Hamilton Locke Pty Ltd v Hamilton & Co Legal Pty Ltd
[2024] ATMO 236
•29 November 2024
TRADE MARKS ACT 1995
DECISION OF A DELEGATE OF THE REGISTRAR OF TRADE MARKS WITH REASONS
Re:Opposition by Hamilton Locke Pty Ltd to registration of trade mark application number 2267980 (class 45) - Hamilton Mott - in the name of Hamilton & Co Legal Pty Ltd
Delegate: | Benjamin Goldsworthy |
Representation: | Opponent: Source IP Pty Ltd Applicant: Ryan Maguire, of Counsel, instructed by Louise Emmet from Madderns |
Decision: | 2024 ATMO 236 Trade Marks Act 1995 (Cth) – opposition under section 52 – grounds under ss 42(b), 44, 58A and 60 considered – none established – trade mark may proceed to registration |
Background
On 8 May 2022 (‘Relevant Date’) Hamilton & Co Legal Pty Ltd (‘Applicant’) filed trade mark application 2267980 under the Trade Marks Act 1995 (Cth),[1] details of which are reproduced below:
Priority date: 8 May 2022
Trade mark: Hamilton Mott
Specification: Class 45: Advisory services relating to the law (‘Applicant’s Services’)
[1] A reference in these reasons to a section is a reference to such in the Trade Marks Act 1995 (Cth).
On 8 December 2022, Hamilton Locke Pty Ltd (‘Opponent’) filed its Notice of Intention to Oppose the Trade Mark. On 20 December 2022, the Opponent filed its Statement of Grounds and Particulars (‘SGP’). On 8 February 2023, the Applicant filed its Notice of Intention to Defend.
On 22 May 2023, the Opponent filed its Evidence in Support (‘EIS’) consisting of a declaration of Henry Llewellyn Lloyd, Deputy Managing Partner and co-founder of the Opponent, dated 18 May 2023, with Annexures HL-1 to HL-4 (‘Lloyd’).
On 24 August 2023, the Applicant filed its Evidence in Answer (‘EIA’) consisting of a declaration of Jock Hugh Hamilton, sole director and Principal lawyer of the Applicant, dated 24 August 2023, with Annexures JHH-1 to JHH-13 (‘Hamilton’).
The Opponent filed no Evidence in Reply.
On 20 November 2023, the Opponent requested to be heard by written submissions. On 23 November 2023, the Applicant requested to be heard by teleconference. However, on 29 August 2024 the Opponent advised this office by letter that it no longer wished to be heard on the matter. On 3 October 2024, I heard the matter by teleconference. Ryan Maguire, of Counsel, instructed by Louise Emmet from Madderns, appeared on behalf of the Applicant. Jock Hamilton was also in attendance as an observer. I am to the decide the matter as a delegate of the Registrar of Trade Marks (‘Registrar’).
Grounds
The SGP nominates grounds of opposition under ss 42(b), 44, 58A and 60. The Opponent has the onus of demonstrating one or more of the grounds of opposition, on the balance of probabilities.[2] The assessment of the rights of the parties is as at the Relevant Date.[3]
Evidence
[2] Pfizer Products Inc v Karam [2006] FCA 1663, [22] (Gyles J); Telstra Corporation Limited v Phone Directories Company Pty Ltd [2015] FCAFC 156, [133] (Besanko, Jagot and Edelman JJ).
[3] Southern Cross Refrigerating Co v Toowoomba Foundry Pty Ltd (1954) 91 CLR 592, 595 (Kitto J) (‘Southern Cross’).
EIS
The Opponent was incorporated in 2017 and offers legal services. Lloyd declares that the Opponent has 56 partners, 180 employees and 1700 clients.
The Opponent is the registered owner of several trade marks including the following registered trade mark:
Owner: Hamilton Locke Pty Ltd
Trade mark number: 2141056
Trade mark: HAMILTON LOCKE (‘HAMILTON LOCKE’)
Priority date: 4 December 2020
Specification: *see Schedule 1 to these written reasons (‘Opponent’s Services’)
Lloyd declares that there has been use of HAMILTON LOCKE since early 2018. Lloyd also declares, ‘my belief that given the Opponent’s use of the HAMILTON LOCKE trade mark, that the trade mark has acquired a significant reputation in Australia and that use of the Trade Mark by the Applicant presents a real risk of confusion in the marketplace.’[4]
[4] Lloyd, [7].
Annexure HL-1 consists of examples of the Opponent’s use of HAMILTON LOCKE and a company extract from the Australian Securities & Investments Commission. Screen captures of articles on the Opponent’s website (‘Opponent’s Website’) are dated 4 June 2018, 12 June 2018 and 15 May 2018. Annexure HL-2 consists of screen captures of articles on the Opponent’s Website dated 18 May 2023 with mentions of corporate and commercial legal services. Annexure HL-3 consists of copies of news articles in the Australian Financial Review which mention HAMILTON LOCKE dated 24 June 2021, 2 December 2021, 30 June 2022 and 1 December 2022. Annexure HL-4 consists of copies of the Opponent’s registered trade marks as appearing on the Register of Trade Marks.
EIA
Mr Hamilton was admitted for legal practice in South Australia in 2013. Hamilton states that he has worked in small and large law firms, including HWL Ebsworth and King & Wood Mallesons. Hamilton declares that the Applicant has been operating as a law firm since mid-2022 which has been accessible from its website ( Hamilton declares that the combination of the two words forming the Trade Mark has its origin in a combination of Mr Hamilton’s own surname and the surname of his grandmother.
Much of Hamilton seeks to demonstrate that it is common for law firms to carry a traditional formula for their trading names, being the surnames of partners to the law firm. In this respect Hamilton provides various Wikipedia articles, including a list titled ‘Law firms of Australia’ from Wikipedia as well as Wikipedia articles about individual law firms that operate in Australia. The names of many of these law firms, if not most of them, consist of a collocation of various apparent surnames. Hamilton declares that based on his experience of practising law, in his opinion, ‘the reputation of a legal practice is more dependent on the reputation of its principal(s) and practitioners rather than an abstract brand, which explains the historical tradition of law firms using the surnames of their founding partners as their names and brands.’[5]
[5] Hamilton, [9].
Hamilton also provides evidence of research about the surnames ‘Hamilton’, ‘Locke’ and ‘Mott’ in Australia, including in the area of legal services. Hamilton notes that there are 13,319 instances of the surname ‘Hamilton’ and 1349 of the surname ‘Mott’ in Australia. Search records from the registers of legal practitioners in New South Wales and Victoria for each of the names also are provided at Annexure JHH-12 to Hamilton. There are examples of eight law firms which include the surname Hamilton, five of these commence with the surname Hamilton.
Hamilton declares that in general consumers of legal services tend to be cautious and describes the process for engaging a lawyer as an involved one, with selection of a legal services provider often based on the reputation of the individual lawyer.[6]
Consideration
[6] Hamilton, [24].
Section 44
Section 44 relevantly provides:
44 Identical etc. trade marks
…
(2) Subject to subsections (3) and (4), an application for the registration of a trade mark (applicant’s trade mark) in respect of services (applicant’s services) must be rejected if:
(a) it is substantially identical with, or deceptively similar to:
(i) a trade mark registered by another person in respect of similar services or closely related goods; or
(ii) a trade mark whose registration in respect of similar services or closely related goods is being sought by another person; and
(b) the priority date for the registration of the applicant’s trade mark in respect of the applicant’s services is not earlier than the priority date for the registration of the other trade mark in respect of the similar services or closely related goods.
By its SGP, the Opponent relies on HAMILTON LOCKE for its s 44 ground of opposition. HAMILTON LOCKE has a priority date which is before the Relevant Date. HAMILTON LOCKE is also in the name of a person other than the Applicant.
I must consider whether the Applicant’s Services are ‘similar’ to the Opponent’s Services. In this regard, s 14 relevantly provides that ‘services are similar to other services… (a) if they are the same as the other services; or (b) if they are of the same description as that of the other services’. Plainly all the Applicant’s Services are either the same as or are notionally included in the various legal services of 2141056 in class 45. Therefore, the services of 2141056 are of the same description as Applicant’s Services.
Comparison of marks
I first consider whether the trade marks are substantially identical. Whilst the trade marks share the word HAMILTON, the trade marks also have differences by their respective suffix word elements. Because of the differences between the trade marks, there is a total impression of dissimilarity on a side by side comparison of the Trade Mark with HAMILTON LOCKE. Therefore, I should consider whether the Trade Mark is deceptively similar to any of HAMILTON LOCKE.
I must compare the respective whole trade marks,[7] with regard to essential or distinguishing features,[8] and consider them visually and aurally, and in the context of the relevant surrounding circumstances.[9] However, the actual reputation of a trade mark or an owner is not relevant. Rather, what is of importance is the effect and meaning of the spoken trade marks,[10] especially their effect or impression produced on the mind of ordinary consumers.[11] I should account for the imperfect recollection of those ordinary consumers and that the addition of even a single word can in the right circumstances relevantly differentiate one remembered mark from another in the minds of those consumers.[12] Ultimately, what is required is a real tangible danger of confusion.[13] That is, ‘a real likelihood that some people will wonder or be left in doubt about whether the two sets of products … come from the same source’.[14]
[7] Registrar of Trade Marks v Woolworths Ltd [1999] FCA 1020, [50] (French J) (‘Woolworths’). See also, Torpedoes Sportswear Pty Limited v Thorpedo Enterprises Pty Limited [2003] FCA 901, [78] (Bennett J).
[8] Crazy Ron’s Communications Pty Ltd v Mobileworld Communications Pty Ltd [2004] FCAFC 196, [77]-[88] (Moore, Sackville and Emmett JJ).
[9] New South Wales Dairy Corporation v Murray-Goulburn Co-operative Co Ltd (1989) 86 ALR 549, 589 (Gummow J).
[10] Self Care IP Holdings Pty Ltd v Allergan Australia Pty Ltd [2023] HCA 8, [51] (Kiefel CJ, Gageler, Gordon, Edelman and Gleeson JJ) (‘Self Care’).
[11] Ibid [51] and [67], citing Australian Woollen Mills Ltd v F S Walton & Co Ltd (1937) 58 CLR 641 (‘Australian Woollen Mills’).
[12] Jockey International Inc v Darren Wilkinson [2010] ATMO 22 (Hearing Officer Spence).
[13] Southern Cross (n 3) 595 (Kitto J); Woolworths (n 7) [50] (French J); Campomar Sociedad Limitada v Nike International Ltd [2000] HCA 12, [83] (Gleeson CJ, Gaudron, McHugh, Gummow, Kirby, Hayne and Callinan JJ).
[14] Woolworths (n 7) [50] (French J); Southern Cross (n 3) 594-595. See also, Australian Woollen Mills (n 11) 658.
There have been a number of decisions involving the comparison of trade marks containing surnames, including examples of comparisons of trade marks in relation to legal services.[15] In this particular instance I am concerned with the apparent names of two law firms, with the signs each constituted by what would appear to be a combination of two surnames.
[15] Baybridge Lawyers Pty Ltd v LawBridge Legal and Mediation Services Pty Ltd [2023] ATMO 26 (Hearing Officer Tuohy) (‘Baybridge Lawyers’); Solve Legal Pty Ltd v St Hilliers Commercial Realty Pty Ltd [2024] ATMO 51 (Hearing Officer Lyons); Moores MDP Pty Ltd v Moore Stephens International Licensing [2023] ATMO 86 (Hearing Officer Wilson); Olaf Kretzschmar v IP Service International Pty Ltd [2021] ATMO 71 (Hearing Officer T Brown); Law Partners Compensation Lawyers Pty Ltd as trustee for the Law Partners Unit Trust [2021] ATMO 22 (Hearing Officer Lyons); Clarendon Lawyers Pty Ltd v Cornwalls Lawyers Pty Ltd [2020] ATMO 192 (Hearing Officer Smith); Lexvoco Pty Ltd v InCounsel Pty Ltd [2019] ATMO 83 (Hearing Officer Thompson); AXIS Legal (Australia) Pty Ltd v Axia Litigation Lawyers Pty Ltd [2016] ATMO 41 (Hearing Officer Wilson) (‘AXIS Legal’); LexiMed Pty Ltd v Lex Medicus Pty Ltd [2013] ATMO 64 (Hearing Officer Windsor); Slater & Gordon Pty Ltd v Ann Rosa Mary Slater [2013] ATMO 39 (Hearing Officer McDonaugh) (‘Slater & Gordon’). See also, Neumegen v Neumegen & Co [1998] 3 NZLR 310 (Richardson P, Thomas and Blanchard JJ)
I note that s 219 provides that in ‘a proceeding relating to a trade mark, evidence is admissible of the usage of the trade concerned and of any relevant trade mark, trade name or get‑up legitimately used by other persons’. The names of law firms have often consisted of a list of surnames, sometimes being the partners or the founders of a firm. Consumers of legal services are conditioned to this relatively common phenomenon of legal services being offer under a surname or a list or combination of surnames.[16] The evidence reflects that the use of surnames often occurs in the field of legal services. The evidence also reflects that the surname ‘Hamilton’ is a common surname in Australia and that the words ‘Hamilton’, ‘Locke’ and ‘Mott’ would very likely be taken as surnames by consumers.
[16] See also, for example, In the Matter of Application No 3696054 O/0737/24, [69] (UK) (‘O/0737/24’) where the decision maker found that in the UK context, ‘the relevant public would be accustomed to law firms using one or more surnames to designate the origin of their services’.
The trade marks share a leading element in the word ‘Hamilton’. HAMILTON LOCKE also includes the words ‘Locke’ whereas the Trade Mark terminates with the word ‘Mott’. The Applicant submits that ‘Mott’ would be understood as a surname, which when combined with the surname ‘Hamiton’ conveys the impression of two surnames, or a full name. The trade marks are ultimately a combination of two surnames, the leading element of each being a common surname. I accept that the word HAMILTON would contribute to the whole trade mark for each of the respective trade marks. However, the impact of that word itself is not determinative of the impression caused by the whole trade mark. The name MOTT is not a common surname and it likely offers a terminating contrast to LOCKE. I would contrast this situation with, for example, that in Slater & Gordon Pty Ltd v Ann Rosa Mary Slater[17] where the delegate compared the trade marks SLATERS INTELLECTUAL PROPERTY and SLATER & GORDON, though in the context of s 60.
[17] Slater & Gordon (n 15).
I acknowledge that in the context of legal services consumers may encounter the trade marks over the phone or in spoken contexts, such as by word of mouth recommendations.[18] However, they are very likely encountered in signage, advertisements and websites. This suggests to me that the visual appearance of the trade marks is of importance. There is some level of similarity aurally in that each of the trade marks commences with the word ‘Hamilton’ and is combined with another apparent surname. Further, the second surname in each trade mark is double-syllabic and the middle portion of the word would be pronounced as ‘oh’. However, the commencing and terminating letters in the second surname of each trade mark presents as, and results in, a distinct impression. I do not, for example, consider the slurring of words here to be a real risk such that consumers would likely be caused to wonder whether the services originate from the same trader.
[18] See, for example, In the Matter of Consolidated Proceedings Involving Trade Mark Application No 3198785 and others O/431/18, [26] (UK).
In Baybridge Lawyers Pty Ltd v LawBridge Legal and Mediation Services Pty Ltd the delegate of the Registrar stated that:[19]
The services in this matter are legal services which consists of the provision of legal advice, assistance or representation and can be of considerable expense, consequently they are typically engaged with a relatively high degree of care and attention. This heightened diligence further diminishes the likelihood of deception or confusion.
[19] Baybridge Lawyers (n 15) [18] (Hearing Officer Tuohy).
There would be a mixture of persons, those commercial and in their individual capacities with varying degrees of attention, who might be a consumer of broad legal services. However, I agree with this assessment of the care and attention of consumers of the services in question is likely to be at least moderately heightened.[20] Such an approach is also supported by the statements in Hamilton, which are unchallenged by the Opponent. These circumstances would lessen the likelihood of confusion.
[20] AXIS Legal (n 15) [30] (Hearing Officer Wilson) also supports such an approach. Redd Solicitors LLP v Red Legal Ltd [2012] EWPCC 54, [81] (Judge Birss QC) concerned the UK context, where the Court accepted the submission that, ‘an average consumer of legal services is in general going to be more careful, circumspect and discriminating and have a higher level of attention when acquiring legal services than an average consumer of many other services and goods’. See also, O/0737/24 (n 16) [60] where the decision maker considered that, ‘at least a medium level of attention will be paid by both types of average consumer, since the applied-for services are all broadly related’ for example for ‘estate agency, advisory services relating to insurance, legal advice’. Further, the Court noted was that such services, ‘are not typically purchased casually due to the potentially serious implications for the business or individual.’
After I take account of the trade marks as wholes and of all of the surrounding circumstances, on the balance of probabilities I do not find that there is a ‘real, tangible danger’[21] of a person being caused to wonder whether the services have the same origin. I am not satisfied that the Trade Mark is deceptively similar to the HAMILTON LOCKE.
[21] Southern Cross (n 3) 594-595.
Accordingly, the s 44 ground of opposition has not been established.
Section 58A
The Opponent also relies upon s 58A, which provides:
58A Opponent’s earlier use of similar trade mark
(1) This section applies to a trade mark (section 44 trade mark) the application for registration of which has been accepted because of:
(a) subsection 44(4); or
…
Note: Subsection 44(4) prevents rejection of an application for registration of a trade mark that is substantially identical with, or deceptively similar to, a registered trade mark or a trade mark whose registration is being sought where the first‑mentioned trade mark has been continuously used since before the priority date of the other trade mark.
(2) The registration of the section 44 trade mark may be opposed on the ground that the owner of the substantially identical or deceptively similar trade mark (similar trade mark) or the predecessor in title:
(a) first used the similar trade mark in respect of:
(i) similar goods or closely related services; or
(ii) similar services or closely related goods;
before the owner of the section 44 trade mark or the predecessor in title in relation to the section 44 trade mark first used the section 44 trade mark; and
(b) has continuously used the similar trade mark in respect of those goods or services since that first use.
The ground of opposition under s 44 has not been established and therefore there has been no application of the provisions of s 44(4). As such, s 58A is not enlivened in the present circumstances. Consequently, the s 58A ground of opposition has not been established.
Section 60
The Opponent also relies upon s 60, which provides:
60 Trade mark similar to trade mark that has acquired a reputation in Australia
The registration of a trade mark in respect of particular goods or services may be opposed on the ground that:
(a) another trade mark had, before the priority date for the registration of the first‑mentioned trade mark in respect of those goods or services, acquired a reputation in Australia; and
(b) because of the reputation of that other trade mark, the use of the first‑mentioned trade mark would be likely to deceive or cause confusion.
Note: For priority date see section 12.
A relevant ‘reputation’ for the purposes of s 60 cannot simply be assumed.[22] It is the Opponent who must establish that a reputation exists as a matter of fact.[23] The word ‘reputation’ here means ‘the recognition of the [trade mark] by the public generally’.[24] The Opponent may demonstrate such a reputation by a variety of means, including quantum of sales or advertising and promotional activities.[25] Advertisements or other appearances of the other trade mark on television, radio or in magazines and newspapers may also be relevant. The required reputation is often inferred from a high volume of sales, together with substantial advertising expenditures and other promotions.[26] Direct evidence of consumer appreciation of a mark, while often harder to produce, is one other avenue for showing that a reputation exists.[27]
The Opponent relies on the trade mark HAMILTON LOCKE for its s 60 ground of opposition. I firstly note that whilst there is a general statement that the Opponent has 1700 clients, there is no indication of the turnover for services offered by the Opponent. I add that the newspaper articles in evidence do not suggest there is a reputation in HAMILTON LOCKE and merely report on staff changes. Whilst there does appear to have been operations since 2018, it is difficult for me to ascertain, or even estimate, the extent of the activities regarding HAMILTON LOCKE before the Relevant Date based on the evidence. The evidence filed by the Opponent is not sufficient to establish a reputation in any earlier trade mark for the purposes of s 60. Since no reputation has been established, it is not necessary to consider the test in s 60(b).
[22] ConAgra Inc v McCain Foods (Australia) Pty Ltd [1992] FCA 159, [77] (Lockhart J).
[23] Ibid. See also, Sara Lee Corp v Bali Blue Pty Ltd [2003] ATMO 81 (Hearing Officer Skivington).
[24] McCormick & Co Inc v McCormick [2000] FCA 1335 (‘McCormick’), [127] (Kenny J).
[25] Rodney Jane Racing Pty Ltd v Monster Energy Company [2019] FCA 923, [83] (O’Bryan J).
[26] McCormick (n 24) [80] (Kenny J).
[27] Ibid.
Consequently, the s 60 ground of opposition has not been established.
Section 42(b)
Section 42(b) provides that an application for the registration of a trade mark must be rejected if its use would be contrary to law. The Opponent must satisfy the Registrar that use of the Trade Mark would not could be contrary to law.[28] The SGP identifies the Competition and Consumer Act 2010 (Cth) (‘CCA), without further specification, as a law alleged to be contravened. The SGP also particularises that use of the Trade Mark would constitute passing off. It is not clear that I should even consider for example, the issue of ss 18 and 29 of the Australian Consumer Law (‘ACL’), or another provision of the CCA since none of these were specifically and fairly identified in the SGP as the basis for the ground of opposition under s 42(b). Furthermore, I have no submissions from the Opponent on this point.
[28] Advantage-Rent-A-Car Inc v Advantage Car Rental Pty Ltd [2001] FCA 683, [28] (Madgwick J).
The ACL forms Schedule 2 of the CCA. The ACL includes ss 18 and 29. Section 18 of the ACL concerns conduct or representations that have, or are likely to, mislead or deceive. Section 29 of the ACL concerns representations that are false or misleading. On the stricter test posited by the ACL, compared to s 60, I am not satisfied that use of the Trade Mark is likely to mislead or deceive, or amount to a false or misleading impression under ss 18 and 29 of the ACL.
For the same reasons, I am not satisfied that the use of the Trade Mark for the Applicant’s Services would contravene the law of passing off.
The SGP also alleges that the Act would be contravened by use of the Trade Mark. I have similar concerns to those regarding the CCA about the particulars here. Without more I am not satisfied that use of the Trade Mark would result in a contravention of the Act.
The Opponent has not established that use of the Trade Mark would be contrary to law. Accordingly, the ground of opposition under s 42(b) has not been established.
Decision and costs
Section 55 relevantly provides:
55 Decision
(1) Unless subsection (3) applies to the proceedings, the Registrar must, at the end, decide:
(a) to refuse to register the trade mark; or
(b) to register the trade mark (with or without conditions or limitations) in respect of the goods and/or services then specified in the application;
having regard to the extent (if any) to which any ground on which the application was opposed has been established.
Note: For limitations see section 6.
The Opponent has not established any ground of opposition. Accordingly, trade mark 2267980 may proceed to registration one month from the date of this decision. If the Registrar is served with a notice of appeal before that time, I direct that registration shall not occur until the appeal has been decided or discontinued and the disposition of the application should otherwise be in accordance with the Court’s order or direction.
The Applicant has requested costs. It is normal for costs to follow the event. I see no reason to make an exception here. I award costs against the Opponent under s 221 in the amounts according to Schedule 8 of the Trade Marks Regulations 1995 (Cth).
Benjamin Goldsworthy
Hearing Officer
Oppositions and Hearings
Trade Marks and Designs
29 November 2024
Schedule 1
Class 35: Compilation of legal information; Administration of businesses; Advice relating to business management; Advice relating to business organisation; Advisory services for business management; Advisory services relating to business acquisitions; Advisory services relating to business management; Advisory services relating to business organisation; Advisory services relating to business planning; Advisory services relating to business risk management; Business administration consultancy; Business advice; Business advisory services; Business auditing; Business consultancy; Business consultation; Evaluation of business opportunities; Management of business projects (for others); Negotiation of business contracts for others; Preparation of business reports; Preparation of documents relating to business; Professional business consultancy; Strategic business consultancy; Arranging exhibitions for business purposes; Consultancy relating to advertising; Consultancy relating to auditing; Consultancy relating to marketing; Consultancy relating to sales promotions; Preparation of commercial reports; Compilation of company information; Searches relating to company information; Business secretarial services; Company office secretarial services; Arranging and conducting promotional and marketing events; Association services being the promotion of the interests of members of the association
Class 41: Legal education services; Business training consultancy services; Business training services; Advisory services relating to training; Coaching (training); Mentoring (education and training); Personal development training; Practical training (demonstration); Provision of training; Training; Business educational services; Conducting of educational courses; Education advisory services; Education services; Arranging and conducting of conferences; Arranging and conducting of seminars; Publication of texts (other than publicity texts); Association services being the provision of training and education to members of the association
Class 45: Association services (providing legal representation or legal advice to members of the association); Legal advice; Legal advocacy services; Legal aid services; Legal compliance auditing; Legal consultancy services; Legal document preparation services; Legal information services; Legal investigation services; Legal mediation services; Legal research; Legal services; Legal support services; Legal watching services; Providing information, including online, about legal services; Provision of legal information; Registration services (legal); Litigation advice; Litigation services; Consultancy services relating to private investigations; Intellectual property consultancy; Judicial advocacy services; Licensing services; Regulatory compliance auditing; Company registration services; Advisory services relating to consumers rights; Advisory services relating to the law
0
19
0