Restive Tech Pty Ltd v Angel Oliver

Case

[2024] ATMO 188

1 October 2024


TRADE MARKS ACT 1995



DECISION OF A DELEGATE OF THE REGISTRAR OF TRADE MARKS WITH REASONS

Re:Opposition by Restive Tech Pty Ltd to registration of trade mark application number 2255308 (classes 9, 35, 41 & 42) - RESTIVE - in the name of Angel Oliver

Delegate:

Tracey Berger

Representation:

Opponent: Melissa McGrath of Counsel, instructed by McLeanDolphin

Applicant: No appearance

Decision:

2024 ATMO 188

Trade Marks Act 1995 (Cth) – opposition under section 52 – grounds of opposition under ss 42(b), 58, 60 and 62A pursued – s 62A ground of opposition established – trade mark refused registration

Background

  1. This decision concerns an opposition by Restive Tech Pty Ltd (‘Opponent’) pursuant to s 52 of the Trade Marks Act 1995 (Cth)[1] to registration of the trade mark which is the subject of the application detailed below in the name of Angel Oliver (‘Applicant’):

Trade Mark:             RESTIVE (‘Trade Mark’)

Number:                   2276310 (‘Application’)

Filing Date:              15 March 2022

Specification[2]:       Class 9: Various computer programs, software and computer databases

Class 35: Various advertising and business services

Class 41: Various photography, video and film services; training services

Class 42: Various computer and IT related services; design services

(‘Applicant’s Goods and Services’)

[1] Any references to sections or regulations in this decision are references to sections or regulations of the Trade Marks Act 1995 (Cth) (‘Act’) or the Trade Marks Regulations 1995 (Cth) (‘Regulations’), respectively.

[2] The full specification is shown in Annexure A to this decision

  1. Once acceptance of the Application for possible registration had been advertised, the Opponent filed a Notice of Intention to Oppose on 5 October 2022 followed by its Statement of Grounds and Particulars (‘SGP’) on 4 November 2022.  The Applicant filed a Notice of Intention to Defend on 27 January 2023.

  2. The parties then had an opportunity to file evidence in accordance with the Regulations. The Opponent’s evidence in support of the opposition was filed on 8 May 2023. The Applicant did not file any evidence in answer.

  3. Following the conclusion of the evidence stage, the parties were able to request a hearing.  The Opponent requested an oral hearing and the Applicant did not ask to be heard.  I heard this matter as a delegate of the Registrar of Trade Marks on 18 September 2024.  Melissa McGrath of Counsel, instructed by Curtis Day of McLean Dolphin, prepared and filed a written summary of submissions on 4 September 2024 and made oral submissions at the hearing on the Opponent’s behalf.  I make my decision based on the aforementioned materials and submissions made on behalf of the Opponent.   

Grounds, onus and relevant date

  1. In the SGP, the Opponent particularised grounds of opposition under ss 42(b), 58, 60 and 62A. 

  2. The Opponent bears the onus of establishing at least one of the nominated grounds of opposition.[3]  The standard of proof is the ordinary civil standard of the balance of probabilities.[4]

    [3] Food Channel Network Pty Ltd v Television Food Network GP [2010] FCAFC 58, [32] (Keane CJ, Stone and Jagot JJ).

    [4] Telstra Corporation Ltd v Phone Directories Co Pty Ltd [2015] FCAFC 156, [133] (Besanko, Jagot and Edelman JJ).

  3. The date at which the rights of the parties is to be determined is 15 March 2022 (‘Relevant Date’) being both the filing date and priority date for the purposes of s 60.

Opponent’s evidence

  1. The Opponent’s evidence consists of a declaration of Stuart David Oliver, sole director of the Opponent, made on 7 May 2023 with Exhibits SO-1 to SO-9 (‘Oliver’).

  2. Oliver declares that in about October 2018 he incorporated Tag Partners and Co Pty Ltd and commenced operating a business called TAG PARTNERS.  In about August 2019, Oliver rolled the Tag Partners business into Amplify Technology Collective Pty Ltd and rebranded the merged business AMPLIFY.  In January 2021, Oliver decided to rebrand his AMPLIFY business under the mark RESTIVE. 

  3. On 27 January 2021, the Opponent and Restive Group Pty Ltd (‘Restive Group’) were incorporated.  The Opponent is wholly owned by Restive Group which in turn is ultimately wholly owned by Stuart Oliver Holding Pty Ltd.  Company extracts for the Opponent and Restive Group, from the Australian Securities and Investments Commission (‘ASIC’) records, are provided.  I note that these extracts show that at the time of incorporation until 7 April 2022, the Applicant was the sole director and company secretary of both companies.  Oliver attests that in addition to being a director, the Applicant was also an employee of the Opponent and Restive Group. 

  4. In addition, the Applicant was a director and employee of Restive Creatives Pty Ltd (‘Restive Creatives’), a wholly owned company of Restive Group which company used the Trade Mark from its incorporation on 20 August 2019 in relation to marketing, promotion and graphic design.  An ASIC extract for Restive Creatives is provided and exhibited to Oliver are copies purporting to be payment summaries to the Applicant from Restive Group and Restive Creatives.

  5. Since January 2021, Oliver declares the Opponent has used the marks RESTIVE, RESTIVE TECH and RESTIVE GROUP (‘Opponent’s Marks’) in relation to its business which provides the following services, amongst others: computer hardware engineering and design; computer software development, consulting, business advisory and administration; design of marketing materials and profiles for consultants; website development and design; cloud solution architecture; project management of digital projects and software development; data and analytics strategy and data science and career advisory and recruitment (‘Opponent’s Services’).  Oliver provides a confidential list of some of the Opponent’s significant clients which includes some well known brands.

  6. The domain names <restivetech.com.au> and <restivegroup.com.au> were registered in January 2021 followed by registration in July 2021 of <restivevirtualtalent.com> (collectively ‘Restive Domains’).  Websites featuring the Opponent’s Marks promoting the Opponent’s Services were available at the Restive Domains from the dates set out below and extracts of the website at restivetech.com.au dated October 2021 are exhibited to Oliver.

  • March 2021: restivetech.com.au and restivegroup.com.au

  • October 2021: restivevirtualtalent.com.au

  1. In March and April 2021, the Opponent prepared various marketing materials featuring the Trade Mark which was completed by 4 May 2021.  A copy of that marketing deck is provided.

  2. Oliver attests that the Opponent’s Marks have been used on the Opponent’s business collateral including letterhead, invoices, emails and business cards.  Exhibited to Oliver is a copy of an email from Mr Oliver dated 1 March 2021 which shows use of the marks RESTIVE GROUP, RESTIVE TECH, RESTIVE CREATIVES and RESTIVE TALENTS in the email signoff and a confidential Statement of Work between the Opponent and a client dated 30 March 2021 showing use of RESTIVE TECH.

  3. In addition, the Opponent promotes the Opponent’s Services on its LinkedIn, Instagram and YouTube social media accounts, Mr Oliver’s LinkedIn account and the Restive Group website, as well as its own website.  Extracts of these accounts and Restive Group website are exhibited to Oliver.  The Opponent’s advertising expenditure for the 2020 and 2021 financial years (‘FY20’ and ‘FY21’ respectively) is provided. 

Discussion

Section 62A

  1. Section 62A provides that registration of a trade mark may be opposed on the ground that the application was made in bad faith.

  2. Although the phrase ‘bad faith’ is not defined in the Act, Bennett J considered the concept of bad faith and summarised the relevant principles in DC Comics v Chequout Pty Ltd:

  • Bad faith is a serious allegation and the more serious the allegation, the more cogent the evidence required to support it.

  • Bad faith does not require dishonesty.

  • Bad faith is a combined test that involves subjective and objective elements. The subjective element refers to the knowledge of the relevant person at the time of making the application. The objective element requires the decision-maker to decide whether, in the light of that knowledge, the relevant person’s behaviour fell short of acceptable commercial standards.

  • The question is whether the conduct fell short of the standards of acceptable commercial behaviour observed by reasonable and experienced persons in the particular area. It is whether the knowledge of the applicant was such that the decision to apply for registration would be regarded as in bad faith by persons adopting proper standards.

  • Mere negligence, incompetence or a lack of prudence to reasonable and experienced standards would not, in themselves, suffice, as the concept of bad faith imports conduct which, irrespective of the form it takes, is of an unscrupulous, underhand or unconscientious character.[5]

    [5] [2013] FCA 478, [62].

  1. In its SGP, the Opponent claims the Applicant was aware of the Opponent and its use of the Trade Mark prior to filing the Application and filed the Application to assert rights in the Trade Mark which they did not own; such conduct falls short of the standard of acceptable commercial behaviour.

  2. It is the Opponent’s contention that at the Relevant Date, the Applicant was aware or ought to have been aware that:

    (a) the Opponent was already using the Trade Mark in relation to goods and services that are the same or the same kind of thing as the Applicant’s Goods and Services;

    (b) as a director of the Opponent, filing of the Application in her own name was contrary to the best interests of the Opponent;

    (c) any use she made of the Trade Mark would take advantage of the Opponent’s reputation; and

    (d) any use she intended to make of the Application would be ‘exploitative and designed to acquire a springboard or advantage for … any fledgling business’[6] which may be inferred in the absence of any evidence to the contrary from the Applicant.

    [6] Fry Consulting Pty Ltd v Sports Warehouse Inc (No 20 [2012] FCA 81, [170] (Dodds-Streeton J).

  3. The Opponent also notes that the Applicant has not provided any explanation for the filing of the Application in her own name and submits that the present situation is similar to that in Enagic Co Ltd v Horizons (Asia) Pty Ltd (No 3)[7] in which Charlesworth J upheld the opposition under s 62A noting ‘Horizons did not strike upon the words.. by original thought or by accident. It sought registration of them knowing they had been used by Enagic …’[8] and had sought registration of the opposed mark as a strategic decision to either ‘exploit a connection between the words KANGEN and ENAGIC in the minds of consumers or to disrupt Enagic’s commercial activities including by limiting its use of the word KANGEN as an indicia of the origin of its goods and services.’[9]

    [7] [2021] FCA 1512.

    [8] Ibid, [301].

    [9] Ibid, [305].

  4. I am satisfied based on the Opponent’s evidence that given the Applicant’s directorships and employment by the Opponent and its related companies, the Applicant knew or should have known of the use of various RESTIVE formative marks by the Opponent and its related companies for the same or similar goods and services to the Applicant’s Goods and Services.  At the time of incorporation, the Applicant was the sole director and company secretary of the Opponent and its parent company Restive Group.  It is highly unlikely that the Applicant did not know of the Opponent’s plans to use, and subsequent actual use, of RESTIVE TECH which mark is highly similar to the Trade Mark in the context of technological related goods and services.    

  5. Objectively, as a director of the Opponent at the Relevant Date, the Applicant should have been aware that the filing of the Application in her own name was contrary to her duties and obligations as a director and conduct falling short of the standards of acceptable commercial behaviour.

  6. In all the circumstances, I am satisfied that the Application was filed in bad faith and the s 62A ground of opposition is established.

Decision

  1. The Opponent has established a ground of opposition under s 62A and I refuse to register the Trade Mark under application number 2255308.

  2. The Opponent has sought an award of costs and as costs generally follow the event, I award costs against the Applicant under s 221 in the amounts set out in Schedule 8 of the Regulations.

Tracey Berger

Hearing Officer

Delegate of the Registrar of Trade Marks

1 October 2024

ANNEXURE A – Applicant’s Goods and Services

Class 9:  Application software; Communication software; Communications networks; Communications processors; Communications programmes; Communications systems; Computer databases; Computer installations for the storage of data; Computer installations incorporating a central processing unit; Computer instruction records; Computer interface apparatus; Computer networks; Computer networks for the communication of data; Computer networks for the storage of data; Computer programs relating to computer networks; Computer programs relating to financial matters; Computer programs stored on data carriers; Computer programs, downloadable; Computer systems; Data communications software; Data processors; Data programmes; Encoded programmes for computers; Encoded programs; Encoded programs for processing apparatus; Interfaces (for computers); Computer programs for commercial transactions; Computer programs for financial management; Computer programs for office use; Computer programs for processing information; Computer programs for the creation of networks; Computer programs for the management of sales; Computer programs for use in communications; Computer programs for use in database management; Computer programs for use in telecommunications; Computer programs for use with structured system analysis; Encoded programs for computers; Programs for computers; Programs for use with data processors; Business programmes for computers; Computer programs for sales purposes; Computer programs, recorded; Communications processing computer software; Computer software; Computer software (programs); Computer software applications (downloadable); Computer software for analysing market information; Computer software for authorising access to data bases; Computer software for business purposes; Computer software programs; Computer software programs for database management; Computer software programs for spreadsheet management; Computer software downloaded from the internet; Computer software for processing market information; Computer software packages; Computer software products; Downloadable software applications (apps); Integrated software packages; Interactive computer software; Personal computer application software; Computer software (recorded); Computer software platforms, recorded or downloadable; Recorded computer software; Computer networks for the processing of data; Data processing programs; Data processing software; Data processing systems; Data processing programmes; Encoded programmes for data processing apparatus; Computer installations for the processing of data; Installations for data processing; Encoded programs for data processing apparatus; Computer programs for data processing; Computer programs for processing data; Computer programs for the analysis of data processing performance; Computer programs for the analysis of data processing efficiency; Computer programs for the analysis of data processing procedures; Programs for data-processing; Programs for processing data on computers; Computer programs for use in processing data relating to financial records

Class 35:  Administration of businesses; Administration relating to sales methods; Advertising; Advertising agencies; Advertising agency services; Advice relating to commercial management; Advisory services relating to advertising; Arranging subscriptions for others; Advice relating to business organisation; Business advice; Business advice relating to advertising; Advisory services relating to business organisation; Business advisory services; Business assistance; Business consultancy; Business consultancy to firms; Business consultancy to individuals; Business consultation; Business counselling; Business advisory services relating to product development; Business development services; Agents' services (business management of actors, artists, authors, performing artists, photographers or writers); Advice relating to business management; Advisory services for business management; Advisory services relating to business management; Business advisory services relating to the management of businesses; Business management; Business management advice; Business management advisory services; Business management assistance; Business management consultancy; Business management for freelance service providers; Business organisation consultancy; Business organisation consulting; Business organization consultancy; Administration relating to business planning; Advisory services relating to business planning; Business planning; Business planning consultancy; Business project management; Collecting business information; Collecting business statistics; Collecting information for business; Collection of commercial information; Collection of data; Collection of financial information; Collection of information relating to advertising; Collection of statistics for business; Company data information services; Consultancy regarding advertising communications strategies; Consultancy regarding public relations communications strategies; Business consultancy relating to the administration of information technology; Business consultation relating to advertising; Consultancy relating to advertising; Consultancy relating to business efficiency; Consultancy relating to business management; Consultancy relating to business planning; Consultancy relating to business promotion; Consultancy relating to public relations; Consultancy relating to the establishment and running of businesses; Data collection (for others); Data compilation for others; Data management; Data management advice; Data management consultancy; Advisory services relating to data processing; Business consultancy services relating to data processing; Consultancy relating to data processing; Data processing; Data processing for businesses; Data processing for the collection of data for business purposes; Data processing services [office functions]; Data processing verification; Development of advertising concepts; Development of advertising plans; Development of publicity plans; Dissemination of advertising material; Dissemination of advertising matter; Dissemination of business information; Dissemination of commercial information; Employment advertising services; Employment agencies; Employment agency services; Employment bureau services; Employment consultancy; Employment counselling services; Evaluation of business opportunities; Information services relating to advertising; Information services relating to business matters; Job agency services; Job placement services; Business management of a retail enterprise for others; Management of business (for others); Online advertising on a computer network; Collection of personnel information; Evaluation of personnel requirements; Advice relating to personnel management; Consultancy relating to personnel management; Consultancy relating to the management of personnel; Personnel management; Personnel management advice; Personnel management assistance; Personnel management consultancy; Personnel placement; Personnel resources management; Personnel selection (for others); Placing of advertisements; Planning services for advertising; Professional business consultancy; Promotion of goods through influencers; Promotional services; Providing business information; Providing business information via a website; Provision of advertising information; Provision of advertising space; Provision of business assistance; Provision of business information; Provision of business management assistance; Provision of business management information; Provision of information in relation to business management; Provision of information relating to advertising; Provision of information relating to business; Provision of information relating to commerce; Business recruitment consultancy; Employment recruiting consultancy; Employment recruitment; Consultancy relating to personnel recruitment; Personnel recruitment; Personnel recruitment advertising; Personnel recruitment agency services; Personnel recruitment consultancy; Professional recruitment services; Recruitment advertising; Recruitment consultancy services; Recruitment of personnel; Research of business information; Research of commercial information; Research services relating to advertising; Research services relating to business; Consultancy relating to sales promotions; Sales promotion (for others); Sales promotion services; Selection of personnel; Selection of staff; Staff placement services; Staff recruitment consultancy services; Staff recruitment services; Strategic business consultancy; Strategic business planning; Career advisory services (other than education and training advice); Career counselling (employment advice and information); Career information and advisory services (other than educational and training advice); Career planning services; Classified advertising; Consultancy relating to the selection of personnel; Copy writing; Direct-mail advertising; Clerical employment agency services; Selection of executive personnel; Executive placement services; Executive recruitment services; Executive search services; Executive selection services; Interviewing services (for personnel recruitment); Administration relating to marketing; Advice relating to marketing management; Business advice relating to marketing; Collection of information relating to market analysis; Development of marketing plans; Market research; Market research for advertising; Marketing; Marketing advisory services; Marketing agency services; Marketing analysis; Marketing assistance; Marketing consultancy; Marketing management advice; Marketing research; Planning of marketing strategies; Planning services for marketing studies; Product marketing; Promotional marketing; Provision of advice relating to marketing; Provision of information relating to marketing; Collection of information relating to market research; Collection of market research information; Market research data collection services; Market research data retrieval services; Research services relating to marketing; Social media marketing; Conducting of market research; Conducting of marketing studies; Business consultancy services relating to marketing; Consultancy relating to marketing; Demographic survey services for marketing purposes; Direct market advertising; Direct marketing; Influencer marketing; Interpretation of market research data; Market campaigns; Market forecasting; Market reporting consultancy; Market reporting services; Market research studies; Market studies; Market survey analysis; Market surveys; Marketing and business development of inventions; Marketing and sales channel management; Marketing forecasting; Marketing in the framework of software publishing; Marketing information; Marketing studies; Office support staff recruitment services; Permanent staff recruitment; Placing advertisements (for others); Point of purchase promotions (for others); Preparation of advertisements; Preparation of advertising material; Preparing of advertisements; Preparation of mailing lists; Preparation of marketing plans; Preparation of publicity documents; Preparation of reports for marketing; Production of advertising material; Production of advertising films; Production of commercials; Production of radio, television and cinema commercials; Production of sound recordings for advertising purposes; Production of sound recordings for marketing purposes; Production of video recordings for marketing purposes; Production of video recordings for publicity purposes; Production of visual advertising matter; Promotional advertising services; Promotion (advertising) of business; Promotion (advertising) of concerts; Promotion (advertising) of travel; Recruiting of office support staff; Resume compilation for personnel seeking employment; Scriptwriting for advertising purposes; Search engine optimisation; Search engine optimisation for sales promotion; Search engine optimisation services (marketing services); Secretarial employment agency services; Secretarial employment services; Sponsorship (promotion and marketing services); Targeted marketing; Telemarketing services; Telephone marketing services; Production of radio television and cinema advertisements; Television advertising; Temporary assignment of employees; Temporary assignment of personnel; Temporary personnel employment services; Temporary personnel placement services; Distribution of advertising material; Distribution of goods for advertising purposes

Class 41:  Photographic film editing; Photography; Video editing; Cinematographic film editing; Distribution (other than transportation) of audio recordings; Distribution (other than transportation) of films; Distribution (other than transportation) of television programmes; Distribution (other than transportation) of videos; Distribution of motion picture films (rental services); Digital imaging services (editing of images); Editing of cine-films; Editing of video-tapes; Film directing, other than advertising films; Film production, other than advertising films; Producing of motion pictures, plays and videos; Production of animated cartoons; Production of animated films and cartoons; Production of audio and/or video recordings, other than advertising; Production of audio entertainment; Production of audio recordings, other than advertising; Production of audio/visual presentations; Production of entertainment videos; Production of films, other than advertising films; Production of motion pictures; Production of television programs; Production of video recordings, other than advertising; Production of webcasts, other than advertising; Providing courses of instruction; Providing films, not downloadable, via video-on-demand services; Providing films, not downloadable, via video-on-demand transmission services; Providing online electronic publications, not downloadable; Providing online videos, not downloadable; Providing television programmes, not downloadable, via video-on-demand services; Providing television programs, not downloadable, via video-on-demand services; Provision of facilities for the production of films; Provision of film studio facilities; Provision of information in relation to art; Provision of information relating to education; Provision of information relating to publishing; Provision of non-downloadable audio and video entertainment via electronic or digital transmission; Provision of non-downloadable audio and video entertainment via streaming services; Video entertainment services; Video equipment hire; Video imaging services by drone; Video production services, other than advertising; Videotape editing; Videotape film production, other than for advertising films; Videotaping; Weblog (blog) services (online publication of journals or diaries); Video editing services for events; Production of special effects; Photographic imaging services by drone; Providing information in the field of education; Provision of tuition; Providing courses of training; Computer based training; Computer training; Computer training advisory services; Computerised training; Organisation of training courses; Personal development training; Provision of information relating to training; Provision of training; Provision of training courses; Provision of training facilities; Training; Training consultancy; Providing information, including online, about training activities

Class 42:  Computer engineering; Advisory services relating to computer programming; Computer program advisory services; Computer program maintenance services; Computer program updating services; Computer programming; Computer programming consultancy; Computer programming services for data processing; Advisory services relating to computer software; Computer software advisory services; Computer software consultancy; Computer software design; Computer software development; Computer software programming services; Advisory services relating to computer systems analysis; Advisory services relating to computer systems design; Computer system analysis; Computer system design; Design of computer programs; Design of computer software; Development of computer codes; Development of computer platforms; Development of computer programmes; Development of computer systems; Design and development of computer software; Design and development of computer software for others; Development of computer software; Development of computer software application solutions; Development of software; Graphic art design; Graphic arts design; Graphic design of corporate branding; Graphic design of promotional materials; Graphic design of promotional matter; Graphic art designing services; Graphic design services; Installation of computer software; Installation and maintenance of computer software; Maintenance of computer programs; Maintenance of computer software; Providing information, including online, about scientific and technological services and research and design relating thereto; Provision of information relating to computer programming; Provision of information relating to computer programs; Provision of information relating to computers; Provision of technical information in relation to computers; Provision of technical information services relating to computers; Software creation; Software development in the framework of software publishing; Computer software engineering; Software engineering; Software engineering services for data processing; Technological advisory services; Technological analysis services; Computer technology consultancy; Technological consultancy; Technological consultation services; Technological consulting services for digital transformation; Technological engineering analysis; Technological planning services; Updating of computer programs; Updating of computer software; Website design; Writing of computer code; Writing of computer programs; Writing of computer software; Computer programming services for search engine optimisation; Computer support services (programming and software installation, repair and maintenance services); Computer support services (software advisory and information services); Data security consultancy; Data security services (firewalls); Design of computer codes; Providing information, including online, about design and development of computer hardware and software; Design and development of computer hardware for others; Design of computer hardware; Design of computer languages; Design of information systems; Development of computer based networks; Development of systems for the processing of data; Development of systems for the storage of data; Development of systems for the transmission of data; Information services relating to information technology; Online provision of web-based applications (non-downloadable); Online provision of web-based software (non-downloadable); Provision of online non-downloadable web-based software; Provision of online non-downloadable software (application service provider); Research relating to computer programming; Research relating to computers; Research relating to data processing; Research relating to technology; Platform as a Service (PaaS); Information technology (IT) consultancy; Information technology services provided on an outsourcing basis; Installation of middleware (software); Installation, repair and maintenance of middleware (software); Installation, repair and maintenance of firmware; Rental of computer programs; Rental of computer software; Rental of web servers; Repair of computer software; Research relating to design; Hosting of software as a service (SaaS); Software as a service (SaaS); Temporary use of online non-downloadable software; Trade mark design (graphic design); Upgrading of computer software; Visual design; Web portal services (designing or hosting); Creating and designing web pages for others; Creating and designing web pages for others, including creating virtual communities for registered users to interact and participate in discussions; Creating and designing website based indexes of information for others using information technology; Creating and designing website-based indexes of information for others (information technology services); Creating and maintaining weblogs (blogs) for others; Creating and maintaining websites for others; Design of computer databases; Database design; Website design consultancy; Consultancy in the design and development of computer software; Information technology (IT) services (computer hardware, software and peripherals design and technical consultancy); Design consultancy; Design engineering; Design of communication systems; Design of printed material; Design of printed matter; Design of stationery; Design services relating to printing; Design services relating to the layout of documents; Digital imaging services (digitisation and scanning of images); Hosting computer websites; Illustration services (design); Illustrator's services; Graphic design of logos; Logo design services; Logo design services (graphic design); Pattern design


Areas of Law

  • Intellectual Property

  • Commercial Law

Legal Concepts

  • Statutory Construction

  • Remedies

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