CIPA JOURNAL Incorporating the transactions of the Chartered Institute of Patent Attorneys
November 2019 / Volume 48 / Number 11
Published 30 October 2019
Practice guidance on a no-deal Brexit Customs enforcement after Brexit Emma Green
Exhaustion of IP rights if there is a no-deal Brexit Katharine Stephens
SEPs and EU standard-setting post-Brexit Andy Spurr
Unified Patent Court and the UK after Brexit Alan Johnson
IP in a postBrexit world Questions & Answers
UP FRONT
CIPA JOURNAL Editor Deputy Editors Publications Committee Production and advertising Design Cover design Contact
Alasdair Poore Sean Gilday; Jeremy Holmes Bill Jones (Chairman) Iain Ross, 020 3289 6445, sales@cipa.org.uk Neil Lampert Jonathan Briggs editor@cipa.org.uk
Published on behalf of CIPA by Ross-Limbe Communications. The Institute as a body is not responsible either for the statements made, or for the opinions expressed in this Journal. No papers read before the Institute or extracts from its Proceedings may be published without the express permission of the Council and without the simultaneous acknowledgement of their source. CIPA Journal is sent to all members of the Institute as part of the benefits of membership. It is also available on subscription at £130 per annum (plus postage for overseas addresses: Europe £35, Other £70). Individual copies may be purchased at £14 (plus postage for overseas addresses: Europe £4, Other £6). The Editor welcomes the submission of articles, news and correspondence for possible publications including photographs, tables, charts, etc, when appropriate, and any contributions should be sent by email to editor@cipa.org.uk. Iain Ross (iain@ross-limbe.co.uk) will be pleased to discuss any queries regarding submissions and advertising. Copyright in material submitted for publication Material submitted to the CIPA Journal will be accepted for publication on condition that the author, or each of them, grants the Chartered Institute a non-exclusive licence to publish the material: i. in paper form first; and ii. after paper publication, also on its website www.cipa.org.uk, in the members’ area with the ability for members to download them. When sending material, the author(s) should confirm acceptance of this condition and also that the submission is free of any third-party rights or other encumbrances. Past contributors The Institute is in the process of putting on its website past articles not covered by an express agreement as set out above. Any contributor wishing to object to their work being treated in this way should write to the editor at editor@cipa.org.uk. Editorial deadline dates for receiving submissions are on the 10th of the preceding month. Please contact editor@cipa.org.uk to discuss any ideas for articles or submissions. © The Chartered Institute of Patent Attorneys 2019 2nd Floor, Halton House, 20–23 Holborn, London EC1N 2JD ISSN: 0306-0314
CIPA CONTACTS
Julia Florence President
Richard Mair Vice-President
Stephen Jones Immediate Past-President
Gwilym Roberts Honorary Secretary
Committee Chairs Business Practice Matt Dixon; Computer Technology Simon Davies; Congress Steering John Brown; Constitutional Alasdair Poore; Designs & Copyright Alicia Instone; Education Vicki Salmon; IP Commercialisation Catriona Hammer; IP Pro Bono Stephen Jones; Informals Matthew Veale; Internal Governance Catriona Hammer; International Liaison Richard Mair; IP Paralegals Julia Tribe; Life Sciences Simon Wright; Litigation Matthew Critten; Media & Public Relations Jerry Bridge-Butler; PEB Michael Yates; Patents Tim Jackson; Protected Titles Lee Davies; Regulatory Affairs Chris Mercer; Textbooks & Publications Bill Jones; Trade Marks Keith Howick. Head of Membership Dwaine Hamilton Membership Officer Frances Bleach Events and Professional Development Officer Emma Spurrs Events Co-ordinators Grace Murray, Kathryn Espino Chief Executive Lee Davies Deputy Chief Executive Neil Lampert Executive Assistant Charlotte Russell Head of Qualifications Angelina Smith Head of Finance Spurgeon Manuel HR Officer Lea Weir-Samuels Communications Officer Amy Williams External Affairs Officer Abby Lever Admin Generalist Kereiss Isles General enquiries 020 7405 9450; mail@cipa.org.uk; www.cipa.org.uk
Contents
29 & 32 UP FRONT
BREXIT BRIEFING DECISIONS
2
28
Council Minutes
Lee Davies
BREXIT UPDATE 5
No-deal Brexit
29
Advice for IP practitioners 6
IP in a post-Brexit world
Questions & Answers 10
Trade marks – the Madrid system post-Brexit
12
Designs – the Hague system post-Brexit Practice guidance on a no-deal Brexit
Questions & Answers
16
Patents; SPCs; trade marks; designs; .eu domain names; Community Plant Variety Rights; Marketing Plant Reproductive Material in the EU; GIs 18
European patent work unaffected by Brexit
32
37
The UK plays a major role in European standard-setting. How will Brexit affect this? Andy Spurr
40
Exhaustion of IP rights if there is a no-deal Brexit
42
Government Brexit guidelines have sought to retain the present system of EEA-wide exhaustion of IP rights, but a no-deal Brexit would not allow this Katharine Stephens
44
Into the unknown
54 33
Non-Institute events
The Unified Patent Court and the UK after Brexit
56
Institute events
Can the UK still play a role in the UPC after Brexit? Alan Johnson
PERSONAL
Customs enforcement after Brexit Emma Green. 34
THE PINKS 59
Volume 48, number 11
SEPs and EU standard-setting post-Brexit
Courses & Events; Support; International; Recruitment
Patent decisions
Beck Greener Shanks v Unilever
Chris Ryan 41
IPO decisions
David Pearce & Callum Docherty EPO decisions
Bristows Trade marks
Bird & Bird
EDUCATION IP Outside Your Comfort Zone
Webinar report on IP Agreements
43
IP Pro Bono update
55 58
Announcements IP Inclusive update
Stephen Jones & Kate O’Rourke
Andrea Brewster OBE
NOVEMBER 2019
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Q&As
IP in a post-Brexit world On Monday 28 October, CIPA Chief Executive Lee Davies chaired a live Q&A session with Institute President Julia Florence and Council members Alicia Instone and Matt Dixon. The panel considered the impact that Brexit will have on various aspects of intellectual property, from the cloning of European trade marks and designs onto the UK register to the continuing work of UK-based Chartered Patent Attorneys in the European Union. Patent work will not be affected by Brexit because the European patent system is not governed by the EU. This event, which was broadcast on YouTube from CIPA HQ on 28 October 2019, was watched by an audience in the UK, the US, Canada, Italy, Spain, Germany, Italy, Spain, Sweden, Finland and Poland. Set out below is a report of the discussion focusing on the questions asked and the responses provided by the panel. The event was organised with the support of the Brexit readiness fund and in conjunction with CIPA’s media partners Worktime TV. CIPA members can see the broadcast in full at: www.cipa.org.uk/whats-on/events/ip-in-a-post-brexit-world. also leads on CIPA’s work on designs and copyright and is influential in trade marks. Finally, Matt Dixon, the focus of CIPA’s work around business practice and what Brexit means for firms. The event started with Lee getting Alicia, Julia and Matt to outline their areas of interest and areas of work on Brexit. Alicia Instone (Chair, Designs & Copyright Committee and incoming vice-president)
A
s well as being live online, the event was broadcasted from CIPA’s office in London to regional hubs (with the support of member firms) in: Manchester (Appleyard Lees); Glasgow (Lawrie IP); Cambridge (Mills & Reeve LLP); Gloucester (Wynne-Jones IP Ltd); Hatfield (Cleveland Scott York); and Munich (Dehns). Lee Davies (CIPA Chief Executive) noted the huge interest for the broadcast, not just from around Europe, but across the world. Pointing out that there were already questions online from Italy, France, Germany, and Spain. Lee highlighted CIPA’s Brexit-related work. Since 2016, CIPA has worked tirelessly 6
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to ensure that the UK leaves the European Union (EU) without the IP system being damaged by any unintended consequences. International work for the last three years has been heavily focused on Brexit, stressing that as far as patents are concerned it is business as usual, but that there will be some changes particularly in the world of trade marks and designs. Council members have been the most active in the work on Brexit and Lee was delighted to be joined on the panel by three council members. CIPA’s president Julia Florence. Alicia Instone, the incoming vice-president (from 1 January 2020). Alicia
Alicia ran through her experiences in the world of trade marks and designs. It had been interesting to spend lots of time being thrown in at the deep end with lots of meetings with the UK government, in particular with the UKIPO and also with Defra and the Ministry of Justice (MoJ). There are quarterly meetings with the Marks and Designs Forum (MDF). There were two separate meetings to talk about rights of representation and the transitions of the rights onto the UK register. As well as special meetings about seniority claims and to make sure that the UK legislation is in place for the creation of comparable or re-registered rights. There have also been meetings to spot any errors in statutory instruments (SIs) before they are laid in Parliament (including the trade marks SI). www.cipa.org.uk
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On the design side Dave Musker (Fellow) has been heavily involved in making sure documents were scrutinised so that nothing went through without CIPA having an opportunity to comment. Although CIPA did not have too much influence, the UKIPO was receptive when CIPA spotted any sort of nuances. All the way through the UKIPO has been very engaged with CIPA. There have been meetings with Defra for update on the geographical indications (GIs) process. As well as meetings with the MoJ about the issues surrounding the rights representation. CIPA will continue working with the government on the rights of representation. How have you found being an unpaid volunteer parachuted into this world of lobbying and campaigning on behalf of members and also the users of the IP system? This was something she had not come across before. It was quite daunting to be the person looking at and scrutinising SIs. It is quite a responsibility but very rewarding to provide feedback. At times, it has even been quite fun. What do you think has been the most challenging aspect of the changing world for designs and trade marks? How to make sure that the UKIPO did not do anything that would inadvertently give anything away in terms of rights. As well as making sure the UKIPO’s implementation was as smooth as possible for users and for business. This involved looking at the pros and cons of the various models put forward by the UKIPO and identifying any issues there might be. Lee thanked Alicia on behalf of our members and also users of the IP system for the work she has done. Julia Florence (CIPA President, and until her recent retirement was a senior patent attorney at GlaxoSmithKline)
Julia shared some of her experiences and thoughts in terms of CIPA’s work on patents but also the work that CIPA has been doing nationally and internationally. It has been very interesting. Much of the work on patents mirrors what Alicia has been doing on trade marks and designs. Certainly, for patents we are in a very fortunate position Volume 48, number 11
Q&As
CIPA’s Chief Executive Lee Davies chaired a live Q&A session with Institute President Julia Florence and Council members Alicia Instone and Matt Dixon
that Brexit does not actually affect European patent work for the UK. There has been a lot of misinformation and misunderstanding, particularly outside of the UK, as to how that could be the case. For the past three years, and before Julia was president, former presidents Stephen Jones and Tony Rollins as well as members of CIPA’s International Liaison Committee have travelled all around the world giving CIPA’s message that for European patents Brexit has no effect and it is business as usual. Julia’s mantra has also been that the Europe that we are trying to leave is quite distinct from the Europe that grants our patents. People are beginning to understand that the EPO is not an EU agency it is an international organization. Likewise, the EPC is not EU law, it is an international agreement and that is why Brexit has no effect on the EPC. CIPA has had to take that message far and wide and continues to do that. The UKIPO has been fantastic in making sure that CIPA is kept up to date with issues that are arising through Brexit. One part of the patent space that is partially affected by Brexit is around supplementary protection certificates (SPCs) and the EU regulation. All EU regulations that are in force on exit day will become retained EU law. The UK have the same effective legislation in the UK after Brexit. There has been a need to fix certain parts of the legislation, which for example refer to other EU agencies and EU legislation and those need to be amended so that they refer instead to UK bodies and UK legislation,
so that the law will operate smoothly once the UK left the EU. That is being done by means of such instruments as Sis, and again CIPA has been very heavily involved with the SIs relating to SPC regulations. Julia has travelled extensively to represent CIPA in her time as president. Lee asked how this has been received in terms of the business-as-usual message and the work on behalf of members when overseas? Julia remarked that CIPA has been very well received. Everybody’s been very interested to hear CIPA’s message and there have been lots of questions. People are glad that CIPA has gone out to demystify and clarify, as far as it can, what is happening with IP and Brexit. What would you say have been the biggest or most important questions you’ve been asked when you’ve been on your travels? There have been a lot of questions about using the EPO and whether UK attorneys will be able to continue to represent clients, which of course they will be able to. A lot of questions about the UPC. When Stephen Jones was president, he wrote to Theresa May urging that the government should ratify the UPC Agreement, so it was very pleasing when the UK did ratify. At the moment progress on the UPC is being held up by the German constitutional challenge. The UK government’s stated aim is to continue to negotiate with Europe to ensure that the UK can play a part in the UPC after Brexit. NOVEMBER 2019
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authorisation, which predates the UK authorisation (article 8). Under the new UK domestic SPC regulation the duration of the SPC will be based either on the first authorisation in the UK or the earlier authorisation in the EEA. EU marketing authorisations, which have been granted before exit day, will be converted to equivalent UK marketing authorisations. The UKIPO may request information regarding the converted marketing authorisations. Pending applications for EU marketing authorisation will need to be refiled at the UK MHRA.
PRACTICE GUIDANCE
It is good practice when dealing with SPCs for members to ensure that they or their clients maintain good communication with those colleagues responsible for obtaining marketing authorisations, and this will be especially important as the above changes are implemented. SPC Manufacturing Waiver: The SPC regulation was amended with effect from 1 July 2019, by virtue of the new Regulation (EC) 2019/933. This permits generic and biosimilar manufacturers in Europe to manufacture medicines protected by an SPC for export to countries where parallel
protection does not exist. The waiver also permits stockpiling during six months prior to SPC expiry, to enable launch in Europe immediately on SPC expiry. The waiver will not apply to SPCs in force on 1 July 2019, but will apply to SPCs applied for after that date. For SPCs pending on 1 July 2019 the waiver will apply as from 2 July 2022. At Brexit. this new Regulation will be retained in UK domestic law, and as with other EU regulations it will be amended by means of an SI, to ensure it will function correctly. The UKIPO has recently consulted on the SI, but the final version is not available at the time of writing.
European patent work unaffected by Brexit
T
he effects of the UK’s decision to leave the EU are already being felt across the UK’s service industries. But when it comes to patents in Europe, it is business as usual. The European Patent Office – via which patent rights across Europe can be obtained – is not an EU institution. The UK’s 2,400 European qualified patent attorneys will be able to continue to represent their domestic and overseas clients there after Brexit. In fact, since
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the result of the UK’s referendum on EU membership, there has been no let-up in the large number of European patent applications filed by British attorneys. The resistance of the European patent system to the effects of Brexit is good news for both the UK, and for those around the world who want to use British legal expertise to protect their intellectual property in Europe. It is positive for the UK because along with trade mark attorneys, the UK’s patent attorneys
contribute more than £1bn to the British economy. The majority of this comes from foreign companies choosing to use British representation. In fact, of the 40,000 European patent applications filed each year by the UK’s European patent attorneys, nearly 90% are for clients from overseas. This shows the high regard the rest of the world has for the UK legal sector. It also means that, while UK chartered patent attorneys form a fifth of all European patent attorneys practising today, they file a third of all European patent applications. While many aspects of UK and European law will be affected by the UK’s withdrawal from the EU, patent work will continue unchanged. And UK patent attorneys will continue to represent domestic and overseas clients before the European Patent Office in exactly the same way as they do now. Good news for Britain. Good news for businesses worldwide. Patents Unaffected by Brexit: script from CIPA’s animation, available online. www.cipa.org.uk
BREXIT
PRACTICE GUIDANCE
EU Registered Trade Marks – EUTMs Assuming there is no deal and no transitional period at 11pm on exit day, the UKIPO will create a “comparable trade mark (EU)” on the UK trade mark register, which will be derived from the corresponding EUTM. The comparable trade mark (EU) will have the same number as the corresponding EUTM, but will be given a different prefix. The number allocated to the comparable mark (EU) will be the last eight digits of the corresponding EUTM prefixed with UK009. Practice Point: Check with the supplier of your records software as to whether or not there is an automated process that they have/are developing that will be able to locate registered EUTMs on your records, and create a new record for the comparable trade mark (EU). You might want to run this in a test environment to look for any unexpected wrinkles ahead of time. The comparable trade mark (EU) will have the same details as the corresponding EUTM, including the same expiry and renewal date. Practice Point: Check your records for any trade marks due for renewal in the six months post exit day. It will not be possible to renew the trade marks early before exit day to avoid having to pay two lots of renewal fees post exit day. Therefore, there may be renewal fees due on the comparable trade mark (EU) immediately after the exit day, which you will not have been notified about in advance. However, there will be no late fees for the first six months. It may be that there is no intention to renew certain comparable trade mark (EU) for example where there is already an “equivalent” earlier filed UK trade mark. The comparable trade mark (EU) will be treated as if it had been a national application and there will be no distinction at the UKIPO. This means Volume 48, number 11
that if the comparable trade mark (EU) is cited in searches carried out by the UKIPO the rights holder (or their address for service) will be notified whereas currently the equivalent EUTM rights holder would not. Practice Point: Many more rights holders will be made aware of UK filings who would not have been made aware previously so there will be an increase in notifications being issued by the UKIPO and there could be an increase in opposition filings at the UKIPO. The comparable trade mark (EU) will have the particulars of the goods/services taken from the English language version of the corresponding EUTM. Practice Point: If you spot any comparable trade mark (EU) that has an error in the English language version, then any person having a sufficient interest may apply to have the register rectified. This can be done at any stage, but probably best to do as soon as you spot anything. This is only relevant for cases not filed in English or where the second language was not English. The UKIPO has indicated that it will notify rights holders that a comparable trade mark (EU) has been granted by publishing a notification and guidance on its website. Practice Point: This notification will simply be a general notification on the website of the UKIPO and individual notifications will not be sent to the representatives on file at the EUIPO or the proprietor of the corresponding EUTM. However, the same representative on file at the EUIPO will be recorded as the UK address for service on the comparable trade mark (EU) initially. This means that you will not receive a bundle of notifications and you will need to find another way to check all of the rights that you are expecting to be created for your clients are correct and that the correct NOVEMBER 2019
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SEPS
EU standard-setting post-Brexit The UK currently plays a major role in European standard-setting. How will Brexit affect this? By Andy Spurr (Fellow)
U
K business’ access to standardsetting organisations such as ETSI, IEEE, ITU will not be affected by Brexit as companies can directly contribute to the technical and policy aspects of these standards bodies; the same applies for implementer access to standards produced by such bodies. However, there are a number of EUbased organisations in which the UK currently participates via the British Standards Institution (BSI) to shape European standards policy, which may no longer be possible following Brexit. The most prominent of these organisations being the European Committee for Standardisation (CEN)1 and the European Committee for Electrotechnical Standardization (CENELEC)2. The UK currently has voting rights regarding decisions made by these bodies and as such can influence the direction of standards to the benefit of UK businesses and consumers. In terms of SEP policy, CEN and CENELC have been active in engaging with stakeholders to determine ‘core principles’ for SEP licencing3,4. Again, the UK’s seat at the table currently enables some influence to be had in these policy decisions. The BSI published a report5
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in February 2018 advocating for maintenance of the UK’s membership in both CEN and CENELEC following Brexit. In this report they point out that CEN and CENELEC are not EU organisations, with the Republic of North Macedonia, Serbia and Turkey being members without being EU or EFTA members. However, this seems by virtue of them being ‘accession countries’, so it is not clear on what basis the UK could maintain its membership (particularly in the event of no-deal). It should be noted that the initiation and development of many standards (and in particular SEP-heavy standards such as 5G) are directed via industry groups independent of organisations such as CEN and CENELC, and Brexit
will have no direct impact on such industry-led groups
SEP litigation Given the global nature of standardised products and services, SEP holders have great degree of freedom in the selection of forum for conducting litigation. In recent years, the UK has been a popular forum. However, the Unified Patent Court (UPC) may prove to be a more attractive forum as it would provide the potential for a broader injunction, assessment of damages, and setting FRAND licence rates. SEP holders may prefer to request unitary effect of their granted EP patents as a UP would provide cheaper territorial
Notes and references 1. www.cen.eu 2. www.cenelec.eu 3. www.cen.eu/news/workshops/Pages/WS-2018-04.aspx 4. www.cencenelec.eu/news/workshops/Pages/WS-2019-014.aspx 5. www.bsigroup.com/globalassets/localfiles/en-gb/about-bsi/nsb/brexit/ bsi-brexit-position-report-february-2018.pdf 6. UKSC 2018/0214, UKSC 2019/0041 and UKSC 2019/0042 – this ruling is likely to be very influential on the UK’s global position with regard to litigating SEPs. 7. C-170/13 Huawei Technologies
www.cipa.org.uk
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coverage (and hence increased net licensing revenue) – and due to the sheer number of SEPs relevant to any particular standard – the possibility of central revocation may be less of a detractor. If Brexit means that the UK cannot take part in the UPC (but it goes ahead nonetheless), it is conceivable that the UK would no longer be as attractive a forum to resolve SEP disputes. However, any impact of Brexit may be outweighed by the upcoming decision of the UK Supreme Court6 scheduled for late 2020 which (amongst other issues) will decide whether the UK courts can set global FRAND rates – which would be a very attractive
EXHAUSTION
position for SEP holders. [See more on the UPC on page 34.]
Interaction with competition law The EU’s precedent for fair negotiation of FRAND terms is currently set out by the CJEU in Huawei v ZTE7 – the UK application of which forming another aspect of the above UK Supreme Court decision. This UK ruling should provide some clarity on what conduct is required during FRAND negotiations in the UK. Following Brexit, only the parts of Huawei v ZTE ruled on by the Supreme Court may be binding on the UK courts, and further divergence may occur following future CJEU decisions.
As EU competition law has a ‘long arm’, it is likely that parties conducting SEP licence negotiations with a European component will choose to follow CJEU guidance during FRAND negotiations, and as such they may prefer to conduct litigation in states bound by such CJEU decisions. This may be via the UPC, or other national courts such as Germany or the Netherlands (which both have significant experience in SEP litigation). Andy Spurr (Fellow); the views and opinions expressed in this article are those of the writer and do not reflect the policy of any other organisation.
Exhaustion of IP rights if there is a no-deal Brexit The government's Brexit guidelines have sought to retain the present system of EEA-wide exhaustion of IP rights, but a no-deal Brexit would not allow this. By Katharine Stephens (Associate)
P
reparing for Brexit presents an opportunity to consider what principle of exhaustion of IP rights should apply to goods sold in the UK – should there be national, international or regional exhaustion? The Government is consulting on this question, but as a temporary measure to come into force on the day the UK exits the EU, the present system of EEA-wide exhaustion will be retained to the extent possible. Post-Brexit, IP rights in goods put on the market in the EEA will be exhausted in the UK but, absent any agreement with the EU, there will be no
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reciprocity for goods put on the market in the UK and the IP rights in the EEA will not be exhausted. The Government’s Brexit guidelines1 stress the need for parallel importers to review their supply chains and, if necessary, contact the relevant IP rights holders for permission to import goods into the EEA. The advice is necessary. Parallel trade from the UK to the EEA does take place, encouraged recently by the significant fall in sterling. A pertinent example is that of the decision of the European Court of Justice relating to the importation into Spain of Schweppes NOVEMBER 2019
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CUSTOMS
Into the unknown – Customs enforcement after Brexit Rights owners should consider their position on Customs enforcement so they are ready to take action as further guidance on Brexit is issued. By Emma Green
entirety from the date of Brexit in the event of a no-deal. Rights owners breathed a sigh of relief when the draft UK Customs Regulations confirmed that EU AFAs filed via HMRC will remain valid and enforceable in the UK until their natural expiry date, albeit that protection cannot subsequently be renewed. Protection will cease in EU27 as anticipated. Rights owners will therefore need to file: 1.
2.
I
t is fair to say the nerves of rights owners have been tested over the Brexit journey to date. Growing pressure to prepare ahead of hard-stop deadlines, which are ultimately deferred, extended and flexed, has created significant concern and uncertainty for those who want to ensure their brand remains adequately protected after Brexit. IPO guidance has clarified the intention to create equivalent UK protection for the existing pan-European IP rights but there has been significantly less discussion around the mechanisms to establish a national UK Customs Enforcement system.
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The draft Customs (Enforcement of Intellectual Property Rights) (Amendment)(EU Exit) Regulations 2019 issued on 1 March 2019 reassured brand owners and practitioners that the new UK Customs Enforcement system would largely adopt the existing EU AFA framework of Regulation (EU) No 608/2013. The complexity comes in managing the transition between the two systems.
Planning for a no-deal Brexit EUIPO guidance issued in June 2018 indicated that any EU AFA filed via HMRC would cease to have effect in its
a new EU AFA via a EU27 Customs office before the exit date under a no-deal Brexit; and a new UK AFA prior to the natural expiry date of the original AFA.
EU AFA's filed via an EU27 Customs office will remain valid and enforceable in EU27 after a no-deal Brexit but, logically, will cease to have effect in the UK. The HMRC Customs policy team has indicated that HMRC may continue to recognise existing EU AFAs in the UK for a short transitional period after a no-deal Brexit, to allow rights owner's time to obtain protection under new national UK AFAs. The duration of this period is, as yet, unconfirmed. HMRC is yet to issue the new national UK AFA forms outlined under the UK Customs Regulation and has not indicated when these will be available. A short transitional period would therefore no doubt be welcomed by rights owners, acting as an essential safety net until the UK framework is fully established. www.cipa.org.uk
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CUSTOMS
Transitioning in the event of a deal
supplemented by a new UK AFA once the framework is established.
During any agreed transitional period, EUTMs and RCDs will remain valid in the UK, HMRC will remain a competent EU customs authority and the EU Customs Regulation will continue to apply. The existing AFAs will remain in force until their natural expiry date. Rights owners should confirm the remaining term of any existing AFA and identify where it was filed: these factors will fundamentally determine the necessary action.
If changes are required and the EU AFA was filed via HMRC, renewal is not an option, so a new EU AFA should be filed via an EU27 Customs Authority before expiry of the term. This can still designate the UK (to avoid interim gaps in protection) but as UK protection will fall away from the EU AFA on exit, a national UK AFA should also be filed once available.
If no changes are required to an EU AFA filed via HMRC, rights owners who wish to defer costs can simply renew via HMRC up to 30 days before expiry. A new EU AFA will still need to be filed before the withdrawal date to maintain protection in EU27. Alternatively, an EU AFA can be filed via an EU27 Customs office, and this will need to be
The easiest position is for existing EU AFAs filed via an EU27 Customs Authority: that can be renewed or updated as normal. A new UK AFA will be required before the withdrawal date to ensure continuous protection.
Other relevant factors The content of new UK AFA forms will mirror the existing EU framework. All
information will need to be provided afresh, as HMRC will no longer have access to the pan-European COPIS database. There will be no filing fee. Rights owners will need to list existing national UK registrations and the new equivalent registrations created from EUTMs and RCDs – guidance on the numbering of those rights has been issued by the UKIPO. [See pages 16-27.] Practitioners will likely need to acquire new letters of authorisation to confirm that they are authorised to file the applications under the new domestic legislative framework (assuming existing authorisations were granted by reference to the EC Regulation). As we face a brief reprieve from Brexit discussions in the wake of the UK General Election on 12 December, rights owners are advised to use this time to review their existing AFA protection and refine their enforcement strategy.
Emma Green is an Associate in Bird & Bird's Brand Management and Intellectual Property teams. Emma support clients in contentious matters, representing them in UK and EUTM oppositions, revocation and invalidity proceedings as well as negotiating amicable settlements and co-existence agreements. Emma works with clients to devise their international brand enforcement strategy, tackling infringements across online platforms and have extensive experience in establishing EU-wide anti-counterfeiting programmes. See www.twobirds.com/en/our-lawyers/e/emma-green
IP Outside Your Comfort Zone: IP Agreements CIPA webinar report, 24 September. One-hour CPD.
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his webinar was one in a series titled “IP Outside Your Comfort Zone”. The speaker was Lucy Harrold, Consultant Solicitor at Keystone Law. The webinar provided a fairly detailed overview of IP agreements. It could help an IP practitioner to recognise the types of IP agreements that may be appropriate for a client after a client has raised a set of circumstances. The webinar also provided examples of important clauses in IP agreements. It is recommended for any IP practitioner who has not had involvement in IP agreements, or an IP practitioner who has
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dealt with IP agreements occasionally and would welcome up-to-date guidance. The webinar helps a practitioner to understand when an IP agreement is needed, and what type of IP agreement is needed. It also addressed some of the specific considerations for different types of contracts. Lucy also covered some of the key pitfalls in IP agreements. The webinar slides and recording can be purchased from CIPA. Contact cpd@cipa.org.uk Matthew Allen (Fellow)
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UPC
The Unified Patent Court and the UK after Brexit Can the UK still play a role in the UPC after Brexit and can the CJEU accept references from the UK? Alan Johnson (Associate) looks at the possible answers to these and other UPC-related issues
A
s readers will be well aware, the UK ratified the UPC Agreement (‘UPCA’) on World IP day 2018, leaving only Germany as a mandatory ratifying country holding the key to the start of the UPC. Equally well known is that the challenge before the German Constitutional Court (the BVerfG) continues to stall Germany’s ability to ratify. Whilst little hard information is available from the Court, based on the progress of cases in the list, a decision in 2019 now seems unlikely, but it is nonetheless reasonable to expect a decision within a relatively few months. Further, most commentators expect the Court to dismiss the complaint. Hence, the German Government may well, within perhaps six months, be in a position to give the green light to the commencement of the UPC by depositing its instrument of ratification of the Protocol on Provisional Application and some months thereafter deposit its instrument of ratification of the UPCA itself. This leads to a consideration of the impact of Brexit on the decision to be taken by Germany (presumably in conjunction with the other Contracting States) because although the UK has ratified the agreement, and although it is an international treaty technically unconnected with the EU, the UK’s changed status is far from irrelevant for a variety of reasons.
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BREXIT
The most recently stated position of the German Federal Government on the effects of Brexit on the future of the UPC (as stated on 31 July 2019 in response to questions from the Free Democratic Party) was as follows: “The question of the exit of the United Kingdom from the European Union (so-called Brexit) and its effects on the European patent reform play an important part in the subsequent implementation process of the Treaty on a Unified Patent Court. The actual and legal effects of an exit must be reviewed in relation to the Treaty and coordinated at European level. Currently, this opinion forming process is not yet complete, not least because significant factors of the likely exit are currently not yet known.” Whilst non-committal, one thing this statement tells us is that the type of Brexit is regarded as relevant to what happens next. So what will be the position if the UK leaves the EU without a deal? Various commentators, notably Ullrich and Lamping (Max Planck Research Paper No. 18-20) have argued that there are all manner of legal question marks over the commencement of the UPC. Of these, those which deserve some analysis are (in summary): Can the UK, as a non-EU state participate in the UPC? This raises several interlinked issues: ■ Are the references in the UPCA to EU member states an issue? ■ Can the Court of Justice of the European Union (‘CJEU’) accept references from the UPC with the UK participating? ■ What of the fact that the UK will not be subject to the Brussels Regulation? ■ Are there any issues concerning the governance of the UPC if there is a need to modify the UPCA to align it with developing EU law? Volume 48, number 11
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UPC
Can the UK, as a non-EU state participate in the unitary patent?
Can the UK, as a non-EU state, participate in the UPC? Are the references in the UPCA to EU member states an issue? The UPCA was drafted as an agreement between EU member states. The UK’s new status outside the EU is a potential issue, therefore, but hardly one of substance. A Protocol could be adopted by the Contracting States saying that references to an EU member state should be construed as references to a state as of the date of execution of the agreement (in 2014). That should be an end to the issue.
Can the CJEU accept references from the UPC with the UK participating? This is a matter of some controversy. Under article 267 TFEU, the CJEU may accept references from the UPC (under article 21 UPCA) if it is a national court of a member state. Despite being an international court in the sense that multiple nations have agreed (in the field of patents) to delegate their national jurisdiction to the UPC, it can properly be regarded as a national court. However, one view is that the CJEU can accept references only from a national court of member states exclusively. The other view is that provided it is a national court of some member states, that is sufficient when the uniformity and autonomy of EU law is safeguarded – in this case by the provisions of the UPCA (to which the UK has signed up) – which include accepting the primacy of EU law. Ultimately this is a matter, however, which only the CJEU itself can determine. No mechanism exists to ask the CJEU for a preliminary ruling before UPC commencement. However, what is certain is that any issue could be dealt with by an agreement on the UPC between the UK and the EU. Hence, even if there is a no-deal Brexit,
a subsequent agreement could fix the problem. Therefore, if Germany would wish to be risk averse and would not want the UPC to start with the UK as a participant in case the system was later declared illegal, it could promote the idea of an agreement on this issue (be it a standalone agreement or a part of a larger post-Brexit agreement).
What of the fact that the UK will not be subject to the Brussels Regulation? The international jurisdiction of the UPC is founded on article 31 UPCA. This references both the Brussels Regulation and the Lugano Convention. Hence, exclusion for the Brussels Regulation regime is not obviously a bar to the UK’s participation in the UPC. However, it would appear necessary that instead the UK should join (re-join) the Lugano Convention. It is understood that this is in any event UK government policy. One slight “wrinkle” in this is that because Lugano has not been updated in the same way as Brussels Regulation, there is a mis-match between the two regimes. Most notable among these is the absence in Lugano of articles 71a-d of the recast Brussels Regulation, which make specific references to the UPC. Ideally, Lugano should be updated.
Are there any issues concerning the governance of the UPC if there is a need to modify the UPCA to align it with developing EU law? Ullrich and Lamping have argued that governance of the UPC to align it with future developments in EU law might be blocked by the UK. Whilst in any event only a theoretical issue, in fact amendments to the UPCA can only – under Article 87(3) – be delayed by an individual country. In the event of a country objecting to a decision of the Administrative Council to revise the UPCA, a Review Conference (a diplomatic conference) must be convened, and at such a conference no one country may apply a veto NOVEMBER 2019
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CPD & EDUCATION
INSTITUTE EVENTS
CIPA events in 2019 For a complete list of CIPA events please see the website – www.cipa.org.uk/whats-on/events.
Monday 18 November 2019 Webinar
INTRODUCTION TO COPYRIGHT Time: 12.30–13.30 Are you interested in movies, art, music or theatre? If so, you will enjoy learning more about copyright in this high level introduction to the topic. Varuni will provide answers to the following: • • • •
How does copyright arise? What works does it relate to? What rights does it give to the owner? How does copyright relate to the digital world?
The webinar also provides practical advice as to how copyright is relevant to the patent profession. Speaker: Varuni Paranavitane (AA Thornton) CPD: 1; Prices: £72 | £48 CIPA members Tuesday 19 November 2019 Webinar
OUTSIDE YOUR COMFORT ZONE: PATENT SEARCHING Time: 12.30–13.30 Accessing the important information contained in patent documents, that was once the sole domain of the professional searcher, has become increasingly mainstream with the introduction of a number of free, web-based patent search tools. The search engines and interfaces are adequate and very userfriendly for novices, and those who are occasional searchers, to retrieve useful patent information without too much effort. Highlighting some key free patent search tools, such as Espacenet (EPO), PatentScope (WIPO) and Google Patents, this webinar will help you better understand the structured nature of the information 56 CIPA JOURNAL
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within a patent document and how it relates to the patent search process, as well as provide awareness and tips to enable you to carry out effective and efficient patent searches in support of your patentability, freedom to operate and validity assessments. The webinar is aimed at the novice searcher, but can also provide a useful refresher for those who carry out patent searches on an occasional basis.
paralegals, looking at the support that’s available and practical tips for safeguarding your mental wellbeing in an often stressful, deadline-driven job. In the chair: Andrea Brewster, Lead Executive Officer of IP Inclusive, which works alongside Jonathan’s Voice to improve mental health and wellbeing in the IP professions. Speaker: Graham McCartney (Jonathan’s Voice); Prices: £0
Speakers: Susan Bates (Shell); Grayce Shomade (Patent Analyst) CPD: 1; Prices: £72 | £48 CIPA members Wednesday 20 November 2019 Seminar
PATENT CASE LAW MANCHESTER Time: 12.30–17.30 Location: Hotel Football, 99 Sir Matt Busby Way, Manchester M16 0SZ Join CIPA on the Patent Case Law Tour. Our panel will focus on interesting patent decisions to have come from UK and US courts, and the EPO Boards of Appeal in the past year. Speakers: Dr Jonathan Markham, Beck Greener; Dominic Adair, Bristows LLP; Gemma Barrett, Bristows LLP; Anthony Tridico, Finnegan LLP; James Porter, UK IPO CPD: 3.5 Prices: £234 | £156 members Friday 22 November 2019 Webinar
MENTAL HEALTH AND WELLBEING FOR IP PARALEGALS Time: 12.30–13.30 Graham McCartney from the charity Jonathan’s Voice will be speaking about mental health and wellbeing for IP
Tuesday 26 November 2019 Social
CHRISTMAS HAPPY HOUR Time: 18.00–19.00 Location: Savage Garden, Doubletree by Hilton, 7 Pepys Street, London, EC3N 4AF It’s that time of the year again, so come and join us and other members of CIPA for the Christmas Happy Hour 2019!. Please note this is a members only event – book online. Tuesday 26 November 2019 Seminar
NEW STUDENT INDUCTION DAY Time: 09.30–17.00 Location: DoubleTree By Hilton, 7 Pepys Street, London, EC3N 4AF Target Audience: Student Members Are you a new student member of CIPA? Then this event is for you! The New Student Induction Day will be a chance to learn more about CIPA, PEB, IPReg and more! Other topics include:
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CPD & EDUCATION
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The basics of client care The commercial context of IP Dealing with complaints and mistakes Financial and business basics: the IP attorney as a cost centre and income generator; the attorney as part of a corporate team) Stress, and other problems encountered during your training CIPA systems for training and qualification
Please book in advance to book disappointment. See full details online. CPD: 7.0 Prices: £78 Thursday 28 November 2019 Seminar
PATENT CASE LAW BRISTOL Time: 12.30–17.30 Location: Bristol Harbour Hotel & Spa, 53-55 Corn Street, Bristol BS1 1HT Join CIPA for the final stop of the Patent Case Law Tour. Our panel will focus on interesting patent decisions to have come from UK and US courts, and the EPO Boards of Appeal in the past year. CPD: 3.5 Prices: £234 | £156 members Tuesday 3 December 2019 Webinar
THE TRADE SECRETS DIRECTIVE AND ITS IMPACT ON UK LAW Time: 12.30–13.30 The importance of trade secrets to businesses is widely recognised. The Directive, implemented in the UK in 2018, is designed to improve remedies and procedures in this area. This webinar introduces the Directive and how it has been introduced into UK law. Speaker: John Hull (consultant IP lawyer), CPD: 1; Prices: £72 | £48 CIPA members
INSTITUTE EVENTS
Thursday 5 December 2019 Seminar
WIPO ePCT WORKSHOP Time: from 08.30-16.30 Location: CIPA, London, EC1N 2JD WIPO and CIPA are offering training on WIPO’s online portal ePCT that provides PCT services for both applicants and offices. It allows secure and direct interaction with PCT applications maintained by the International Bureau. It is possible to conduct most PCT transactions via this web-based service, such as filing PCT applications with RO/ IB, EP, IE (as of 9 September 2019) and with over 50 other offices, performing online actions, uploading correspondence, downloading documents, and monitoring PCT applications CPD: 7 Prices: £234 | £156 members) Friday 6 December 2019 Webinar
SECOND MEDICAL USE PATENTS IS THERE A CURE FOR THEIR ILLS? Time: 12.30–13.30
ARTIFICIAL INTELLIGENCE AND PATENTABILITY AT THE UK-IPO Time: 12.30–13.30 Join Russell Maurice and Stephen Richardson as they walk through the UK-IPO’s approach to assessing the patentability of Artificial Intelligence under the exclusions of section 1(2) of the Patents Act 1977. They will set out the principles and guidance that examiners at the UKIPO must follow, and they will use this to indicate what is likely to be allowable and what is not, before summarising the latest information on AI and ownership. Speakers: Russell Maurice and Stephen Richardson (UK-IPO) CPD: 1; Prices: £73.20 | £49.20 members
A look at some recent UK and EPO case law in the pharmaceutical field, in particular in relation to new medical uses and dosage regimens, and consider whether these will make it more difficult to obtain and enforce such patents in the future. Speaker: Julia Florence (CIPA President) CPD: 1; Prices: £72 | £48 CIPA members
Thursday 23 January 2020 Regional Meeting
MERSEYSIDE MEETING Thursday 12 December 2019 Regional Meeting
WALES MEETING Time: from 12.30 Location: Clayton Hotel, Cardiff CF10 1GD Join CIPA for the annual Wales Meeting. Don’t miss your chance to gain 3.5 hours of CPD. plus excellent networking opportunities – including a drinks reception. See the full programme online. CPD: 3.5 Prices: £234 | £156 members
Volume 48, number 11
Thursday 9 January 2020 Webinar
Time: from 12.30 Location: Hard Days Night Hotel, 41 North John Street, Liverpool, L2 6RR Come and join CIPA at the Merseyside Regional Meeting 2020. There will be a range of speakers giving talks on different aspects of IP as well as a great networking opportunity after the event. See the full programme online. CPD: 3.5 Prices: £238.80 | £159.60 members
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IP INCLUSIVE
PERSONAL
IP Inclusive update By Andrea Brewster OBE
IP Inclusive Week We’ve had some fabulous events in the last few weeks – on social mobility, bisexuality, inclusive leadership, flexible working and mental health, not to mention a packed drinks reception after CIPA Congress and hopefully, by the time you’re reading this, a celebration of Diwali and Hanukkah by our BAME community IP & ME. Now it’s time to start work in earnest on our plans for #ipinclusiveweek. What will you be doing, between 11 and 17 November, to promote diversity and inclusion in the IP professions? We’ve posted some ideas on our dedicated web page (www.ipinclusive.org.uk/ip-inclusiveweek) and we’d love to share yours there too. We also have a few things of our own planned, including a fascinating Women in IP discussion on “Navigating a nonlinear career” (London, 11 November; all genders welcome); a first event for our new Midlands network, with a social mobility theme (Birmingham, 13 November); and the launch of our fifth networking and support community IP Ability, for disabled people, their carers and their allies.
topics including personal resilience, workplace banter, coaching and inclusive leadership. We hope that for people who were planning to come into London specially for the annual meeting, the additional CPD content will make the trip more worthwhile, as well as providing inspiration for our 2020 plans. The date is Tuesday 21 January 2020; again you can register via our Events page.
IP Inclusive resources Recently added to our website Resources page is a link to our very first podcast, “Demystifying coaching”. Development coach and former patent attorney Karen Crawley gives us an inspiring insight into the what, how, who and why of coaching and its potential value to IP professionals. Recordings of our 1 October webinar on
inclusive leadership and our 8 October panel discussion on flexible working are also available from the Resources page.
Not just for London… As requested at our annual meeting last January, we’ve organised plenty of webinars this year, and also tried to establish regional networks and run more non-London events. We’re hugely grateful to CIPA for hosting the webinars, and to the CPD team for helping to organise them. We’re on the lookout now for firms who can help share that burden by allowing us access to their webinar broadcasting platforms: please let us know if you can help. We’d also love to hear from you if you’re interested in setting up a new regional network where you’re based.
IP Inclusive is open to all IP professionals and those who work with them. For more information, visit our website, www.ipinclusive.org.uk; follow us on Twitter (@IPInclusive, @bameipinclusive, @ip_out, @WomeninIPI, @CareersInIdeas) or join one of our LinkedIn® groups. And if you’re interested in getting involved, please contact contactipinclusive@gmail.com
Other events Following IP Inclusive Week, we’ve a seminar/workshop on the benefits and challenges of diversity data gathering (Gloucester, 5 December). We’ll also be contributing to a webinar on mental wellbeing, for CIPA paralegals, on 22 November. There are more details and registration links on our website Events page. Excitingly, our annual meeting next year will form part of a full-day conference, with workshops on a range of diversity- and inclusion-related 58 CIPA JOURNAL
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To keep abreast of everything we’re doing, join our mailing list: there’s a “Stay in touch” form on the website.
Books for review We have some books for reviewing in the CIPA Journal. If you are interested in writing a review please contact editor@cipa.org.uk. The titles we have include: • •
Technology Transfer, (Bloomsbury Professional) 4th edition. IP, Climate Change and Technology (Edward Elgar)
www.cipa.org.uk
OU T S O ON
CIPA Guide to the Patent Acts 9th edition Editors: Paul Cole, Patent Attorney, Lucas & Co.; Richard Davis, Barrister, Hogarth Chambers
Hardback ISBN: 9780414073920 December 2019 £295
The CIPA Guide to the Patents Acts, 9th edition, by The Chartered Institute of Patent Attorneys brings together the expertise of over 30 highly respected professionals including patent attorneys, solicitors and members of the Bar, all individually selected for their expert knowledge.
ORDER TODAY sweetandmaxwell.co.uk +44 (0)345 600 9355
The new edition offers coverage of legislative and jurisprudence developments to end of July 2019 and notable cases including Actavis v ICOS, Warner-Lambert v Generics, Garmin (Europe) v Koninklijke Philips, Regen Lab v Estar Medical and more. It features analysis of the latest cases applying the doctrine of equivalents since the landmark decision in Actavis v Eli Lilly and of SPC developments including the new SPC regulation and relevant UK and CJEU decisions. The impact of Brexit is discussed as also are US patent eligibility decisions insofar as they affect European applicants.
Also available on Westlaw UK and as an e-book on Thomson Reuters Proview™
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SWEET & MAXWELL
THE PINKS
COURSES • SUPPORT
JDD CONSULTANTS EQE 2020 REVISION COURSES 19 NOVEMBER – 3 DECEMBER 2019 We have a full set of residential revision courses for the spring 2020 European Qualifying Examinations (EQE). Our Pre-Exam course is on 2-3 December 2019. Our courses for Papers A&B, C and D are on 19-29 November 2019. We have added extra Paper C and Papers A&B courses on 19-20 and 21-22 November. You can book a course for one paper, several papers or all – as desired. The courses are in Milton Keynes and are supported by our online Moodle resources forum. The course fee includes accommodation and meals, but there are discounts if accommodation is not needed and for bookings of a suite of courses and/or the booking of five or more courses by a firm. For further information, a leaflet and online booking, please visit www.jddcourses.co.uk or phone us at 01234 294049 / 07791 959630 • We are a CIPA Approved Training Provider. E-mail: jdd.consultants@ntlworld.com / admin@jddcourses.co.uk • Fax: +44(0)800 0664016
PATENT TRANSLATING Since 1997 we have specialised in providing translations for patent and trademark attorneys, with meticulous attention to detail and ensuring the correct terminology, in the right format for filing anywhere in the world. To achieve this, our specialist translators include former patent agents who only translate into their mother-tongue, with all assignments being proofread before delivery. Areas of expertise: Aeronautical • Automotive • Bio-chemical • Chemical Computing • Electrical • Electronic • Mechanical Pharmaceutical • Telecommunications
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Training Training for the EQE Dates: Dates: 11-12 11-12November November 2019 2019 6-8 6-8January January 2020 2020 Venue: Venue:De DeVere VereGrand Grand Connaught Connaught Rooms 61-65 5DA 61-65Great Great Queen Queen St, St, London WC2B 5DA
Areyou youtraining trainingto tobe beaaEuropean European Patent Patent Are Attorney?Are Areyou youpreparing preparingto totake take the the EQE EQE Attorney? in Spring 2020? Support your studies by in Spring 2020? Support your studies by attending our preparatory course, learn from attending our preparatory course, learn from experienced practitioners and previous experienced practitioners and previous candidates, and network with fellow candidates, and network with fellow professionals. professionals. This course is for candidates preparing for This is for candidates thecourse main papers (A, B, C and preparing D) of the for the main papers (A, B,Examination C and D) of (EQE) the European Qualifying European Qualifying Examination (EQE) RI WKH (XURSHDQ 3DWHQW 2IÀFH ,W LV RI WKH (XURSHDQ 3DWHQW 2IÀFH ,W LV VWUXFWXUHG LQ WZR SDUWV DQG UHÁHFWV WKH VWUXFWXUHG LQ WZR SDUWV DQG UHÁHFWV WKH practical nature of the examinations. practical of the examinations. Bookingsnature are now accepted for the EQE training Bookings for Parts 1 and areboth nowPart accepted. programme. Registration2for 1 and Part 2 is compulsory.
Why Why book book Queen QueenMary MaryUniversity UniversityofofLondon’s London’s course? course? • In-depth study of previous EQE papers in small • In-depth study of previous EQE papers in small groups and with highly experienced tutors. groups and with highly experienced tutors. • The course is continuously adjusted to the • The course is continuously adjusted to the changing requirements of the examination and changing requirements of the examination and the profession. the profession. • Queen Mary University of London has nearly • 30 Queen Mary University of London has nearly years’ experience running this programme 30 years’ experience runningsupervision. this programme and provides close academic and provides close academic supervision. • The pass rates of Queen Mary University of • London The pass rates candidates of Queen Mary Universityinof trained are generally Londonoftrained excess 95%. candidates are generally in excess of 95%. For more information and to register please go to For more information and to register please go to www.ccls.qmul.ac.uk/events www.ccls.qmul.ac.uk/events
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