home the position is no different.

Not long ago, it was not possible to register a trade mark in South Africa for a charity because trade marks had to be capable of being used in trade, and a charity was not considered a trade. This has changed but there still exists a responsibility for the charity to police and protect the trade mark. The National Lottery Board’s failures to manage the use of their trade mark by others lead to a Supreme Court of Appeal decision in 2009, invalidating their LOTTO trade mark for becoming generic (see Afro-IP here). The repercussion of this decision may well be that someone gaming with a different lotto on the assumption that some of their funds are going to a charity.

This is why Behr in her article advocates for greater protection for trade marks in the non-profit sector “because the work of these organisations affects the greater public as well as both potential donors and recipients”. I would agree with that.

Back to the CEO SleepOut event, the rights in the trade marks SLEEPOUT and its associated marks eg CEO SLEEPOUT, RISE TO THE CHALLENGE, #SOUTHAFRICAMUSTRISE, STUDENT SLEEPOUT, SCHOLAR SLEEPOUT and others are protected through the CIPC, the Advertising Standards Authority, through an application to the DTI for the event to be determined a protected event and at common law. The sponsor’s rights are protected through their own trade marks and the Sponsorship Code against ambush marketing. These rights are in the hands of a tremendous IP Commercialisation team at Adams & Adams including Lita Miti-Qamata,John NdlovuIan Learmonth  Maureen Makoko, and Nicholas Rosslee,

So, not everything’s on a wing or a prayer. 

Here’s wishing Ali - Africa's Pallotta - a fantastic launch on Tuesday. It’s truly time for the SLEEPOUT brand get charity brands out of their purple rain.

Oh and here's also a formal challenge to all IP firms in South Africa to participate....

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Thursday 21 April 2016

Afro Leo

Aggregator site needs to get permission to use trade marks says judge in RSA

illustrative use!
Car Find (Pty) Ltd ("Car Find") successfully approached the high court in Johannesburg on an urgent basis to restrain Car Trader (Pty) Ltd ("Car Trader") from using the trade mark CAR FIND on their website to denote a link to Car Find’s website. The two aspects of interest are the case for urgency and the finding of the court on trade mark use.

Car Trader has an aggregator site listing a range of different sites linked to the sale of motor cars and related services. They describe their services as “software products designed to assist car dealerships maximise efficiencies and profits through the leverage of market data and systems”. The court describes their services as follows:
“In summary, the website provides for direct access by dealers to multiple portals simultaneously, without having to access each such portal separately”.

non-enhancing use!
Car Find has two trade marks; CARFIND in class 38 covering telecommunication services including portals and CARFIND.CO.ZA in class 35 covering advertising services in particular. So the services are identical, satisfying this element of the S34(1)(a) infringement test.
 
Infringement  
The applicant relied only on S34(1)(a) of the Trade Marks Act which is relatively straightforward. You can review the provision here
 
Identical trade marks - no likelihood of confusion required
 
The judge held that the mere use of an identical trade mark of necessity causes confusion and hence it is not necessary to show a likelihood of confusion. Afro Leo has no problem with the statement as it stands. However, it needs to be appreciated that not all forms of use of another's identical trade mark is an infringement or actually causes confusion. For example, it is not necessarily an infringement to say "I am selling Coca-Cola, Sprite and Pepsi" if you are a corner café or for a blog to have a useful list of other blogs, denoted by name or if you run a comparison site. Indeed all cases are quite common. The reason why one is not likely to infringe in these circumstances is because the trade mark is not used in the sense contemplated by the infringement sections of the legislation (so called trade mark use requirement) and/or because it is a pure descriptive use to denote the goods or services of the other (S34(2)(b) defence).
 
Was the use identical?
 
It is not altogether clear from the decision whether the identical mark was being used because the registered trade marks take two different forms; one being the word mark CARFIND and the other CARFIND.CO.ZA. However, one cannot infringe both marks by using a single mark that is deemed to be identical because logically that is not possible. As a result, it seems that there is an error in reasoning on the infringement of one of the marks, most likely the CARFIND.CO.ZA mark. We know that because of the wide ambit of identical trade mark use infringement, the test for "identity" is interpreted strictly (LTJ Diffusion) and one would have expected the same to apply in this case.
 
Is this trade mark use?
 
On the question of “use” the court relied on the dictionary definition of "use" perhaps not realising that "use" is defined in the Act as "use in relation to the performance of services". Regardless though, there is a need to also establish whether that use affects one of the functions of the trade mark (Interflora) ie trade mark use. These functions include the origin function, the investment, quality or advertising function of that trade mark. In cases where there is bona fide descriptive use, there is not likely to be so-called "trade mark use" and vice versa. Harms touches on this relationship, and the need to show trade mark use in (Century City at para 18 and in Verimark at para 7). However, there is very little argument or reasoning on which functions of the trade mark were affected in the Car Find judgement.
The closest is the reasoning that "the direct access to portals [provided through the use of the trade mark in the link], including that of the applicant, in fact enhances the website and therefore the services offered by the respondents. It moreover, implies that some link in the course of the trade exists between the respondents and the applicant. The respondents deny any connection with the applicant or that the website implies as much. No factual foundation for the latter denial exists and I am satisfied that the objective dealer, upon accessing the website, may well infer a link between the respondents and the applicant."
Afro Leo's difficulty with this conclusion is that:

  •  the use of a link to enhance the site eg make it richer or more accessible and user friendly does not necessarily imply trade mark use affecting one of the functions of the trade mark. Consider a blog portal listing other blog portals by name or the comparator website, for example.  The link enhances the sites but does this imply a link between the portals. Could the link simply not imply that the blogger or comparator has gone to the trouble of linking to another blog or site? Could it not be that the CAR FIND link enhances the site simply because it makes it easier to recognise the services provided through that link?
  • the relevance of "enhancement" is perhaps more appropriate to whether there is an advantage to using the trade mark and whether this advantage is unfair. However, this is a factor under the dilution provisions and not S34(1)(a) infringement.
  • what is there to imply some sort of link between the websites? If the trade mark simply points to the site of that other party, why would it necessarily create a link between the aggregator and the services on that site, especially if competitor sites are also referenced. Is there not an also an argument that the dealer is a businessman, acutely aware of his market, and that he would not imply an economic link between the two without something more? It is, of course, not to say that an economic link could not be present but given the nature of the decision (a final interdict in a reported case likely to set a precedent for these increasing disruption businesses ie aggregator sites that are ultimately pro consumer), Afro Leo would have expected to see some guidance as to why the judge comes to that conclusion.
Urgency 
The court heard the matter despite the fact that Car Find had known of the alleged infringing use for three months before launching the application. The judge reasoned that:

“…the infringement of a trade mark is at stake, which by its nature implies some urgency, as ‘The life of a trade mark depends on the promptitude with which it is vindicated…’ (Kerr on Injunctions 363, quoted in Tullen Industries Ltd v A de Souza Costa (Pty) Ltd 1976 (4) SA 220 (W) 220B).”

The judge went on to say that as:
-          no prejudice was alleged,
-          the matter was relatively straightforward (factually)
-          it was succinctly set out in the papers with arguments fully ventilated
-          certainty was important on an issue relevant and important in the industry
the court was prepared to hear the matter on an urgent basis. 

This is great news for trade mark owners enforcing their rights. Typically courts are loathe to hear matters as urgent if there is a delay by the applicant, even of a few days. It seems that the case was presented in a simple way and the judge felt it necessary and expedient to deal with it immediately. Again, this approach is to be celebrated. However one does wonder if it may have been perhaps a little bold given some of the complexities in a case like this and the fact that it is a first of its type case in RSA.

It is understood that the case is going on appeal. The decision can be found here.

Original post updated with format changes and to include link to case.
 
 
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Wednesday 13 April 2016

Afro Leo

New TK Bill - South Africa

The Minister of Science and Technology intends introducing the Protection, Promotion, Development and Management of Indigenous Knowledge Systems Bill, 2015 into Parliament during the 2016 calendar year. The TK Bill aims to provide for:

  • the protection, promotion, development and management of Indigenous Knowledge Systems
  • the establishment and functions of the National Indigenous Knowledge Systems Office
  • the managements of rights of IK holders
  • the establishment and functions of an Advisory Panel
  • for access and conditions of access to knowledge of indigenous communities
  • for the registration, accreditation and certification of IK practitioners
  • the facilitation of IK based innovation
The Bill (see page 40 onwards) was open to public comment last year (see this post here). 

Readers will be aware that the Intellectual Property Laws Amendment Act (IPA) was signed in December 2013 and we are still waiting for regulations before it will come into force. This Act alters the existing IP legislation to protect IK. How this Act will sit alongside the Bill is not entirely clear. Indeed, readers may recall the significant controversy over the Act with many suggesting that a stand alone piece of legislation would be preferable. The question which Afro Leo has is will we ever have the regulations to the IPA (its been over two years) and are the critics satisfied with this Bill?

Afro-IP will be following the progression of this legislation with interest. One thing for sure is that if you are using any traditional knowledge in your business, including traditional or cultural expressions, you need to stay up to date because the legislation will affect your business.

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Tuesday 12 April 2016

Afro Leo

Reminder: Unisa's The Patent Declaration Research Seminar

Readers may recall that Prof Tana Pistorius is organising a workshop to be held in Pretoria on 14-15 April on The Patent Declaration - "The Patent Declaration was drafted by numerous academics worldwide under the leadership of Max Planck ... [which] mainly relates to TRIPS flexibilities... As part of this project workshops have been held in various countries to address the different themes. Panels are comprised of representatives from academia, government, the bench, practitioners and industry" 

There are still a few seats available for a red hot line-up including

  • Professors Hilty and Lamping from the Max Planck Institute, 
  • Profs  Coenraad Visser, Klaus Beiter, Esme Du Plessis, Andries van der Merwe, Eddie Hurter, Steve Cornelius and Frantzeska Papadopoulou from around the country (and globe), 
  • Attorneys Jaco Theunissen, Alexis Apostolidis, At Van Rooy, Danie Dohmen, and Ralph Van Neikerk,
  • Industry representatives Morne Barradas, Andre Kudlinksi, Catherine Tomlinson, Madelein Kleyn, Tumelo Tshaya and Thokozani Simelane,
  • Government representatives Macdonald Netshitenzhe, Jetane Waters and Amanda Lotheringham,
  • Judges Louis Harms and Mabel Jansen  
The person to contact is Nomagugu Hlongwane at this address here.
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Wednesday 6 April 2016

Afro Leo

MIP and A&A team up for Africa Roadshow in New York


Afro-IP has just been notified of an Africa Roadshow co-sponsored by Adams & Adams and Managing Intellectual Property happening in New York today. You can read more about it here including how you can participate online.

Just a reminder if people want to inform this blog of African IP events, please send an email here with information, which we will edit and publish as appropriate.


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Monday 4 April 2016

Afro Leo

Upcoming events: a book launch and UJ seminar

Afro Leo is delighted to announce that blogger Prof Caroline Ncube is launching her new book on IP, and it involves Africa. The venue is UCT Faculty of Law, Kramer Building, Faculty Common Room 4th Floor on 14 April at 5pm-6pm and the invitation is open to YOU! RSVP to Abigail.Calata@uct.ac.za.



Don't forget the UJ seminar tomorrow Perspectives on Intellectual Property. Over 100 have already signed up but there are still a few places apparently.

Date: 5 April 2016
Time: 08:00 – 15:30
Venue: University of Johannesburg, Council Chambers, Madibeng Building, Auckland Park Campus
To register, please contact Mrs Morgan Buntting
Download full event


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Afro Leo

South Africa's appeal court adjudicates a whisky war

The Supreme Court of Appeal in South Africa recently handed down the appeal judgement in the Distell case, a decision of the Kwazulu Natal High Court. Appeal Judge Lewis wrote the judgement and four other SCA judges concurred.

Briefly, Distell Limited produces and sells cheap whisky under the brand KNIGHTS (website here). The most relevant trade mark that they own is trade mark registration number 91/3863 KNIGHTS (it is unfortunately not clear from the judgement but this is actually a device mark where KNIGHTS appears on a plain black label together with the crest and five circle device) registered from 30 October 1990 covering alcoholic beverages. It was also common cause that Distell had a reputation in the mark.

KZN Wine & Spirits CC import BLACK KNIGHT whisky and sell it in the midlands of Kwa-Zulu Natal. It is also relatively cheap.

Distell make a claim for trade mark infringement S34(1)(a) and passing off and lose in the high court, and are refused leave to appeal. The SCA then grants them leave to appeal.

The labels as they appear in the marketplace, according to the judgment, are as follows:

                           
Citing relevant local (including Plascon Evans and Cowbell) and international case law (Sabel v Puma) the court analysed the various tests to be applied for trade mark infringement. Distell argued that the lower court had erred by placing emphasis on a consumer that was discerning and, as a result, that there was no likelihood of confusion. Both whiskys are relatively cheap and not necessarily purchased by connoisseurs.

The SCA dismissed the appeal deciding that:

"In my view, one cannot ignore the use of the word black to describe KZN Wines’ whisky. Knight is used as a noun, and the adjective describing the knight is black. Whether the colour black is used to describe a mythical figure (as in the Black Knight of King Arthur’s round table) or to express some quality which many whisky brands use (the example given being Black Label, describing a whisky in the Johnny Walker range, but others abound)  does not matter. It simply cannot be ignored. Although Distell tried to argue that knight is the dominant word even in Knight’s Gold, it is hard to see why. Just as black cannot be ignored, nor can gold. As the high court said, the word black was as significant as knight in KZN Wines’ mark."

The Judge makes the bold move that the marks are not even similar:

"The sound, sense and appearance of the respective marks are different. Even the consumer with an imperfect recollection, and in a noisy pub or crowded bottle store, is not likely to be confused as to the origin of BLACK KNIGHT whisky."

Comment:

If the court cites Sabel v Puma it means that it ascribes to that test for comparison on marks. The court then has simply not applied the infringement test correctly. The test for "similarity of marks" under the Sabel v Puma test (as applied) has very little to do with a man in a noisy pub; it simply involves a consideration as to whether there is any level of similarity (as opposed to "likelihood of confusion" - which comes later in the test) between the marks. The question is whether there is any similarity between the marks (as registered by Distell and used by KZN Wines) visually, conceptually and/or orally.

If there is any level of similarity (both marks contain the word KNIGHT, for example), the judge should then because the goods concerned were identical, consider the reputation in the mark KNIGHTS (label) as marks with a reputation have a greater degree of protection. He then should have considered the likelihood of confusion taking into account all relevant factors, including that he had decided that the mark "black" was common and descriptive, the man in the noisy pub, the relevant consumer, the degree of similarity in the marks etc. Had he approached the test in this way, it is difficult to believe that he would have reached the same conclusion.

Having decided that there is no infringement, passing off was hardly entertained. The logic of this seems reasonable in the circumstances but the test for infringement, as explained above, does not appear to have been correctly applied.

edited to reference the mark KNIGHTS as registered.



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