Miscellaneous musings (on recent IP news)

Madrid Protocol

I'll start my musings on Madrid (the Madrid Protocol) where Hong Kong is beginning steps to become available for International trademarks, although this is not likely until 2019 at the earliest.

Under Article 3bis of the Madrid Protocol, "The protection resulting from the international registration shall extend to any Contracting Party only at the request of the person who files the international application or who is the holder of the international registration. However, no such request can be made with respect to the Contracting Party whose Office is the Office of origin."

This is interpreted so that Hong Kong applicants will not be able to designate (mainland) China and vice-versa. As many will know, Hong Kong is not a sovereign state and is a Special Administrative Region of China. As such, any Madrid membership will be made by China on its behalf.

Notwithstanding this, the Netherlands has membership of the Madrid Protocol and has extended this to Bonaire, Sint Eustatius and Saba (sometimes referred to as the BES Islands or the Caribbean Netherlands). Bonaire, Sint Eustatius and Saba are special municipalities of the Netherlands. There are 817 live International Registrations which designate Bonaire, Sint Eustatius and Saba and where Benelux is the Office of origin (that's not to say all applicants are from the Netherlands, some are from Belgium or Luxembourg).

From the above, it seems a Contracting Party can have different Office of origins and is not necessarily caught by an Article 3bis restriction.

Anyway, it seems Hong Kong and (mainland) China will look to come to another arrangement outside of the Madrid Protocol.

Eurasian Trademark

Another IP system we may need to become aware of is through the Eurasian Trademark system. This may be with us in 2018. It will cover Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia.

It seems it will be a mix between how the International and EU trademark systems work. There will be no need for a base application/registration, but applications can be filed with anyone of the five national IP Offices. Although it will be a unitary right across all countries, it will be examined by each national IP Office separately. In the event of refusal, this can be argued nationally. A final refusal in any country will result in refusal of the Eurasian trademark, but conversion/transformation into national applications in the non-refused countries appears to be possible.

It's not clear if this system will look to link to the International trademark system. I'm not sure I can envisage it being used much by Western trademark owners when all member countries are members of the Madrid Protocol anyway (Russia and Kazakhstan being particularly cheap under Madrid). However, it may be useful for local portfolios (think, in particular, marks in Cyrillic script) as there is no requirement to get an unnecessary base registration (with the 'Central Attack' fears that can pose). Any attractiveness to Western trademark owners may come down to costs.

Hague

Remaining in the Eurasian region and Russia will be joining the Hague System for Designs. They will join other regional countries as members: Armenia, Azerbaijan, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan and Ukraine. Accession is anticipated for later this year and will be for the Geneva Act only.

The UK is also likely to accede to the Geneva Act of the Hague System in early 2018. This will be welcomed, particularly if UK applicants shall no longer have easy direct access to the Registered Community Design system when 'Brexit' happens.

Representation at the EUIPO

Whether UK practitioners will still be able to work directly with the EUIPO is something that is very much on the radar of British IP professionals that undertake a lot of EU work. There has been talk of Brits opting into "EU citizenship" and this may present an opportunity, although a) anyone remaining in the UK would still not be resident in the EU/EEA and b) this is an idea that might not get any further than being just an idea. Nonetheless, it could be an interesting angle that may not currently be being looked at for British professionals looking to retain representation rights.

Series marks 

Remaining in the UK and the UKIPO has recently issued guidance on series marks. Although not exclusively available in the UK, they are a bit of an alien concept to some trademark professionals in other countries. A Series of trademarks is a number of marks with very small differences. Any differences between the marks must not substantially change how they look, sound or alter their meanings. As a common example, a black and white version of a trademark and a colour version of a trademark can often be included in the same application (and at no extra cost).

The IPO's guidance reflects a strict approach for marks to form a series.

Enjoy your weekends readers!

Hague movements, Brunei joins

After a quiet 2013 in the international world of designs comes some news from WIPO of the accession of Brunei to the Hague System for the International Registration of Industrial Designs.

It will be possible to designate Brunei in a Hague application from 24 December 2013.

As a word of caution, Brunei is a common law jurisdiction and should therefore reflect its membership of international treaties by making reference to them in their local laws. I cannot see that this has been done, although I may not have access to the latest legislation. In the absence of legislative amendments there could be some doubt regarding the enforceability of International design registrations in Brunei.

Although a wealthy country, Brunei is not quite the major Asian economy to join the Hague System with there being talk of China, Japan and the Republic of Korea all acceding. The United States is scheduled to join up in the near future and this may prove to be the catalyst for a more rapid expansion to new jurisdictions.

For now though, welcome aboard to Brunei.

New on-line filing tool for Hague Design applications

WIPO have announced the introduction for a new on-line filing system for Hague International Design applications.

It will now be possible to upload multiple design representations at the same time, which may speed up the preparation of applications. A fee calculator will be built into the tool to help with the accurate calculation of fees due (which can be complicated under Hague). Furthermore, it will be possible to pay for applications using a credit card. This will be very useful for filers that do not hold a deposit account with WIPO; previously if you wanted to make payment by credit card then you needed to wait for a WIPO irregularity notice and then make payment through their E-Payment tool.

WIPO have prepared some step-by-step tutorials for the filing of Hague applications including the creation of a user account that is necessary.

With the accession of the United States and the powerhouse economies of the Far East to Hague expected in the not-too-distant future, WIPO are preparing themselves well to be more efficient ready for an increase in the number of filings.

Comoros joins OAPI

News from Africa sees the island nation of the Comoros ratify the Bangui Accord to become the 17th member state of OAPI.

I understand the hard copies of the Comoros' accession documents are yet to reach OAPI. It is believed these will arrive soon but there is a little uncertainty pending their arrival.

The Union of the Comoros is due to become a member on 25 May 2013. From this date, applications filed in OAPI will cover the Comoros. Furthermore, renewals filed after this date will then extend the relevant registrations to cover the Comoros.

In the meantime, if renewals are some time away and you wish to protect your trade mark rights in this country, it is possible to file Extension Applications to cover the Comoros. (This is very much different from the CTM system where new members (such as Croatia) will be automatically covered upon their joining.)

Prior to its accession to OAPI, the Comoros was one of the Cautionary Notice countries of the world. If you have published a Cautionary Notice in the islands then you should now look to register these rights at OAPI either by making an application or, if existing OAPI rights already exist, by making Extension Applications (although if these rights are close to renewal you may be able to save some money by just waiting until renewal can be filed).

I have previously speculated that the Comoros may join OAPI because as a small, francophone country it would represent a quick-win to join this organisation. However, it is located between Mozambique and Madagascar in the south west of Africa and will form a geographic outpost of OAPI - they will need to enlarge the map appearing on their homepage. Saying this, Madagascar was a member of a precursor to OAPI, OAMPI.

The Comoros represents the 17th member of the OHADA - Treaty on the Harmonisation of Business Law in Africa to mirror this with membership of OAPI. The Democratic Republic of Congo (for those of you of a certain age, this might still be Zaire to you) is also due to adhere to OHADA. This country already has its own trade mark legislation and has less need to join up to OAPI too (although this did not prevent Mali and Guinea becoming OAPI members in the 1980s and 1990s respectively).

As one of the world's poorest countries, the Comoran government will be hoping that its accession to OAPI will encourage investment to the islands.

Incidentally, the Comoros disputes the status of Mayotte, part of the Comoros islands archipelago but administered by France (at the wishes of its local population it may be said). Mayotte is covered by French registrations (including International Registrations designating France) and, from 1 January 2014, when it will become an Outermost region of the European Union, Community Trade Marks too.

Caribbean IP Part 10: Cuba

ISO 3166 country code: CU.

The Republic of Cuba is the largest and most populous of all the island nations of the Caribbean. It comprises nearly the whole of the island of Cuba except the Guantanamo Bay Naval Base which is perpetually leased to the United States despite the lack of diplomatic recognition bestowed to Cuba by the US Government.

A single-party communist state that can find itself somewhat isolated, it could be considered surprising that Cuba involves itself in international IP circles being a member of a number of treaties including the Berne Convention, Madrid Agreement and Protocol, Nairobi Treaty, Paris Convention, Patent Cooperation Treaty, and the Lisbon, Locarno and Nice Agreements.

The Cuban Industrial Property Office administers registered IP rights in the country. Their website is only available in Spanish. However, Cuba was one of the first members of the Madrid Protocol in 1996, some time before Spanish was added as an official language in April 2004.

Unfortunately, my Spanish is limited but it is clear the site contains information on the three main IP rights (patents, designs, trade marks). Typical for a communist nation, representatives must be registered with the Office and in Cuba there is a choice of just five firms. To be fair this is an improvement if we go back to the 1980s and compare to former Communist states such as the Soviet Union and the German Democratic Republic where foreigners had a choice of just one and two Government-approved IP agencies respectively.

Cuba allows the registration of trade marks and designs through a national route. For trade marks, as stated above, International applications through both the Madrid Agreement and Protocol are possible. For the Protocol, Cuba has made a declaration under Rule 34(3)(a) that it wishes to receive Individual fees in two parts (you may well be more familiar with this requirement with respect to designations of Japan).

Cuba seems an enthusiastic member of the 'international IP community' and it also provides IP support and guidance to local businesses. Despite this, International applications originating from Cuba total just 37 in the last 8 years. This may be unsurprising given the economic situation in Cuba. The country also has work to do on improving the efficiency and operations of its IP Office with delays being a regular occurrence. These are often not helped by unresponsive agents but as Cuba (very) slowly opens up more to the West, we can hope for improvements.

Hague happenings

The Hague System for the International Registration of Industrial Designs does not compete with its trademark counterpart under the Madrid System.

There are some fairly obvious reasons for this:

1. In the "hierarchy of intellectual property" designs do not sit as high up as patents or trademarks.

2. The country scope of the Hague System is not as comprehensive as the Madrid System.

3. The confusion with - and to a certain extent non-compatibility - of the Hague and Geneva Acts of the Hague System.

The value of designs is expanding, as I have previously blogged, and the number of registered designs is increasing.

The country scope of the Hague System is far from comparable to the Madrid System for trade marks.

Europe is widely covered by Hague - the EU being a member making a notable contribution here. Africa is a patchwork of members and non-members (as it is also with respect to Madrid) with OAPI membership noteworthy. However, the membership barely touches Asia or the Americas let alone Australia at all.

Hague membership sits at 60 members. However, this is a bit misleading as 15 are a party to the Hague Act only and 45 are a party to the Geneva Act. For those of you with more exposure to trade marks, you can align this with the Madrid Agreement and the Madrid Protocol. Similar to how the Madrid Agreement is being phased out (with just Algeria being a member of the Madrid Agreement but not the Madrid Protocol), it seems the aim of WIPO to replace the Hague Act with the Geneva Act; a previous Act, the London Act is already "frozen".

It is complicated a bit further in that some of the members of the Hague Act only are member states of the European Union or of OAPI; with the EU and OAPI being members of the Geneva Act. Applicants from these countries can take advantage of both the Hague Act and the Geneva Act (using different entitlements).

Expansion of the Hague System is arguably less of a priority for IPR owners. Designs are often protected in a home jurisdiction only, as WIPO's statistics for 2010 seem to evidence. 77% of direct applications for Registered Community Designs were by EU applicants in a total of 76,865 filings. In the same period the EU was designated in an International Hague Application on only 3,512 occasions.

When the UK Government examined the EU's plan to accede to the Hague System it came out in support but against a simultaneous application to join it at a national level. It was asserted that the majority of IPR holders that sought design registration outside of the UK would need it in the EU anyway.

The figure for Hague designations of Switzerland is similar to that of the EU. Conversely, this figure is higher than the number of applications filed directly to the Swiss Federal Institute of Intellectual Property. This does suggest more regular use of the Hague System by Swiss applicants to protect in their home country and the EU.

New joiners tend to join the Geneva Act. Of the 15 Hague Act only countries, only four (Belize, North Korea, Morocco and Suriname) do not also have effective Geneva Act membership through being a part of the EU or OAPI.

Of these, Belize, as a Common Law country, should amend local legislation to reflect their membership but I cannot see anything in their Industrial Designs Act - Cap. 254 regarding this and would therefore have doubts concerning the enforceability of an International Registration in Belize.

North Korea faces stringent UN sanctions and most banks in the West will refuse to transfer funds there. Use of the Hague System circumnavigates this somewhat (as official fees are transmitted to WIPO) but potential applicants should be cautious and I would consider avoiding designating North Korea, even if it is possible to do so.

For Geneva Act qualifying only applicants, Suriname at the top of South America also cannot be included. The same applies for Morocco for the time being at least, but according to my sources at WIPO this country is moving towards Geneva Act accession.

The Republic of Korea - for the avoidance of doubt, that's South Korea - is expected to provide notable Asian presence with its expected accession to the Hague System. Over 57,000 design applications were filed in South Korea in 2010 which makes it a considerably large design filings country. Internal politics - an election is scheduled for later this year - have slowed the accession proceedings for the time being.

China and Japan have also been mooted as future members but this could be over enthusiasm from WIPO officials. During 2010, a humongous 421,273 design applications were filed in China (and it's not often I get to use the word 'humongous' in an IP blog!).

The United States have also been suggested as future members; I'm certainly aware that they have an upcoming election but more in the dark about any possible Hague membership application.

Of the current members, do be careful in designating Ghana for the same reason as Belize above. I cannot see amendments to Ghana's local law to allow for the enforceability of Hague International Designs. Incidentally, this is the same situation with respect to the Madrid Protocol and Ghana.

The situation in Namibia is ambiguous. Constitutionally Namibia should recognise the international treaties it has become a party to, but it has yet to implement specific legislation catering for Hague designs. With its history tied to neighbouring South Africa, it has a mixed Civil Law and Common Law system.

The other member countries are Civil law countries, which take into account international obligations. This includes Rwanda, which has a legal system derived from Belgian Civil law, although is now a part of the Commonwealth of Nations.

The Hague System languishes behind the Madrid System but it provides a very cost effective way to obtain design protection across Europe (beyond the EU). The addition of manufacturing powerhouses such as China and South Korea can only see its stature grow as a major commercial player could add momentum to a membership increase.

WIPO's own 2012 report on the Hague System, containing statistics and pretty graphs, was issued in May.

D-d-d-d-designs

Despite a terrible reputation for its food, the United Kingdom has historically lead the way in many areas. In terms of intellectual property, it introduced the world's first trade mark registration system through enactment of the Trade Mark Registration Act 1875. However, design legislation pre-dates this - by some time - starting with the Designing & Printing of Linen Act 1787.

In fact, there was a branch of the UK Patent Office based in Salford (a city in walking distance from my office) purely for the receipt of textile designs. This area of the country was nicknamed 'Cottonopolis'.

During the 20th Century, I think it is fair to say that designs fell behind trademarks (and patents) in terms of prestige and perceived value. However, these reflections are being evaluated if not already revised.

Quotes from two branding professionals:

"Design is intelligence made visible", Alina Wheeler

"Design is an opportunity to continue telling the story, not just to sum everything up", Tate Linden

These quotes are, of course, not restricted to the intellectual property right definition of "design". However, design rights are now often seen as an increasingly critical piece of a brand owner's IP arsenal. They can provide an invaluable right given a registered design is not restricted to certain products in the same way as a trademark registration must be. The Locarno classification exists but not to pigeon hole in the same way as the Nice Classification for trade marks. There is "no principle of speciality".

However, the addition of Class 32 covering "graphic symbols and logos, surface patterns, ornamentation" to the Locarno classification in 2009 has made it easier for brand owners to protect the likes of logos through design registration.

Obtaining design protection is largely seen as a supplement to trade mark registration rather than an alternative.

SMEs are often more pressured on costs to rely on designs only - and new products are created and protected through registered designs whereas a verbal brand is not developed or a descriptive name is adopted. From an IP professional's perspective this may not be ideal but at least they are recognising that a form of intellectual property protection is useful.

With steps being taken by the UK and the International community to simplify and harmonise design legislation, the status of registered designs in IP's 'hierarchy' should continue to rise.

Increase in International trade mark and design filings

WIPO has announced an increase of International filings for both trade marks and designs during 2011.

Trade mark filings have risen by 6.5% compared to 2010.

That looks good on the face of things, but we will analyse further. OHIM's figure, when the figures for International designations are removed, is an increase of 6.9% year-on-year but compare this to an increase of EU designations in Madrid applications of 11.9%.

I have found some US graph statistics for their filings which are far from specific with the figures so I've used very rough amounts. Nevertheless, removing the Madrid figures from the total sees US filings increase from 2010 to 2011 by approximately 9.5%. This compares to an increase in the Madrid figures of US designations of 11.5%.

Can we draw conclusions from these figures? Firstly, are we comparing a like-for-like Madrid system from 2010 to 2011? The answer is, broadly, yes we are. Israel was a notable joiner to Madrid on 1 September 2010 but this is it really. Kazakhstan (8 December 2010) and Tajikistan (30 June 2011) also came on board but they were already Madrid Agreement members. Denmark's extension of the Madrid Protocol to Greenland - with a population of little over 50,000 - on 11 January 2011 is, I feel, unlikely to have made much inroad into the statistics.

Given this, perhaps the figures show some increased confidence in the global economy but one in which trade mark owners are being more careful with their money. The EU and US have often been filed separately from an International application - there can be some differences and practical advantages by keeping the US and the EU away from an International registration - but costs constraints may appear to have pushed many to consider these acceptable.

When it comes to designs the situation is similar. We have to go on rough graph statistics from OHIM this time. Registered Community Design filings increased by 4% from 2010 to 2011 whereas designations of the EU in a Hague International application rose by 6.6% in the same period.

Again, is this a like-for-like comparison? Yes, largely it is with neither Azerbaijan (joined on 8 December 2010) nor Rwanda (31 August 2011) troubling the statisticians from 2010 to 2011.

A difference in the Hague system compared to Madrid is that you do not require a base application in your home country and can include your home country within an application. This could also demonstrate a stronger global economy as EU applicants go via Hague because they have interest in protecting their designs not just in the EU but outside it too.

The Hague system will welcome Tajikistan on 21 March 2012 as it already has done with Montenegro on 4 March 2012. The Madrid system (which may see its Madrid Agreement part become extinct) is also hoping to increase its members this year. Both will continue to offer great value ways of obtaining broad trade mark and industrial design protection.

Just be aware of the issues in Common Law countries that do not enshrine their obligations to Madrid or Hague in their national laws. As I've touched on before, I have some doubts regarding the enforceability of Madrid International Registrations in Bhutan and some African countries.

UK Registered Designs - how far do they go?

I sometimes describe registered designs to clients as suffering from middle child syndrome when it comes to intellectual property rights stuck between big brother patents and younger sibling trade marks, with copyright being a close cousin and spoilt only child. Design law gets less attention and suffers from a lack of harmonisation worldwide; it's law being made up of bits of the other three. It's tagged on to a dominating patent regime of some countries, part of copyright and/or, as in the case of the EU, being controlled by its Trade Marks Office.

It does not always get completely disregarded and, for example, the UK is looking to improve its registered design system at the moment.

Some countries do not have design legislation and in some it is often assumed that a UK registration covers some countries automatically. Some of these assumptions come from the UK IPO website - or from private firms who advise based on this information. Therefore, I have explored how up-to-date the IPO's information is and provide my findings here. Independently, I have passed these on to the IPO so, if they agree, they can update their own website pages.

Of note is that Registered Community Designs ("RCDs") will not, except in a few cases, have the same effect as a United Kingdom Registered Design in these jurisdictions. This is a similar situation as with respect to UK Trade Marks and their Community Trade Mark counterparts.

Many of the countries that have introduced local design legislation provided for 12-month transitional periods for owners of UK Registered Designs to apply locally. I believe these periods have now concluded, where applicable.

Legislation introduced in 2002 brought design registration to Anguilla. Unfortunately, the law is is not available on-line without paying a fee.

Antigua and Barbuda now has independent design legislation.

Bermuda has a design law that allows for automatic protection of UK registrations but also allowing for purely local applications.

It is believed UK registrations will be automatically protected in the British Indian Ocean Territory.

The Falkland Islands also provide for automatic protection. Note the UK IPO's advice, "The Supreme Court of the Falkland Islands is empowered to declare that rights in a UK design have not been acquired in the Falkland Islands on any grounds for cancellation existing under UK law, including publication of the design in the Falkland Islands prior to the UK registration." This provision tends to be replicated in other jurisdictions providing automatic protection.

Fiji also provides for automatic protection. However, it is possible, and would indeed seem recommendable if this country is of commercial interest, to advertise the design rights already obtained in the UK in a Fijian newspaper.

Gambia now has its own law after implementing regulations were brought in during 2010.

Both Gibraltar and Grenada have laws providing for automatic protection.

With respect to Gibraltar, its status with the EU under Article 299(4) of the Treaty of Rome should allow for automatic protection of RCDs. However, there have not been amendments to Gibraltar's local Designs Act to reflect this and, as such, I believe it would be unwise to rely on RCDs being enforceable in Gibraltar.

Guernsey is a 'secondary' design jurisdiction and re-registers designs including those from the United Kingdom and Registered Community Designs.

Guyana also provides for automatic protection although there is a defence for infringers if they could not know of the design in Guyana which suggests if there is no use or disclosure in Guyana (e.g. in the UK only), a registered design owner would be prevented from taking action. This could be a fair defence in many of the other jurisdictions too.

UK Design legislation is extended to the Isle of Man (by the British Government not the Manx Government) to provide automatic protection. Obviously, this has been amended to reflect a Registered Community Design covering the UK. Therefore, I am confused by the IPO's statement that RCDs do not cover the Isle of Man as my interpretation is that they would.

Jersey is a re-registration jurisdiction. Only a UK National Registered Design can be registered locally; no provision is made for RCDs.

UK Registered Designs are automatically protected in Kiribati.

Malta now has independent design legislation and being part of the European Union is also protected through a RCD.

United Kingdom Designs (Protection) Act No. 181 of 1887 is not available on-line but is understood to be the local legislation providing for automatic protection of UK Registered Designs in Montserrat.

St Helena is another with the fairly standard "recognise UK Registered Designs automatically" law.

I cannot see that St Kitts and Nevis has a design law to allow for either automatic protection of UK Registered Designs or for independent local applications.

St Lucia and St Vincent and the Grenadines now allow for independent design registration and UK Registered Designs will not have effect.

I cannot see that there is any design legislation in the Seychelles at all, let alone any that would give provision to automatic protection of a UK Registered Design. However, it is possible to register copyrights.

Sierra Leone offers an unclear situation through my on-line enquiries (I've not bothered my associate in Freetown at this stage). I cannot locate a design law which would allow for automatic protection of a UK Registered Design. It is possible to designate Sierra Leone in an ARIPO design application but in the absence of any design legislation, questions should be asked of its enforceability. Sierra Leone had plans for a new IP law in late 2008 but I do not believe this came into force.

UK Registered Designs extend automatically to the Solomon Islands.

Swaziland operates its own national design registration system now.

Tanzania is made up of two separate IP jurisdictions, Tanganyika (the mainland) and the island of Zanzibar. The mainland seems to lack design legislation but provisions within its Patent Act provide for automatic protection of UK Registered Designs. When it comes to Zanzibar, local independent legislation is in place.

My interpretation of the Tuvalu Chapter 62: United Kingdom Designs Protection would be that it provides for automatic protection of UK Registered Designs but I make this statement with a disclaimer. The UK IPO seems to think a local re-registration application is necessary.

In his over six years in power, Idi Amin CBE ("Conqueror of the British Empire") obviously forgot to repeal Uganda's United Kingdom Designs Protection Act. This remains in force to this day and provides for automatic protection of UK Registered Designs.

Vanuatu's design law is in a state of limbo - and for the same reason as its trade mark counterpart i.e. an absence of implementing regulations - is not yet in operation and it is therefore not possible to file for designs at this time.

The situation with the British Virgin Islands as described by the UK IPO would appear to be the same situation as exists in Bermuda (above).

After all this, I will provide a concluding table which I must stress is based on my interpretations and the taking of some information at face value.

Jurisdiction	UK	RCD
Anguilla	No	No
Antigua and Barbuda	No	No
Bermuda	Automatic	No
British Indian Ocean Territory	Automatic	No
British Virgin Islands	Automatic	No
Cayman Islands	No	No
Falkland Islands	Automatic	No
Fiji	Automatic	No
Gambia	No	No
Gibraltar	Automatic	Automatic but questions remain
Grenada	Automatic	No
Guernsey	Extendable	Extendable
Guyana	Automatic	No
Isle of Man	Automatic	Automatic
Jersey	Extendable	No
Kiribati	Automatic	No
Malta	No	Automatic
Montserrat	Automatic	No
St Helena	Automatic	No
St Kitts and Nevis	No	No
St Lucia	No	No
St Vincent and the Grenadines	No	No
Seychelles	No	No
Sierra Leone	No	No
Solomon Islands	Automatic	No
South Georgia and the South Sandwich Islands	No	No
Swaziland	No	No
Tanzania (Tanganyika)	Automatic	No
Tuvalu	Automatic	No
Uganda	Automatic	No
Vanuatu	No	No
Zanzibar	No	No

Many readers will be aware of the excellent value of the RCD system - 27 countries protected for a basic official fee of €350. The UK itself also provides for cost-effective design registration with the basic official fee being only £60 (about €70). Global owners of design rights may wish to ensure they obtain protection at not only the European Community level but also at the UK level, particularly if protection is required in parts of the Americas, Africa or the Pacific. RCDs and UK Registered Designs are both obtained very quickly.

As always, any comments or questions are welcomed.