IP Litigation in Europe. UPC and CTM/CD: A Comparison

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1 UNION-IP Congress Berlin, June 4 to 8, 2014 IP Litigation in Europe UPC and CTM/CD: A Comparison Professor Dr. Alexander von Mühlendahl, J.D., LL.M. Rechtsanwalt/Attorney-at-Law Visiting Professor, Queen Mary, University of London Vice-President, Office for Harmonization in the Internal Market (Trade Marks and Designs),

2 Overview Introduction Competent courts Applicable law Subject matter jurisdiction exclusive competences Relation between declaratory action for non-infringement and infringement claim International jurisdiction where to bring the action Scope of competence of the court EU-wide or limited Defenses Sanctions applicable law Related actions multiple infringement actions, infringement and validity Preliminary actions Torpedos Bardehle Pagenberg

3 Introduction Bardehle Pagenberg

4 Competent courts UPC UPC UPC is special court established by international agreement Competence is exclusive for specifically enumerated cases National courts remain competent for other cases CTM/CD Community trade mark courts, Article 95 CTMR Community design courts, Article 80 CDR CTM and CD courts are national courts with special competence conferred by EU legislation Competence is exclusive for specifically conferred cases National courts remain competent for other cases relating to CTMs and CDs Bardehle Pagenberg

5 Applicable law UPC Article 24 Union law, incl. Reg 1257/2012, and 1260/2012 UPCA EPC Other international agreements, e.g. Paris Convention, TRIPS Agreement National law, to be determined under Union internationai private law CTM/CD CTMR Title 10/CDR Title IX CTMR/CDR Brussels-I-Regulation with derogations Article 31 Brussels-I-Regulation (recast) (Reg. 1215/2012), as amended by Reg. 542/2014 (14 May 2014) LuganoConvention II (2007) Bardehle Pagenberg

6 Subject-matter jurisdiction (1) Bardehle Pagenberg UPC Exclusive competence, Article 32 (1) Actions for actual or threatened infringement, incl. counterclaims concerning licenses (a) Declaratory actions for non-infringement (b) Actions for provisional and protective relief (c) Actions for revocation (d) Counterclaims for revocation (e) Actions for compensation under provisional protection (f) Actions relating to prior use (g) Actions for compensation for licenses of right (Article 8 Reg. 1247/2012) (h) Actions against decisions of EPO taken pursuant to Article 8 Reg. 1257/2012 (i) CTM/CD Article 96 CTMR/Article 81 CDR Actions for infringement Actions for threatened infringement, if available under national law Declaratory actions for noninfringement, if available under national law Counterclaims for declaration of invalidity CTM: Actions for reasonable compensation CD: Actions for declaration of invalidity of unregistered CD 6

7 Subject-matter jurisdiction (2) UPC CTM/CD Article 32 (2) National courts remain competent for actions not expressly listed Examples: Ownership disputes, licensing, Article 106 CTMR/Article 93 CDR National courts remain competent for other actions concerning CTMs/CDs Examples: Ownership disputes, licensing, Bardehle Pagenberg

8 Relation between DNI and infringement Article 33 (6) UPC CTM/CD No express provision DNI action pending before central division must be stayed when infringement action is brought before local dividion within three months of the date when DNI action was initiated ECJ case law: DNI precludes later infringement action (lis pendens) Bardehle Pagenberg

9 International jurisdiction (1) Article 31 UPC CTM/CD Article 96 CTMR/Article 82 CDR Brussels-I-Regulation (recast) (Reg. 1215/2012), as amended by Reg. 542/2014 (14 May 2014) Lugano Convention II Is or would a court of a MS party to UPCA be competent to hear the case, as an isssue of subject matter jurisdiction and international jurisdiction? If yes, Article 33 applies if the case falls within Article 32 (exclusive competentence): UPC is competent Bardehle Pagenberg Instead of Brussels-I-Regulation: Cascade EU-wide jurisdiction MS where defendant has residence MS where defendant has an establishment MS where claimant has residence MS where claimant has an establishment MS where OHIM has ist seat (Spain) Prorogation and acceptance MS-wide jurisdiction MS where acts of infringement have been committed or are threatened, except DNI not allowed 9

10 International jurisdiction (2) Article 31 UPC CTM/CD Article 96 CTMR/Article 82 CDR If not, UPC not competent Examples Infringement of EP in Spain Revocation of EP in Spain However, UPC competent for revocation of EP held by Spanish entity (Article 24 No. 4 Brussels-I-Regulation) UPC competent for infringement of UPC/EP by non contracting state national (Article 7 No. 2 Brussels-I- Regulation) Competence over third-country defendants now provided by Reg. 542/2014 Bardehle Pagenberg Instead of Brussels-I-Regulation: Cascade EU-wide jurisdiction MS where defendant has residence MS where defendant has an establishment MS where claimant has residence MS where claimant has an establishment MS where OHIM has ist seat (Spain) Prorogation and acceptance MS-wide jurisdiction MS where acts of infringement have been committed or are threatened, except DNI not allowed 10

11 International jurisdiction (3) Article 33 a, c, f, g, i UPC Local/regional division where actual or threatened infringement has occurred or may occur, or Where defendant or one of them has residence or principal place of business, or in the absence of res. or ppb, place of business CTM/CD Article 96 CTMR/Article 82 CDR Instead of Brussels-I-Regulation: Cascade EU-wide jurisdiction MS where defendant has domicile MS where defendant has an establishment MS where claimant has domicile MS where claimant has an establishment MS where OHIM has ist seat (Spain) Prorogation and acceptance Bardehle Pagenberg MS-wide jurisdiction MS where acts of infringement have been committed or are threatened, except DNI not allowed 11

12 International jurisdiction (4) Article 33 a, c, f, g, i Bardehle Pagenberg UPC Actions against foreign defendants: place of infringement, or central division Counterclaim for revocation against infringement action; local division may refer invalidity counterclaim to central division; infringment case may be stayed DNI and revocation actions only before central division, unless infringement action is first CTM/CD Article 96 CTMR/Article 82 CDR Instead of Brussels-I-Regulation: Cascade EU-wide jurisdiction MS where defendant has domicile MS where defendant has an establishment MS where claimant has domicile MS where claimant has an establishment MS where OHIM has ist seat (Spain) Prorogation and acceptance MS-wide jurisdiction MS where acts of infringement have been committed or are threatened, except DNI not allowed 12

13 International jurisdiction (5) Domicile is defined in Article 63 Brussels-I-Regulation, for legal entity, as either statutory seat, or central administration, or principal place of business Bardehle Pagenberg UPC Article 33 connecting factors Deviation from language and rules of Brussles-I-Regulation difficult to understand Domicile vs. Residence or principal place of business Place of business vs. Establishment CTM/CD Article 96 CTMR/Article 82 CDR Instead of Brussels-I-Regulation: Cascade EU-wide jurisdiction MS where defendant has domicile MS where defendant has an establishment MS where claimant has domicile MS where claimant has an establishment MS where OHIM has ist seat (Spain) Prorogation and acceptance MS-wide jurisdiction MS where acts of infringement have been committed or are threatened, except DNI not allowed 13

14 Multiple defendants Article 33 (1)(b) UPC CTM/CD Joinder of defendants: An action may be brought against multiple defendants only where the defendants have a commercial relationship and where the action relates to the same alleged infringement Is there a potential for conflict between Article 33 (1)(b) and Article 8 No. 1 Brussels-I-Regulation? A person domiciled in a Member State may also be sued: (1) where he is one of a number of defendants, in the courts for the place where any one of them is domiciled, provided the claims are so closely connected that it is expedient to hear and determine them together to avoid the risk of irreconcilable judgments resulting from separate proceedings; Application to non-eu defendants? Bardehle Pagenberg

15 Scope of competence Article 34 UPC CTM/CD Article 98 CTMR/Article 83 CDR Competence is UPC-wide for UPs Competence is UPC-wide for EPs EU-wide competence MS where domicile or establishment is basis for jurisdiction MS-wide competence MS where jurisdiction is based on infringemens that have been committed or are threatened Bardehle Pagenberg

16 Defenses UPC Non-infringement, including prior use, exhaustion, Invalidity only by way of counterclaim, counterclaim must be brought before infringement court Other defenses: Statute of limitations, Article 72 (5 years) Laches? Acquiescence? CTM/CD Article 99 CTMR/Article 85 CDR Non-infringement, including fair use, exhaustion, Earlier rights of defendant CTM: Non-use Attack on validity of allegedly infringed right only by way of counterclaim or direct action before OHIM Unregistered CD: plea or counterclaim Other defenses: Laches and acquiescence Prescription (statute of limitations) Bardehle Pagenberg Other: abuse of right, abuse of process, breach of contract 16

17 Procedure applicable law UPC UPC law, Rules No reference to national law Legitimacy of the Rules? CTM/CD Article 101 CTMR/Article 88 (3) Lex fori, incl. international private law Problem: qualification of procedure vs. substance Bardehle Pagenberg

18 Sanctions applicable law UPC UPC No reference to national law Injunction (Article 63), qualified by may Provisions are Enforcement Directivebased CTM/CD Article 102 (1) CTMR Injunctive relief Article 89 (1)(a), (b), (c) CDR Injunctive relief (a) Seizure (b) Seizure of implements (c) Article 102 (2)/Article 89 CDR (1)(d) CDR Other relief (damages, accounting, information): Lex delicti commissi, including private international law Mosaic approach? Unitary approach? Bardehle Pagenberg

19 Related actions infringement, validity Article 33 (2) UPC CTM/CD Multiple infringement actions Further action before another division not allowed Later co-pending action between the same parties on the same patent inadmissible Revocation only by way of counterclaim in pending infringement action No provision in CTMR/CDR Articles 29, 30, 31 Brussels-I- Regulation apply Co-pending infringement/revocation counterclaim and direct action in Alicante In principle, first action continues, second action must be stayed, unless special reasons for continuing second action Article 102 CTMR/Article 91 CDR Bardehle Pagenberg

20 Preliminary actions UPC Exclusive competence of UPC CTM/CD Article 103 CTMR/Article 90 CDR CTM and CD courts, and any national court Scope of jurisdiction for non-ctm/cd court limited Bardehle Pagenberg

21 Torpedos UPC DNI can be superseded by infringement action Article 32 (5) Earlier revocation action before central division does not prevent subsequent infringement action; infringement court not competent for revocation CTM/CD Bringing direct action in Alicante when threatened with infringement action Bringing DNI in CTM/CD court inconvenient for proprietor; competence of DNI court is determined under general rules, not mirror-image approach Bardehle Pagenberg

22 Conclusions Strength of CTM/CD system National courts, EU-wide competence, combination with other actions and rights (national marks, unfair competition) Opportunities for forum shopping Weaknesses Easy to outmaneuver ( torpedo ) Absence of unitary/uniform law on sanctions No unitary appeal system; reference to ECJ is time-consuming and uncertain Strength/weaknesses of UPC system Forum shopping? Bardehle Pagenberg

23 Max Planck Institute for Intellectual Property and Competition Law IP Litigation in Europe Strategic Choices Crossborder Enforcement of unitary rights Annette Kur UNION congress Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

24 Introductory remarks The unitary protection systems for trademarks and designs have created favourable conditions for cross-border enforcement in case of multi-state infringement. However (contrary to the unified system to be established for patents) CTM/CD courts remain within the national court hierarchy; there is no access to a common appeal court. Relationship between CTMR/CDR and the Brussels + Rome Regulations may raise issues. In particular, sanctions are only regulated in a rudimentary fashion; it is unclear to what extent a mosaic approach must be applied to ancillary sanctions (= damages, information claims, corrective measures, publication of judgments) Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

25 Overview Jurisdiction CTMR/CD Brussels Regulation Multiple defendants Applicable law CTMR/CD Rome II-Reg. The mosaic approach is it justified? how would it work in practice? Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

26 Jurisdiction, I CTMR/CD Central competence of CTM/CD courts (Art. 97 (1)-(4), 98 (1) CTMR; Art. 82 (1) (4), 83 (1) CDR) = EU-wide jurisdiction Alternative competence resulting in territorially limited jurisdiction (Art. 97(5), 98(2) CTMR; Art. 82(5), 83(2) CDR). (Potential) differences vis-à-vis Art. 5(3) BR I (Art. 7(2) BR I bis): no jurisdiction for claims for declaration of non-infringement (contrary to CJEU C-133/11 Folien Fischer); no jurisdiction at the place of damage (contrary to e.g. CJEU C-170/12 Pinckney)?? See GA Jääskinen, Case C-360/12 Coty to be decided ! Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

27 Jurisdiction, II multiple defendants As CTMR and CD do not regulate multiple defendant-claims, Art. 6(1) BR I (Art. bis) applies by default. 8(1) BR I Issues: If ancillary sanctions are claimed, does this mean that the claims do not concern the same legal situation? (see CJEU C-539/03, Roche Nederland; but also Cases C-145/10 Painer, and C-616/10, Solvay) Is the Court s competence to impose sanctions limited in any manner, in particular to the territories where the resident defendant has acted? Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

28 Applicable law, I (CTMR/CDR) The law to be applied by CTM and CD courts is the law enshrined in the relevant Community instruments (Art. 101 (1) CTMR; Art. 88 (1) CDR); on all other (substantive) issues, it is the law of the forum including its private international law (Art. 101 (2) CTMR; Art. 88 (3) CDR); on all procedual matters, it is the lex fori (Art. 101 (3) CTMR; Art. 88 (3) CDR). Regarding sanctions that are not regulated in the relevant Community instruments, the CTM/CD courts apply the law of the Member State where the act of infringement was committed, including its private international law (Art. 102 (2) CTMR; Art. 89 (1)(d) CDR). Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

29 Applicable law, II (Rome II) Pursuant to Art. 8 (2) Rome II Regulation (Reg. (EC) No. 864/2007), the law applicable to infringements of a unitary right, for any question that is not governed by the relevant Community instrument, shall be the law of the country in which the act of infringement was committed. As the Rome II-Regulation has replaced, within its scope of application, the international private law of the Member States, the reference to Member States PIL in Art. 101 and 102 CTMR/Art. 88 and 89 CDR must be understood as referring to Art. 8 (2) Rome II. The crucial question regarding ancillary sanctions for infringement of CTMs/CDs is therefore: Which law is designated by Art. 8 (2) Rome II as the law of the country where the act of infringement was committed? Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

30 Applicable law, III Gautzsch/Duna (Case C-479/12) The question whether ancillary sanctions in case of cross-border infringement of a CD are subject to the law of the Member States in which the acts of infringement are committed was referred to the CJEU in Case C-479/12 Gautzsch/Duna. The CJEU did not answer the question but held that claims for damages and information are not other sanctions in the meaning of Art. 89 (1) (d) CDR but fall under Art. 88 (2) CDR. As a result, such sanctions are subject to the law of the forum state, including its private international law. Art. 8 (2) Rome II was not addressed at all. Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

31 Applicable law, IV The currently prevailing opinion holds that Art. 8 (2) Rome II compels applying a mosaic approach to ancillary sanctions. However, that approach appears flawed: Once the infringement has been committed in all its elements in the Member State where the causal act occurs, the full range of sanctions is triggered by that event. If subsequent damage occurs through distribution in other Member States, that is only of relevance for the dimension of the sanctions to be imposed (amount to be paid, information to be disclosed etc.); it does not concern their substance. It is basically wrong to fall back on a territorially fragmented assessment of sanctions where the infringement concerns a unitary right. Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

32 Applicable law, V Even if a mosaic approach is applied, it must be observed that issues such as evidence required for the calculation of damages, leeway for courts to estimate damages, eventually also claims for information and procurement of evidence, are subject to the lex fori, if they are deemed under national law as being of a procedural nature; courts in some legal systems (like in the UK) remain (arguably) free to presume that the law in other Member States is the same as their own. Furthermore, considering that Member States are obliged anyhow to bring their legislation in accordance with the Enforcement Directive (48/2004; IPRED), it would be unneccessary and unfeasible in practice to require detailed evidence of the law applying in 28 Member States where the ancillary sanctions claimed remain within the mandatory framework set out in IPRED. Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

33 And at last A better solution, at least in the longer run, would be to include a full catalogue of unitary sanctions into the CTMR and CDR Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

34 Thank you for your attention! Max Planck Institute for Intellectual Property and Competition Law Annette Kur /

35 Enforcement of IP rights in the EU in practice: Patents - pre UPC and post UPC observations Richard Willoughby UNION IP Congress 5 June 2014

36 Patent litigation strategies in an EU context Multi-country enforcement in the current regime Defensive strategies and risks Stays What might we see in the UPC? #

37 Multi-forum, national system or is it? Offensive strategies Place of manufacture Key markets (DE, UK, FR) Place of EU entry (NL, BE) Solvay-type enforcement Interim relief All defendants acting in multiple countries #

38 Defensive strategies Declaratory relief (torpedoes) The General Hospital Corporation v Asclapion Laser Technologies GmbH (Corte di Cassazione 2013) Agilent v Oerlikon (Genoa District Court 2014) Actavis v Eli Lilly (High Court, London 2013/14) Risks Preliminary injunctions Further jurisdiction for infringement claims Actavis v Eli Lilly (Germany) #

39 Other defensive strategies Validity challenge Opposition is EU/EPC wide Intervention Revocation actions in selected countries can be very effective UK, NL, DE Tactical use of existing procedures can lead to pan-european outcome #

40 Stays Primarily to avoid: Duplication Injustice Approaches to stays vary: two illustrations Germany Duplication avoidance Opposition precludes revocation action But note approach to Articles 27 and 28 Regulation 44/2001 Injustice avoidance Stay difficult to achieve in infringement action #

41 UK Duplication avoidance Stay pending opposition relatively unlikely Speed of reaching commercial certainty a major factor Injustice avoidance Virgin Atlantic v Zodiac Seats: overturned res judicata issue IPCom v HTC: new guidance on stays Effect of central limitation proceedings Samsung v Apple (2014): stay of appeal Starsight/Rovi v Virgin Media (2014): adjournment of trial #

42 Single forum, pan-european system or is it? EP Opt-outs for 7-14 years (plus life of patent etc.) Potentially complex situation for related actions Same parties, same patent Article 33 (2) : must bring in same division Article 33(6): can t have a declaration of non-infringement and infringement action Based on past experience, can we see any potential issues with Articles 33(2) and 33(6)? #

43 Samsung v Apple: Not the ipad design case (Designs Regulation) 9 August 2011 Ex-parte injunction in Germany vs Samsung DE and SEC 9 August 2011 Numerous Samsung entities seek invalidity at OHIM 11 September 2011 Samsung UK seeks DNI in UK Apple counterclaims for infringement 25 November 2011 Substantive action brought in DE 9 July 2012 Finding of non-infringement in UK by Samsung UK 24 July 2012 Oberlandesgericht upholds pan-eu interim injunction vs SEC Result: inconsistent decisions #

44 Actavis v Lilly: Recent patent case (Articles 27 & 28 Regulation 44/2001) 20 July 2012 Lilly sues two Actavis entities in Germany (but proceedings not served) 27 July 2012 Different Actavis entity seeks UK declaration of non-infringement 9 August 2012 German proceedings served (after UK service) December 2012 Dusseldorf Regional Court denies Actavis application contesting jurisdiction (upheld on appeal) UK first seized of an action involving same subject matter BUT no exact overlap of parties with identical claims Result: split jurisdiction and inconsistent decisions #

45 Are these different parties for jurisdiction? Oberlandesgericht (DE) says yes in Apple v Samsung Granted injunction even after substantive result in UK Approach in Actavis v Lilly is consistent Strict view of same parties? Court of Appeal (UK) says no commercially unrealistic approach (Jacob LJ) But is it? P&G v Reckitt Benckiser: parent company was not the controlling entity claim struck out #

46 Might things be different in the UPC in practice? Reaction to declaratory claim Why bother suing a different party (Article 33(6))? Different parties, same patent Article 33(1) : multiple defendants in same division Important: joinder of actions on same patent with different parties (Rules and 340) What about same infringement and/or same parties but different patents? No general joinder power #

47 Defensive strategy considerations Loss of venue and bifurcation Declaratory proceedings: Article 33(6) again Use a different party? Rule 340 plus Article 33(1) and 33(6) (again) Validity proceedings Infringement and validity could be separated Revocation action and infringement claim: Rule 70 and Article 33(5) #

48 Stays Duplication risk Article 33(6) Stay pending opposition (and limitation) but only where decision imminent Article 33(10) and Rule 295 Rule 70 Rule 340 Injustice risk Article 33(3) and Rule 37: stay at time of bifurcation Rule 118 May/shall stay infringement pending Central Division revocation or imminent EPO opposition decision (Rule 118.3(b)) May set security for enforcement (Rule 118.9) #

49 Scope for EU enforcement in existing regime Current EU jurisdictional rules not free from issues UPC jurisdictional rules subtly different Scope for jurisdictional tactics in the UPC #

50 Thank you Richard Willoughby #

51 Does the unitary character of CTMs / RCDs imply a uniform protection? Arnaud Folliard-Monguiral, ICLAD, OHMI, 6 June 2014, UNION-IP Congress, Berlin

52 Introduction A CTM / RCD shall have equal effect throughout the Community: it shall not be registered, transferred or surrendered ( ), nor shall its use be prohibited, save in respect of the whole Community. Exceptions: Art. 110, 111 & 165(5) CTMR Uniform protection : C-235/09, DHL Express France, para Art. 4(3) TM Dir. & Art. 9(2) CTMR: enlarged protection for CTMs with reputation Pending reference for a Preliminary Ruling C-125/14, Iron & Smith Kft / Unilever NV (BE IMPULSIVE)

53 Territorial effect of reputation Is it sufficient for a CTM to have acquired reputation in a Member State if the later contested mark is applied for in another Member State? C-301/07 Pago, para. 30: the territory of a Member State such as Austria can constitute a substantial part of the EU The territorial coverage of the enlarged protection encompasses geographic areas other than the one or those in which reputation was acquired

54 Proof of reputation in the Member State in which the later mark is filed Is the qualification of reputation of a CTM conditional upon proof that the knowledge threshold requirement is satisfied in the Member State where the exclusive rights are enforced? Once reputation has been substantiated in a substantial part of the European Union, the CTM enjoys a uniform protection across the European Union If proof of reputation was required in each and every Member State, Pago would be deprived of any effet utile

55 Territorial effect of reputation and of genuine use Are the principles applying to genuine use applicable to reputation? C-149/11, Leno Merken (OMEL), para. 44: territorial borders are irrelevant A CTM may be known by a significant part of the European public in an area which encompasses parts of different Member States. Should regard be had to the specificities of the market in which reputation was proven?

56 Territorial effect of reputation and proof of dilution / parasitism What is the effect of the lack of reputation in the Member State in which the exclusive rights are enforced? (A) A CTM reputed in a substantial part of the European Union is given equal protection throughout the European Union A disproportionate advantage vis-à-vis national marks? Quid the existence of a link in respect of the public targeted by the later mark? Due cause: C-65/12 Leidseplein Beheer BV et al. / Red Bull GmbH et al, para. 60 (B) The conditions for protection of a reputed CTM must be substantiated in each and every Member State in which the exclusive rights are enforced A non-hypothetical risk of parasitism or dilution may still be established Knowledge of the CTM s reputation in other Member States may serve to substantiate the applicant s willingness to take advantage of this reputation

57 Procedural issues: time-barring rules CTMs: acquiescence + prescription RCDs and Unregistered CDs: defences of the extinction of rights over time and of an action being time barred are governed by national law, in compliance with the principles of equivalence and effectiveness (C-479/12 Grosshandel, para. 49) Specificity of Unregistered CDs Which national law to apply in cross-border disputes? Has prescription an effect on the admissibility of the action or on that of the claims?

58 Procedural issues: proof of entitlement to UCD Art. 17 CDR: presumption of entitlement to the holder of a registered Community design Art. 27 CDR: the entitlement to the right on the UCD (and the capacity to start legal actions) entirely depends on the national law of the Member State in which the holder has his seat, domicile or establishment Legal persons will be required to prove that the design was developed by an employee in the execution of his duties or following the instructions given by his employer (Article 14 CDR) or that they have acquired rights

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