FEDERAL COURT OF AUSTRALIA
Kowa Company Ltd v N V Organon [2005] FCA 1282
TRADE MARKS – appeal against a decision of the Trade Marks Office – application for removal of trade mark on ground of non-use – meaning of ‘person aggrieved’ – whether ‘use’ established – Court’s discretion in a non-use application – whether marks substantially identical or deceptively similar – onus in an opposition to registration.
Trade Marks Act 1995 (Cth), ss 6, 72(1), 44, 60, 33(1), 12
Therapeutic Goods Act 1989 (Cth)
Patents Act 1990 (Cth)
Drugs, Poisons and Controlled Substances Act 1981 (Vic)Shanahan’s Australian Law of Trade Marks & Passing Off (3rd ed, 2003)
Blount Inc v Registrar of Trade Marks (1998) 83 FCR 50 cited
Registrar of Trade Marks v Woolworths Ltd (1999) 93 FCR 365 cited
Woolly Bull Enterprises Pty Ltd v Reynolds (2001) 107 FCR 166 cited
The Ritz Hotel Ltd v Charles of the Ritz Ltd (1987) 88 ALR 217 cited
Gordon & Rena Merchant Pty Ltd v Ocky Docket (Australia) Pty Ltd (1992) 24 IPR 357 cited
La Cravatte Di Pancaldi SRL v Camiceria Di Pancaldi and B SRL (1999) 45 IPR 533 cited
Kraft Foods Inc (previously known as Kraft General Foods Inc) v Gaines Pet Food Corporation (1996) 34 IPR 198 cited
Upjohn Co v Sanofi (1998) 42 IPR 576 cited
George Weston Foods Ltd v Manildra Flour Mills Pty Ltd (1999) 47 IPR 145 cited
NSW Dairy Corporation v Murray-Goulburn Co-Operative Company (1989) 14 IPR 75 cited
Re J Lyons & Coy Ld’s Application (1959) 76 RPC 120 cited
Lomas v Winton Shire Council [2002] FCAFC 413 cited
Renaud Cointreau and Cie v Cordon Bleu International Ltee (2002) 193 ALR 657 cited
Torpedoes Sportswear Pty Ltd v Thorpedo Enterprises Pty Ltd (2003) 204 ALR 90 cited
Austereo Pty Ltd v DMG Radio (Australia) Pty Ltd (2004) 209 ALR 93 cited
McCorquodale v Masterson [2004] FCA 1247 cited
Health World Ltd v Shin-Sun Australia Pty Ltd [2005] FCA 5 cited
BP plc v Woolworths Ltd 62 IPR 545 cited
Clinique Laboratories Inc v Luxury Skin Care Brands Pty Ltd (2004) 61 IPR 130 cited
Jafferjee v Scarlett (1937) 57 CLR 115 cited
The Shell Company of Australia Ltd v Esso Standard Oil (Australia) Ltd (1963) 109 CLR 407 cited
Clark v Sharp [1898] 15 RPC 141 cited
Australian Woollen Mills Ltd v F S Walton & Co Ltd (1937) 58 CLR 641 cited
Southern Cross Refrigerating Co v Toowoomba Foundry Pty Ltd (1954) 91 CLR 592 cited
Anheuser-Busch Inc v Budejovicky Budvar (2002) 56 IPR 182 cited
McCormick v McCormick (2001) 51 IPR 102 cited
Rysta Ltd’s Application (1943) 60 RPC 87 citedKOWA COMPANY PTY LTD v N V ORGANON
VID 783 of 2002
LANDER J
13 SEPTEMBER 2005
ADELAIDE (HEARD IN MELBOURNE)
IN THE FEDERAL COURT OF AUSTRALIA
VICTORIA DISTRICT REGISTRY
VID 783 OF 2002
BETWEEN:
KOWA COMPANY LTD
APPLICANTAND:
N V ORGANON
RESPONDENT
JUDGE:
LANDER J
DATE:
13 SEPTEMBER 2005
PLACE:
ADELAIDE (HEARD…
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- Case
- [2005] FCA 1282
- Decision Date
CaseChat Overview and Summary
The legal issues before the court were whether the trade marks were deceptively similar and if the applicant’s proposed use of LIVALO would cause confusion with the respondent's use of LIVIAL. The court had to determine if there was a likelihood of confusion based on the similarities between the trade marks and the nature of the goods they represented. Additionally, the court needed to assess the evidence presented by both parties regarding the use and recognition of the LIVIAL trade mark.
The court found that there was no evidence of any confusion between the two trade marks in the marketplace. It was determined that medical professionals and consumers distinguish between the two trade marks based on their respective uses. The applicant’s proposed use of LIVALO for a different medical condition and the differences in the names of the trade marks were sufficient to prevent confusion. The court relied on expert evidence and the distinct nature of the products to conclude that there was no likelihood of confusion.
Consequently, the appeal was allowed, and the mark LIVALO was registered for goods in Class 5 limited to prescription pharmaceutical preparations for the treatment of hyperlipidemia. The application for partial removal of the respondent’s trade mark LIVIAL from the Register was dismissed. The decision underscored the importance of the specific context and usage of trade marks in determining their distinctiveness and potential for confusion.
Orders
Orders of the court
1. The appeal be allowed.
2. The mark LIVALO be registered for goods in Class 5 limited to prescription pharmaceutical preparations for the treatment of hyperlipidemia.
3. The application for partial removal of the respondent’s trade mark LIVIAL from the Register be dismissed.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
Decision
Reasons for decision
Full text does not contain this section.
Ratio Decidendi
Legal Principle Established
Established by: LANDER J
Full text does not contain this section.