THE COMMENCEMENT OF THE INTELLECTUAL PROPERTY LAWS

By:
Mrs. NAILA SABIR KHAN,
LLM, Advocate High Court
Part-time Lecturer,
BZU, Gillani Law College, Multan

Intellectual property law rights strain the principles of conservative jurisdiction and the test the existing tenets of law. The intangibility of these rights leads to their own peculiar difficulties in creation and enforcement. A right in immoveable is normally a perpetual right. Intellectual property rights however, have their own different periods of existence. Immortal writers, poets or artists have limited periods of rights in their works. Once their rights fall in the so-called 'Public Domain', others equipped with infrastructure (i.e. deep pockets) can exploit these rights to the hilt. There are many theories with regard to the nature of legal rights.

(1)  Austin, Holand, Pollock, Vinogradoff and others are the exponents of the will theory. According to this theory, a right is an inherent attribute of the human will. The subject matter of a rights is derived from the exercise of a human will. The will of theory was inspired and extended by the doctorine of natural rights. It is the function of law to confer certain powers or allow certain freedom to individuals in the form of legal rights. A legal rights a power conferred of law. According to Justice Halmes, a legal right is "nothing but a permission to exercise certain natural powers and upon certain conditions to obtain protection, restitution or a compensation by the aid of public force". Again, "legal right is the power to removing or enforcing legal limitations on conduct". According to Puchta, a legal rights is a power over an object which by means of this rights can but subjected to the will of the person enjoying the right. According to Holland, a legal rights is "the capacity residing in one man of controlling with the assent and assistance of the state, the action of others".

(2)  Another theory is known as the interest of theory of rights, hearing is the greatest advocate of this theory and man English and American writers have followed him. According to Ihering: "A legal right is a legally protected interest." Ihering does not put stress on the element of will in a legal right. On the other hand, he puts emphasis on the material element of interest. The basis of right is not but interest. According to Buckland, a legal right is "an interest or an expectation granted by law". According to the Salmond, a legal right is "an interest recognized and directed by a rule of right". Paton defines a legal right in terms of recognition an protection by the legal order.

As against this, trade marks, which are basically concerned with business, have a perpetual existence and may continue to exist for centuries. The period of monopoly in patents is also being enlarged gradually. These developments are not necessarily the result of a planned legislation.

At present, the field of the intellectual property rights legislation is in state of constant turmoil. Not only in Pakistan, but all over the world, the legislatures are trying to grapple with the more and more complex fields of intellectual property rights like biotechnology, Information Technology, Plant Varieties, Geographical Indications, etc. With Pakistan Joined the World Trade Organization, there is a sudden flurry of activity in the filed of intellectual property legislation. The existing laws have either been replaced, as in the case of trade marks and designs, or substantially amended like copyrights and patents, New rights such as rights in geographical indications, plant varieties and farmers rights, rights in layout-designs of semiconductor integrated circuits etc, are being recognized and codified. There is also concerted effort to extend the effectiveness and enforceability of the intellectual property rights beyond the internal territories by joining international treaties.

Although various intellectual property rights are discernible as separate rights, these cannot be divided or compartmentalized. All these rights require a totalistic approach. Many of these rights and principles for recognition and enforcement of these rights are similar and interrelated. In many cases, there is an overlapping of rights for example, a trade mark may be registered under the provisions of the trade mark law; while, at the same time, such trade mark can be registered as an artistic work under the provisions of the copyright law.

There has not been a uniform and unified approach in drafting intellectual property rights legislation. The recent intellectual property rights legislation in the Pakistan has involved by fits and starts, more in response to the onslaught of technology and ever-increasing need to protect economic interests. It has not been a planned exercise. In my opinion, it is necessary for the legislature to have a unified and uniform approach while drafting intellectual property legislation. The establishment of intellectual property rights authorities, under superintending administration and enforcement of intellectual property rights. The concepts in the intellectual property rights require constant reappraisal and continuous monitoring. There is always a tendency to accept the law and the dead ends in law as final. I have always believed that a healthy disrespect for law is essential for the growth of law. In view of the intellectual property rights now being relegated to the status of "Trade Related Intellectual Property Rights” and the struggle to establish a balance between protection of these rights and rights of societies, conflicts of interest will raise new challenges for the judiciary. In the areas of compulsory licensing of intellectual property products, protection of biodiversity, plaint varieties or interpretation of comparative legislations, the Courts will have a substantial role to play. The ethos and leanings of the judiciary in these areas will vitally affect the administration of intellectual property rights.

The right to trade mark is common law right. An owner of a trade mark can always protect such right independent of any Statutory provision. Before the Trademarks Act of 1940, the Specific Relief Act of 1877, recognized trade mark as a right to property.

Section 54 of the Specific Relief Act, 1877 dealt with cases in which perpetual injunction could be granted. The explanation to that provided that, for the purpose of S. 54, a trade mark was a property. Therefore, if a trade mark, the Court under S. 54 had the discretion to grant a perpetual injunction at par with any other kind of property.

In Pakistan the first enactment on the subject of trade marks was the Trade Marks Act, 1940 (Act V of 1940). And thereafter the Trade Mark Ordinance, 2001 was promulgated likewise the Merchandise Mark Act, 1889, the Trade Marks (Invalidation and Summary Registration Act, 1950 were also made in enactment). The Patent and Designed Act, 1911 was repealed and presently the patents Ordinance, 2000 does exists the Copy Right Ordinance, 1962 alongwith the Copy Right Rules, 1967 have come into force. The Courts have however always kept in mind the independent nature of rights in trade mark.

To any mind, it is clear that even prior to the passing of the Act the owner of a trade mark could maintain an action for infringement of a trade mark and that action could only be maintained on the assumption that he was the owner of the trade mark, he had proprietary right in the trade mark.

A trader acquires a right of property in distinctive mark merely by using it upon or in connection with his goods irrespective of the length of such user and the extent of his trade.

It was also necessary to take into account the effect of various important judicial pronouncements and simplify the procedures. It was felt that it was necessary to take a comprehensive review of the existing law to bring the trade marks law in Pakistan at par with other comparative enactments.

The Intellectual Property Organization of Pakistan Ordinance, 2006 was came into force in Pakistan and this organization got control over the all intellectual property laws in Pakistan.

Powers and functions of Organization:--The powers and functions of the organization shall to be to:--

(a)     administration and coordinate all Government systems for the protection and strengthening of Intellectual Property Rights under the laws specified in Schedule and the rules and the regulations made thereunder;

(b)     prescribed, regulate or implement measures and standards on any matter related to or connected with intellectual property rights;

(c)     accredit or certify and regulate any person as intellectual property agent;

(d)     levy such charges or fees as may be reasonable for services and facilities provided by the Organization and its constituent offices;

(e)     carry out such other works or activities as may be deemed by the Organization to be necessary, with a view to making the best use of the assets of the Organization;

(f)      coordinate, monitor or engage, in conjunction with other authorities, international agencies or Organizations, in any study or corporation project related to intellectual property;

(g)     enter into a contracts for the supply of goods or materials or for the execution of works as may be functions;

(h)     supervise and coordinate the working of all intellectual property offices including the Patent Offices, Trade Marks Registry and Copyright Office;

(i)      evolve and maintain a system to provide access to public documents and information relating to any intellectual property kept or maintained by the Organization;

(j)      advise the Government of Pakistan on Policy relating to intellectual property rights;

(k)     plan for development and up-gradation of the intellectual property infrastructure and capacity and in Pakistan;

(l)      promote education and research in the field or intellectual property;

(m)    advise the Federal Government regarding the international negotiations in the area of intellectual property;

(n)     engage in human resource development of its officers and staff;

(o)     promote awareness about intellectual property issues in public and private sector;

(p)     liaise and interact with counterpart Intellectual Property related organizations in other countries for capacity building and exchange of information;

(q)     propose and initiate intellectual property rights legislation for the protection of intellectual property rights in Pakistan.

(r)      Initiate and monitor the enforcement and protection of intellectual property rights through designated law enforcement agencies of Government and collect related data and information. The law enforcement agencies shall keep the Organization regularly and appropriately informed of their actions and operations against violations of intellectual property rights and ensures full liaison and cooperation with the organization;

(s)      Develop working manuals references, materials and procedures in order to assist in improving the protection of intellectual property rights;

(t)      Coordinate the implementation of foreign-aided technical assistance projects on intellectual property; and

(u)     perform and carry out any other act, thing or function relating to intellectual property assigned to it by the Board or the Federal Government;

The objects of the Trade Marks laws should be the followings:--

(a)     To provide for registration of trade mark for services in addition to goods;

(b)     To refuse registration of trade marks which are an imitation of well-known trade marks besides enlarging the grounds for the refusal of registration;

(c)     To amplify the actors to be considered for defining a well-known mark;

(d)     To do away with the system of maintaining registration of a trade mark with different legal rights and to provide only a single register for simplifying the procedure for registration and with equal rights;

(e)     Simplify procedure for registration by registered user and enlarging the scope of permitted use;

(f)      Provide for registration 'collective marks' owned by association etc;

(g)     Provide for an appellate Board for the speedy disposal of appeals rectifications and applications which at present lie before the High Courts;

(h)     Transfer the final authority relating to registration and certification of trade marks to the registrar instead of the Central Government;

(i)      Provide for enhancement of punishment for offences relating to trade marks as compared with the present Copyright Act to prevent sale of spurious goods;

(j)      Prohibit the use of someone else's trade mark as part of the copyright names or name of business concerned;

(k)     Explain the obligation of a convention country to include countries which are members of a group or union of countries and inter-Governmental organizations;

(l)      Incorporate other provisions like amending the definition of trade mark; provision of filing a single application for registration in more than one class and increase the period of registration, and renewal from 7 to 10 years; making trade mark offences cognizable; enlarging the jurisdiction of Courts to bring the law in this respect on par with copyright law; amplifying the powers of the Courts to grant ex parte injunction in certain cases and other related amendments; simplifying and streamlining the trade marks law and procedure.

A trade mark is usually associated with goods, trading style etc.
Several judicial decisions have extended the principles of trade marks law to include websites on the internet also. With the advent of the Internet, there is a spree of registering domain name for the purpose of business. As a website has a universal presence the reach of a domain name is universal. An attempt of a domain name or domain name on the Internet.

In a case the dictum laid down by Indian Court in "Yahoo Inc V Akash Arona", the Delhi High Court rejected this argument. It was found that although the word 'services' was not used in Ss. 27 and 29 be recognized for an action of passing off. It was held that `Yahoo' which was the domain name of the plaintiff and `Yahoo India', the domain name of the defendants, were similarly except for the use of suffix 'India' in the domain name of the defendants. The argument was advanced that Internet users were sophisticated users and as such, there was no possibility of such intelligent user being confused. This contention was rejected by the Court of observing that, even if an individual is a sophisticated user of the Internet, he may be an unsophisticated consumer of information as such, such a person may be misled by the use of a similarly domain name. Thus, a person intending to visit the site of the plaintiff would land on the site of the defendant.

In Rediff Communicatins Ltd V Cyberbooth and Anor7, the Bombay High Court held that domain names 'Rediff’ and 'Radiff’ were similar. It was sought to be contended by the defendants that the word 'Radiff’ was derived from four words namely Radical Information, Future, and Free. The High Court rejected the explanation as completely false and held that it was impossible to held that the word 'Radiff’ was coined by the defendant as an abbreviation of the aforesaid words. The High Court observed:-

What emerges from these authorities is that the Internet domain names are all important and get a valuable corporate asset. Domain name is more that a Internet Address and is entitled to equal protection of trade marks. With the advancement and progress in technology, the services rendered in the Internet site are accepted and are being given protection so as to protect all such providers of services from passing of services rendered by others as his services.

Ss. 2(1)(f), 6(1)(a) & 14(1). Trade mark. Registration. Refusal to Register Trademark Logo. Logo adopted by the party was composite and compound mark, with particular get and colour scheme, with combination of company name placed in a particular manner. Contention of the party was that the logo fulfilled the definition of mark as provided under S. 2(l)(f) of the Trade Marks Act, 1940. Validity. Any person claiming to be proprietor of a mark used or proposed to be used by him might apply for registration under S.14 of Trade Marks Act, 1949. Validity. Any Person claiming to be proprietor of a mark used or proposed to be used by him apply for registration under S.14 of Trade Mark Act, 1940. Requirement for registration of Trademark under S.6(l)(a) of Trade Marks Act, 1940 was that the same might contain name of the company, individual or a firm represented in a special particular manner. Where the logo/mark was combination of the name of the party inscribed in the logo / mark in a particular manner, the same was in accordance with the definition of the word 'mark' as defined under S.2(l)(f) of the Trade Marks Act, 1940, and was applicable to the logo/mark applied for. Discretion exercised by the Registrar in declining registration of logo/mark was against the set principles of law applicable thereto and the order passed by the Registrar was set aside. CLD 2002 Karachi 37(f)

Ss. 6(1) & 14 Trade Mark application for registration. Mark to be registered must be in use anterior to making of application. Any person claiming to be proprietor of trade mark, used or proposed to be used by him is entitled to apply for the registration of the same. Not merely a mark must be in use anterior to making of application but any proposed user thereof gives a right to the intending user to apply for the registration of a particular mark proposed to be adopted by him, provided the mark is otherwise qualified to be registered under the provisions of Trade Marks Act, 1940. CLD 2002 Karachi 37(c)

Ss. 6(1)(a) to (e) & 14(1). Discretion of Registrar of Trade-Marks Act, 1940, Registration of Trade Mark. Exercise of such discretion. Principles. Discretion vesting in the Registrar under S. 14(1) of Trade Mark Act, 1940, is not arbitrary or fanciful, but a judicial one is which must be exercise fairly, equitably, with vigilance circumspection, care and caution based on cogent, coined and supportive reason in accordance with set principles of law, Mere bald statement that a particular order has been passed because a discretion vests in the authority is nothing but erroneous exercise of discretion liable to be corrected and reviewed, whenever it comes under judicial scrutiny CLD 2002 Karachi 37(e) . S. 14— "Passing off”—Connotation—Factors to be proved—When people use goodwill of companies' business and their products that they have worked their way to the top in order to sell their wares, these reputable establishments are deprived of their rightful benefits—People use trade marks similar to ones used by those well-known companies, thereby confusing the customer and inducing him to buy their wares—Such acts attract the doctrine of passing off— Ingredients that have to be established in a successful action of passing off stated. [Sayyed Engineering Vs. Tristar Industries (Pvt.) Ltd. (Anwar Mansoor Khan, J)] 2001 CLC 1368(d).

S.14—Proprietary rights, infringement of-passing off- Proof -Test to be applied in matters of passing off is as to whether a man of average intelligence and of imperfect recollection can be confused. [Sayyed Engineering Vs. Tristar Industries (Pvt.) Ltd. (Anwar Mansoor Khan, J)] 2001 CLC 1368(i) 2001 CLC 1368(i)

Ss. 76, 10(4), 14(1) r/w S.10(1) and 8(a). 15(1) - Trade Mark Rules, 1963, Rr. 23 and 24--General Clauses Act, 1897, S. 24—Show Cause notice - in the instant case, Registrar has refused acceptance of an application u/S. 14(1) of the Act, 1940 without advertisement of that application — At the same time another application for registration of mark "Nobel" was advertised—Reason forwarded day representatives of the Trade Mark Registry was that the present appellant was simply "the proposed user" which the other applicant was user of that mark - This was a correct classification but in order to exercise discretion more judiciously, it would have been advisable to get the same advertised - It was well-known maxim of law that justice should not only be done but it should be seen to have been done—It is not on record as to what was the fate of the other application for the same mark - For the sake of arguments. If it is presumed that the said application was accepted them there remain no justification for refusing the advertise the application filed by the applicant - It is settled law that all applications pertaining to similar and identical marks of the same class are to be dealt with jointly—- This may be done to avoid any conflicting decisions - in consonance with the above view, this appeal is accepted and the matter is remanded to the Registrar to deal with it according to law and after advertisement - appeal accepted. 2000 PCTLR (Kar) 431

Ss. 10 and 14 -- Civil Procedure Code, 1908, O, XXXIX, Rr. l and 2—Interim injunction, graft of — Proprietary Rights, infringement of — Unregistered trade mark — Dispute was with regard to use of word 'Crystal' on bail pens manufactured by the parties — Plaintiffs claimed to be the prior user of the word 'Crystal' on his product - Contention of the defendant was that the word 'Crystal' only described the pen and the same was common to trade --- Validity -- Continuous use of a mark over a length of time did not characterize the word as used by the user, and was in the mind of the public as identifying them that the product was that of person using the same regular as such it was misconceived that because the word was used on a transparent pen, it described the pen and because of the that reason all could use the word—Such act would amount to infringing upon the right and goodwill created by the user word - Subsequent user, in such a case would be trying to cash upon the reputation attached to the product of the manufacturer using the word and the same would amount to misrepresentation and there was likelihood of damage being suffered by such use to the previous user — Where, notwithstanding the transparency, the look, the design and/or other marked features of the pen, which might be descriptively similar, use of the word 'Crystal' could disclose no other intention of the defendants accept to pass off their goods as the goods of the plaintiff - Even if the defendants were manufacturing a transparent/clear ball point pen, it could not be said that the same would be descriptive of the pan, as the plaintiff over the years started use of the word "Crystal" and the plaintiff over the years had acquired, by advertisements and otherwise reputation, goodwill and the said word therefore, would be deemed to be in the mind of the public, as a product of the plaintiff —- Defendant, in the present case, would not be entitled to mark their product by describing the same as "crystal" — Plaintiff has made out a strong prima facie case - By the use of the word "Crystal" the defendants had committed an actionable wrong of passing off injuring substantially the reputation and goodwill of the genuine user of the word "Crystal and the same would amount to misrepresenting their product as the product of the plaintiff and would also, therefore, amount to damaging their goodwill - Interim injunction was granted in circumstances. 2001 CLC 1368(f)

—Ss. 10 and 14 —- Proprietary Rights — Proof of -- Excusive prior use of mark was sufficient to cause proprietary rights to be created. 2001 CLC 1368(e)

Authority while refusing registration failing to consider that applicant being proprietor of the registered trade mark for his other goods of same description was entitled to have his registered as an associated trade mark. Order of nonregistration of applicant's trade mark was set aside and Authority was directed to reconsider case on basis of his entitlement to get registration of mark as an associated trade mark. PLD 1992 (c) Kar. 119

Registration of Trade Mark "Hudson" refused. Validity. Word "Hudson" did not appear to be caste of any person in the telephone directory. Word "Hudson" was not geographical name of any place or river in Pakistan. Objection against registration of Trade Mark "Hudson" by Registrar was thus, misconceived. Registrar was directed to proceed with application of applicant for registration of Trade Mark "Hud son" in accordance with law. PLD 1992 Kar 119

Registration of Trade Mark "Tip Top" was declined by Registrar, ground for refusal being that the mark sough to be registered, was similar if compared as a whole to the already registered trade marks "Top" and "Tip Job". Validity. Application for registration of trade mark having been rejected at a preliminary stage, without issuing any notice to proprietors of trade marks concerned whose trade marks were deemed to be similar to the trade mark applied for, order of rejection was set aside. Applicant's case was directed to be processed and due notices to be issued to concerned persons whose trade marks already registered, were deemed to be similar to be similar to the trade mark applied for, and decision to be taken in accordance with law. PLD 1992 Kar 15.

Applications for registration of trade marks: For the purposes of the Act, goods are classified into 34 classes. These goods are again divided into textile and non-textile goods. Textiel goods are those which fall under classes 22 to 27 (inclusive)—(see Rule 38 read with sec. 62 of the Act.)

In the case of non-textile goods it does not matter what the mark is, whether it is a device, numeral, letter or word, or any other combination, the application has to apply on Form TM-1.

When, however, the goods are textile goods, the form of application varies according to the nature of the trade mark. The Textile mark may be —

(1)     a word or words (not being an invented word or invented words);

(2)     a mark consisting of letters or numerals or any combination thereof; and

(3)     other marks such as a device or invented word or invented words.

In each of the above there is a separate form for application. In the case of marks consisting exclusively of a word or words (not being an invented word or invented words) the application is to be made on Form TM-51. Where the trade mark consists exclusively of letters of numerals or any combination thereof the application has to be made on Form TM-53 or on Form TM-52 according as the goods fail in the Fifth Schedule of the Rules or not, if the goods fail under the Fifth Schedule, the applcaiton should be made on Form TM-53. if the textile goods do not fall under the Fifth Schedule, the application should be made on Form TM-52. in the case of marks comprising a device or an invented word, the application has to be made on Form TM-2.

Main criterion for registration of a trade mark, would be that an unwary purchaser should not be led to belief that goods of persons seeking registration and those of objector come from the same source and belonged to the same origin. 1988 CLC 1636

The Registrar of Trade Mark, could not delegate his power to Examiner of the Trade Marks. Examiner of the Trade Marks can examine applications for registration to see whether they qualify for registration under the provisions of the Act and Rules, such functionary also assists Registrar in all procedural, administrative and supervisory functions connected with various proceedings under the Act and the Rules. 1987 MLD 1415

The appellant seeking registration of the Trade Mark "Air Prince" for its electric fans. The respondent asserting that it had been using its mark "Prince" in respect of all sorts of fans manufactured by its since 1965 and had procured registration of the said trade mark in 1971. Income-Tax assessment orders showing that the respondent had been regularly paying income-tax which ran into lakhs of rupees while appellant not paying any income-tax. The respondent him found doing good amount of business of manufacturing and marketing fans under the Trade Mark "Prince" and were entitled to hold the field. It was held that:

The appellants's trade mark would certainly cause confusion and deception as the goods were to be sold on the same counter. View formulated by the Registrar that the word "Air" was descriptive of goods, therefore, could not be take exception to. Decision of the Registrar endorsed and appeal dismissed. 1988 CLC 1991

Although goods required to be registered fall in different classes that those produced by objectors but possibility of objectors producing goods sought to be registered could not be ruled out. 1988 CLC 1636

The petitioner's application for registration of the Trade Mark having been consigned to record, constitutional petition against such consignment filed after about 4 years, held, suffered from the inordinate laches and was not maintainable. 1987 MLD 2827

The application for registration of Trade mark refused by Examiner of Trade Marks who had no jurisdiction in the matter. The order of refusal passed by Examiner set aside and proceedings allowed to continue according to law. 1987 MLD 1415

The Registrar while refusing applications of appellant neither communicating objections to the appellant nor hearing him. The Registrar, violated mandatory provision of law. Order of the Registrar set aside and the case remanded to the Registrar with direction to process application in accordance with law. 1986 MLD 2966

Applications dealt with in the Registry: when an application for registration has been made, it is first examined in the Trade Marks Registry. In the first place the application examined in order to see whether the formalities have been observed. The name of the applicant must be stated in a precise manner. If the applicant is the sole proprietor of the trade mark, he should state his name and address on the application. If the application is made on the behalf of a firm, all partners, names should be given in the application together with the address of the firm. When the applicant is a corporation, the application should be signed by a Director or any other principal officer of the company. If the applicant lives outside Pakistan, he should state his address for service in Pakistan. Where the applicant has appointed a lawyer or a registered trade marks agent, the application may be signed by such agent and such agent should forward his authorization of Form TM-48. The applicant must also give his description, i.e. whether he is a manufacturer or an agent who sells only, etc.