FEDERAL COURT OF AUSTRALIA
DC Comics v Cheqout Pty Ltd [2013] FCA 478
Citation: DC Comics v Cheqout Pty Ltd [2013] FCA 478 Appeal from: DC Comics v Cheqout Pty Ltd [2012] ATMO 64 Parties: DC COMICS v CHEQOUT PTY LIMITED
(ACN 124 830 726) and REGISTRAR OF TRADE MARKSFile number(s): NSD 1145 of 2012 Judge: BENNETT J Date of judgment: 22 May 2013 Catchwords: TRADE MARKS – appeal from decision of the delegate of Registrar of Trade Marks allowing registration of applicant’s mark – whether trade mark is deceptively similar to respondent’s mark – whether application to register trade mark made in bad faith Legislation: Trade Marks Act 1995 (Cth) ss 43, 60, 62A Cases cited: Allergan Inc v Di Giacomo (2011) 199 FCR 126 cited
Berlei Hestia Industries Ltd v The Bali Company Inc (1973) 129 CLR 353 cited
Commissioner of Patents v Sherman (2008) 172 FCR 394 cited
Fry Consulting v Sports Warehouse Inc (No 2) (2012) 201 FCR 565 followed
Fry Consulting Pty Ltd v Sports Warehouse Inc (No 1) [2011] FCA 1417 citedMerck & Co Inc v Sankyo Co Ltd (1992) 23 IPR 415 cited
Radio Corporation Proprietary Limited v Disney (1937) 57 CLR 448 discussed
Re Application by Pianotist Company Ltd (1906) 1A IPR 379 applied
Registrar of Trade Marks v Woolworths Limited (1999) 93 FCR 365 applied
Smith Hayden & Co Ltd’s Application (1946) 63 RPC 97 cited
Southern Cross Refrigerating Company v Toowoomba Foundry Pty Ltd (1953-1954) 91 CLR 592 applied
Sym Choon & Co Ltd v Gordon Choons Nuts Ltd (1949) 80 CLR 65 citedTorpedoes Sportwear Pty Ltd v Thorpedo Enterprises Pty Ltd (2003) 132 FCR 326 cited
Date of hearing: 30 January 2013 Date of last submissions 30 January 2013 Place: Sydney Division: GENERAL DIVISION Category: Catchwords Number of paragraphs: 78 Counsel for the Applicant: Mr R Webb SC Solicitor for the Applicant: Baker & McKenzie Counsel for the First Respondent: The first respondent did not appear Solicitor for the Second Respondent: Mr N Gouliaditis of Australian Government Solicitor
IN THE FEDERAL COURT OF AUSTRALIA
NEW SOUTH WALES DISTRICT REGISTRY
GENERAL DIVISION
NSD 1145 of 2012
ON APPEAL FROM THE REGISTRAR OF TRADE MARKS
BETWEEN: DC COMICS
ApplicantAND: CHEQOUT PTY LIMITED (ACN 124 830 726)
First RespondentREGISTRAR OF TRADE MARKS
Second Respondent
JUDGE:
BENNETT J
DATE OF ORDER:
22 May 2013
WHERE MADE:
SYDNEY
THE COURT ORDERS THAT:
1.The appeal from the decision of the delegate of the Registrar of Trade Marks be allowed.
2.The decision of the delegate of the Registrar of Trade Marks be set aside.
3.The application to register “superman workout” be refused.
Note:Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
IN THE FEDERAL COURT OF AUSTRALIA
NEW SOUTH WALES DISTRICT REGISTRY
GENERAL DIVISION
NSD 1145 of 2012
ON APPEAL FROM THE REGISTRAR OF TRADE MARKS
BETWEEN: DC COMICS
ApplicantAND: CHEQOUT PTY LIMITED (ACN 124 830 726)
First RespondentREGISTRAR OF TRADE MARKS
Second…
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- AGLC
- DC Comics v Cheqout Pty Ltd [2013] FCA 478
- Case
- [2013] FCA 478
- Decision Date
CaseChat Overview and Summary
The central legal issues were whether Cheqout's trade mark was deceptively similar to DC Comics' marks and whether the application was made in bad faith. The Court had to consider the notional use of the trade mark and whether there was a real danger of confusion. It also had to examine the extent of protection afforded to unregistered marks and whether the unregistered "superman" word mark was associated with the Superman character to the exclusion of other meanings.
The Court found that the Registrar's decision should be given weight, but not presumed correct. The Court noted that the Superman character was well known and recognised, and the word "superman" was intrinsically connected to the character and the associated indicia. However, the word "superman" has entered the language to connote more than just the superhero. The Court found that while consumers may associate the word "superman" with the character, they would not necessarily associate the word with DC Comics' marks when used in conjunction with fitness services. The Court concluded that there was no real danger of confusion and that the application was not made in bad faith.
The Court allowed the appeal, set aside the Registrar's decision and refused the registration of "superman workout". The Court held that the unregistered "superman" word mark was not associated with the Superman character to the exclusion of other meanings and that the notional use of the trade mark did not give rise to a real danger of confusion. The Court also found that the application was not made in bad faith.
The Court's decision highlights the importance of considering the notional use of a trade mark and the extent of protection afforded to unregistered marks. It also emphasises the need to examine the association between a word and a character or indicia, and whether that association is exclusive. The decision provides guidance for parties seeking to register trade marks that may be deceptively similar to existing marks or that may be associated with well-known characters or indicia.
Orders
Orders of the court
1. The appeal from the decision of the delegate of the Registrar of Trade Marks be allowed.
2. The decision of the delegate of the Registrar of Trade Marks be set aside.
3. The application to register “superman workout” be refused.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Other relevant considerations for the purposes of s 60 of the Act are set out in Torpedoes Sportwear Pty Ltd v Thorpedo Enterprises Pty Ltd (2003) 132 FCR 326 at [78]. In particular (citations omitted):·An attempt must be made to estimate the effect or impression produced on and retained by customers and potential customers.·What is to be compared with one mark is the impression based on recollection of the other mark that persons of ordinary intelligence and memory would have.·Consideration is given to the goods to which the marks are to be applied and the nature of the customer, as well as all the surrounding circumstances when the marks are used in a normal way as a trade mark.·It is important to look at the whole of the marks.·Deceptiveness must result but from similarity; a likelihood of deception is judged by the effect of the similarity in all of the circumstances.·The fact that two marks convey the same idea is not sufficient in itself to create a deceptive resemblance between them and a proprietor of the mark is not entitled to a complete monopoly of all words conveying the same idea as that mark. However, the presence of a common idea may be a determining factor because the idea is more likely to be recalled than the precise details of the mark.·Where an element of a trade mark has a degree of notoriety or familiarity, it would be artificial to separate out the physical features of the mark from the viewer’s perception of them. The question of resemblance is about how the mark is perceived.·The comparison is between marks, not uses of marks, although use is not irrelevant as a circumstance. The consideration is not only actual use but also the extent of the statutory monopoly by reference to the full extent of the goods or services in respect of which the mark is registered.CONSIDERATION It must be remembered that DC Comics’ registered trade marks consist of the word Superman together with a device or figure of the superhero or simply of the S Shield Device, but not of the word alone. DC Comics maintains that the public will be misled or confused by use of the word alone. There is no dispute, and no doubt, that Superman the superhero is well known and recognised, by look and by name, to the public at large. Indeed, the superhero and his “get-up” are so famous that they could be said to be instantly recognisable, as is, by name, Superman’s alter ego, Clark Kent. However, the word “Superman” was not invented by the applicant and it is not presently defined by reference only to the superhero. Whether or not an association of the word is with the superhero, the word superman has entered the language to connote more than the superhero. The Macquarie Dictionary provides several relevant definitions of “superman”. The first is a definition which includes the plural “supermen”:1.an ideal human being who by virtue of greater spiritual powers rises above the usual notions of good and evil; conceived by the 19th-century German philosopher Friedrich Nietzsche as the product of human evolution.2. a. a man of more than human powers.b. a man who prevails by virtue of such characteristics.