Notesale: Turn your study into money

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PASSING OFF
INTRODUCTION
The protection of trade symbols is the action of passing off
...
”
(Reddaway v
...
”
(Star Industrial v
...
Spalding v Gamage and the later cases make it possible to identify five
characteristics which must be present in order to create a valid cause of action for
passing-off:
(1) A misrepresentation
(2) Made by a trader in the course of trade
(3) To prospective traders of his or ultimate consumers of goods or services
supplied by him
(4) Which is calculated to injure the business or goodwill of another trader (in the
sense that this is a reasonably foreseeable consequence) and
(5) Which causes actual damage to a business or goodwill of the trader by whom the
action is brought or (in a quia timet action- because it's feared) will probably do
so
...
”
THE “CLASSIC TRINITY”
(1) Goodwill- Customer Recognition of particular sign
(2) Misrepresentation- eg Samsung sold representing that it's the plaintiff's
(3) Damage- Arise as a result of the Misrepresentation, eg: loss of sales,; not
actually a Samsung product
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1
...
Muller & Co
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It is the attractive force which
brings in custom…goodwill has no independent existence
...
It
must be attached to a business
...

The goodwill must have a power of attraction sufficient to bring customers home
to the source from which it emanates
...
1 MANIFESTATIONS OF GOODWILL
Goodwill associated with packaging, get-up and trade dress
 Reckitt & Colman Products Ltd v Borden Inc
The claimant had succeeded in persuading the public that lemon juice sold in plastic
lemon-sized containers had been manufactured by them
...
As a part of its
marketing campaign in Australia, the claimant launched a series of TV advertisements,
which featured 'ruggedly masculine and adventurous men' drinking SOLO
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Lord
Scarman said that there was no reason in principle why the claimant could not have
acquired goodwill associated with a particular advertising style
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 See Reddaway v
...

Also other examples : MOTHERCARE for clothing expectant mothers and children Mothercare v Penguin Books [1988]
 Cf BBC v
...

In proving secondary meaning, the claimant may submit evidence of things such as :





Length of use and the amount of money spent on advertising - Chivers v Chivers
(1900)
Easier to find the name distinctive when the trader has used it separately rather
than in conjunction with another signs that designate the source - McCain v
County Fair [1981]
A trader may acquire secondary meaning in a descriptive phrase through public
adoption rather than their own action- Edge & Sons v Gallon & Son [1900]

1
...

One instance when passing off was denied:
 Kean v McGivan [1982] - the claimant claimed the exclusive right to the name
SOCIAL DEMOCRATIC PARTY
...
If the claimant had been one
of the major political parties, which received and spent large sums of money,
however, the Court might well have held that he was engaged in a trade
Distinguishing
 Burge v Haycock [2001] - a lobbying organisation known as the 'Countryside
Alliance' was granted injunctive relief to prevent the defendant, a former
member of the right wing British National Party, from standing in parish council
election under the banner of the Countryside Alliance
...

THE CLAIMANT MUST BE TRADING- BIRTH OF GOODWILL
The birth of goodwill
 Stannard v Reay [1967] RPC 589
 British Broadcasting Corporation v Talbot Motors Co Ltd [1981] FSR 228
 County Sound plc v Ocean Sound plc [19911 FSR 367

i
...

 Maxwell v Hogg (1867) - pre-launch publicity of a magazine BELGRAVIA by
Maxwell, no trading yet; Maxwell could not restrain Hogg from using the same
name BELGRAVIA
...

In contrast:


Allen v Brown Watson [1965] - where there has been substantial pre- launch
publicity, claimants have occasionally succeeded in gaining interim relief prior to
the launch of their products
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 BBC v Talbot Motor Co Ltd [1981] - The BBC had publicized its forthcoming
traffic information service named CARFAX, which required motorists to have
special car radios fitted or conventional ones adapted
...
The Court said that although the scheme had not yet
been published, that does not prevent BBC from having built up goodwill in it
which is entitled to protection
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Goodwill After Trading Ends- The Death Of Goodwill

Given that goodwill is directly linked to the existence of a business, it follows that once a
business ceases to trade that the goodwill starts to wither away
...
's Margarine- goodwill
cannot subsist by itself
...
Destroy the business
and the goodwill perishes with it
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Whether the public retains relevant associations between the sign and a
particular trader
B
...
Pennycuick VC granted an interlocutory
injunction against the defendant who, four years later, announced that they were
going to open a disco under the same name
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 Jules Rimet Cup Ltd v Football Association Ltd [2008] FSR 10- the court held
that even though the Football Association had not used the 'World Cup Williw'
device for 40 years and had allowed its trade mark registrations to lapse, the
circumstances did not indicate that the Association had no intention to resume
use of the sign
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 Maslyukov v Diageo Distilling Limited [2010] EWHC 443 (Ch)
 Linoleum Manufacturing Co v Nairn (1878)-Words, once distinctive, may
later lose their ability to indicate source
...
A classic example is LINOLEUM, which is the name used
for a floor covering made of solidified oil
...
After the expiry of the patent, other competitors could use this
term on the basis that it had become generic
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FOREIGN TRADERS GEOGRAPHICAL ISSUES-WHERE
1
...
There is no need to have a registered business
in the UK
...
The court held that although the claimant did not have
any hotels in the UK at that time, the fact that bookings for its hotels
abroad were frequently made both through an office that Sheraton
maintained in London and through travel agencies was sufficient to
entitle it to relief
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No business activity, but customers - Soft school
Where a foreign trader has customers in the UK
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 Crazy Horse decision - the claimant was a proprietor of the CRAZY
HORSE SALOON in Paris
...
Pennycuick J refused to grant an injunction to restrain the
defendant from using the CRAZY HORSE SALOON name in London
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2nd line of cases: if a foreign business can demonstrate that it has
customers in the UK it is likely that the court will treat this as sufficient to
establish goodwill
...
While the
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American firm had a reputation in the UK, it had not conducted business
in the UK
...
Given that the claimant had no customers
in the UK, the court held that they did not have the goodwill necessary to
sustain a passing off action
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 Hotel Cipriani SRL v Cipriani [2008]- C operated a hotel in Venice
under the name HOTEL CIPRIANI
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The D, another member of the Cipriani family,
opened a bar in London, called BAR CIPRIANI
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At the same time, the D also argued that they had
goodwill in England as a consequence of a bar that they operated in
Venice
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Where the desirability of relaxing the requirements that must be met to
establish passing off was called into question:
 Starbucks (HK) v BSB- the claimant had no goodwill in the designation
NOW TV in relation to its Internet broadcast service, which originated in
Hong Kong
...
The court stressed that C could not rely upon the fact
that its service was accessed by residents in England to show the
existence of goodwill in England
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Mere reputation
Case law is unclear
1st line of cases:
 Maxim's v Dye [1978] - C well known restaurant in Paris known as
MAXIM'S; D restaurant in Norwich also called MAXIM'S
...
The court held that the claimants did have
sufficient goodwill to bring a passing off action, as globalisation makes the
'world grow smaller'
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 Anheuser Busch Inc v Budejovicky Budvar NP [1984] FSR 397 (CA) The
Budweiser case - AB, an American company that manufactured BUDWEISER
beer, sued the Czech brewers, BB for passing off
...
The court supported the
view that the mere reputation alone would not justify an action for passing off
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Well known marks
The Trade Marks Act 1994 provides foreign traders who lack local goodwill with
a potential remedy, s56 :
56Protection of well-known trade marks: Article 6bis
...

The key limitation of this section is not goodwill, it is whether the mark is well known
Features :


Trade recognition and public recognition in the UK



Inherent distinctiveness of the mark



Duration and extent of any use (whether in UK or neighbouring territories)



Promotion or advertising

1
...
when considering whether a patent has been infringed, the question of
geographical scope of the protection is not an issue
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GOODWILL – GEOGRAPHICAL ISSUES
Only goodwill within the jurisdiction is relevant
Distinguishing “goodwill” and “reputation”
No goodwill - Anheuser Busch Inc v Budejovicky Budvar NP [1984] FSR 397 (CA)
GOODWILL – GEOGRAPHICAL ISSUES – THE “WADLOW” TEST
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“…[A] service business operating from a place or places abroad has customers and
therefore goodwill in England to the extent that persons from England consciously seek
out and make use of its services in preference to those available from competitors in
England or elsewhere…”
Goodwill – geographical issues – the “Wadlow” test
•

“…So the foreign business has goodwill here if English residents are
prepared to go to it (literally or figuratively) to avail themselves of its
services, or if the availability of those services abroad is a material factor
in the travelling to wherever the services can be acquired or
experienced
...


1
...
In the 1980's the claimant was taken over
...
The C demanded that D stop using the
SCANDECOR mark
...
It observed that where
goodwill originates from a common source overseas, but then expands and is
developed by different companies in different territories, it is necessary to
analyse the effect of the changes occurring from time to time in the control and
ownership of the business that generate the goodwill
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'What matters is who retailers identified as the person carrying out
the trading activities in the local territory'
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Early cases, culminating in –
 Erven Warnink BV v J Townsend & Sons (Hull) Ltd [1980] RPC 31 (HL)
“My Lords, these findings of fact… seem to me to disclose a case of unfair, not to say
dishonest, trading of a kind for which a rational system of law ought to provide a
remedy to other traders whose business or goodwill is injured by it
...
”
(Erven Warnink BV v J Townsend & Sons (Hull) Ltd [1980] RPC 31 (HL), per Lord Diplock)
Shared Goodwill
“As respects subsequent additions to the class, mere entry into the market would not
give any right of action for passing off; the new entrant must have himself used the
descriptive term long enough on the market in connection with his own goods and have
traded successfully enough to have built up a goodwill for his business
...
So
if one can define with reasonable precision the type of product that has acquired the
reputation, one can identify the members of the class entitled to share in the goodwill as
being all those traders who have supplied and still supply to the English market a
product which possesses those recognisable and distinctive qualities
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Cadbury Limited
[1998] RPC 117 (Laddie J)






“Swiss chocolate” having goodwill – having perceived distinctive quality (not just
a descriptive term)
Identifiable characteristics – made in Switzerland in accordance with Swiss
regulations (didn’t matter that public didn’t know characteristics)
[Misrepresentation]
[Damage]
Standing of Chocosuisse

Shared Goodwill
Chocosuisse Union des Fabricants Suisse de Chocolat v
...

But “trade” defined very widely, see
 British Diabetic Association v Diabetic Society Ltd [1995] 4 All ER 812 (charity)
 Burge v
...
Associated Newspapers Ltd [1998] RPC 261 (author)
Owning “goodwill”
Goodwill is a tradeable commodity – for consequences, see IN Newman Ltd v Adlem
[2006] FSR 16 (CA)
Sometimes, it can be difficult to establish exactly who is the proprietor of goodwill - see,
for example, Scandecor Development AB v Scandecor Marketing AB [2002] FSR 7 (HL)

2
...
1 NATURE OF THE DEFENDANT'S REPRESENTATION
 Spalding v Gamage (1915) - 'So long as the representation confuses the public
in a relevant way, the means by which this comes about is irrelevant'
DEFENDANT'S STATE OF MIND:
There is no need for the misrepresentation to be conscious, deliberate, intentional or
fraudulent - HFC Bank plc v Midland Bank plc [2000]
 Parker Knoll v Knoll International [1962] - Despite dicta to the effect that
individuals have a 'natural and inherent right' to use their own name, the HL
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denied that a person was entitled to use their own name to indicate that their
goods are the goods of another
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Words
D makes a statement that links them either exiplicitly or implicitly to C
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2
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 Bovril v Bodega Co
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 Associated Press v Insert Media [1991] - D places their goods in close
proximity to that of C
...
the position might have been different,
if the 2 products were delivered at the same time
...
2 WHAT TYPE OF SUGGESTIVE CONDUCT IS ACTIONABLE?
1
...

Also where D uses a word/name that the public associates with C's business
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 Kimberley Clark v Fort Sterling [1997] - as a part of the D's campaign to
promote the NOUVELLE toilet roll, D offered to placate customers who had
bough NOUVELLE but were dissatisfied with it, by replacing NOUVELLE with
ANDREX toilet paper
...


2
...

'
...
The external appearance of the toothpaste tube was the same in
different countries but the quality varied
...
Colgate UK, a
wholly owned subsidiary of Colgate US, initiated an action to prevent Markwell
from importing lower quality COLGATE toothpaste, which had been sold in
Brazil, into the UK
...
Given that D had made a misrepresentation to customers
in the UK as to the character and quality of the Brazilian toothpaste, it was
irrelevant that the goods were originally produced and sold by a subsidiary of
Colgate US
...
French champagne house have been
able to stop other traders who do not make drinks with those characteristics, eg
producers of the drinks SPANISH CHAMPAGNE OR ELDERFLOWER
CHAMPAGNE, from using the term champagne
...
MISREPRESENTATION THAT C HAS CONRTOL/ RESPONSIBILITY OVER THE
GOODS/SERVICES
D gives the suggestion that C has some type of control or responsibility over D's goods
...
This was
because the members of the public would have thought that the social club was
either a Branch of the plaintiff association, or the plaintiff association was in
some way responsible for its creation
...
It is not in my opinion sufficient to demonstrate that there must be
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a connection of some kind between the D and the C, i it is not a connection which
would lead the public to suppose that the plaintiff has made himself responsible
for the quality of D's goods/services
...
Personality Merchandising
The practice whereby celebrities use their names and images to endorse and associate
themselves with products and services -UK law refuses to recognise a right of
personality
 Lyngstrad v Annabas Products [1977]-the pop group ABBA complained that D
was selling paraphernalia that ore the name and image of the group
...
The
Ds were not doing anything more than catering for a popular demand among
teenagers for effigies of their idols
...
The
Supreme Court of New South Wales held that in so doing the D had made a
misrepresentation that there was a connection between the claimants and the
defendants
...

English cases have struck to view that passing off requires a misrepresentation
...

A more sympathetic approach :
 Irvine v Talksport [2002] - Formula 1 racing driver, Eddie Irvine brought an
action against Talksports for using his image on a promotional brochure
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Irvine brought an action for
passing off and he won
...
The
court found that the Talksport's bronchure had given the impression that Irvine
had endorsed the radio station
...

 Robyn Rihanna Fenty v Arcadia Group Bands [2013]- The court said that
English law does not recognise a general right for a person to control the
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reproduction of their image
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The main issue was whether, in selling the Tshirt with the picture
of Rihanna on it, Topshop had made a misrepresentation about trade origin
...
approved by Rihanna
herself
...
Character Merchandising
Involves the application of images of cartoon and other fictional characters to
merchandise
...

 Mirage Studios v Counter-Feat Clothing [1991] - the D were found liable for
passing off when they applied the claimant's characters, the Teenage Ninja
Mutant Turtles , to their clothing
...
A misrepresentation to the public that the goods were 'genuine' (that the
drawings were the C's drawings)
2
...

The claimant must show that the public understood that the goods were licensed and
that they bought the merchandise on that basis!
 BBC Worldwide v Pally Screen Printing [1998] - the BBC owned CR and
merchandising rights to the popular children's characters known as the
Teletubbies
...

 'The plaintiffs need to show that they have built up the necessary reputation so
that members of the public would look at this type of artwork and consider it to
represent the plaintiffs or products made with the plaintiff's approval
...

REVERSE PASSING OFF
The impression that the defendant is the source of the claimant's goods/services
...

 Bristol Conservatories v Conservatories Custom Built [1989] - both C and D
were engaged in the business of designing and selling conservatories
...
In doing so, they led customers to believe that the conservatories
were examples of the D's own design and craftsmanship
...
The CA held that the D had made a misrepresentation that its goods
were of the same quality as the claimant's
...
The damage caused was the diversion of sales from the claimant to the
defendant
...

COMPARATIVE ADVERTISING
To show the advertiser's wares in a favourable light, comparative advertisements
usually emphasize differences in things such as price, value , durability or quality
...
Equally, for
the D to say that their goods are similar to or better than the C does not amount
to passing off
...
Opinion poll
indicated that members of the public treated these advertisements for BK
hamburger called 'Big Mac' , or as an improved version thereof
...

 Kimbley Clark v Fort Sterling- it was likely to induce purchasers into thinking
that NOUVELLE was another product 'from the ANDREX stable or that ANDREX
is in some way behind the promotion
...
3 IS THE MISREPRESENTATION DECEPTIVE?

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The claimant needs to show that D's misrepresentation is deceptive
...


WHO MUST BE DECEIVED?




Where D has made a misrepresenation that suggests that the claimant is the
source of the D's goods, and that the goods of the C and the D are similar, the
court considers the impact that the misrepresentation has upon the claimant's
customers
...

 Chocosuisse case (Chocosuisse v Cadbury [1999] - those people confused into
thinking that a chocolate bar swiss CHALET was made from Swiss chicolate were
fewer than those who had not been deceived
...

WHEN MUST THE DECEPTION OCCUR?
 Bostik v Sellotape- at the time of the purchase
 Clark v Associated Newspapers [1998]- The point in time when the product is
consumed and not when it's purchased -the relevant time to consider whether
the public is confused is when the person reads the story, rather than when the
newspaper was purchased
...

 Fine and Country v Otokoks - broader view- damage caused by passing off may
successfully be claimed if a customer is deceived into going into one shop
thinking it to be another if it can be established that, but for the deception, he
might have gone in to the claimant's shop
...

FACTORS TO BE TAKEN INTO ACCOUNT WHEN DECIDING WHETHER
MISREPRESENTATION IS DECEPTIVE:
i
...


The similarity of the D's sign- if a person was o see the signs separately, would
they mistake the D's product for that of the claimant? - Wagamama v City Centre
Reastaurants - D= RAJAMAMA - very similar to WAGAMAMA in form

iii
...

However, this idea has been diluted
...


iv
...


The characteristics of the market - where consumers are well informed or
particularly attentive to detail, small differences between signs may be sufficient to
avoid a finding of deception
...


The intention of the D - not a prerequisite liability, but it will assist a C if they can
how that a D has acted fraudulently
...
Whether the D has made a disclaimer- possible for D to correct any
misunderstanding that their actions may potentially create -Consorzio Parma v
Marks and Spencer- 'Sliced', in front of the C's distinctive designation 'Parma ham'
Effectiveness of the disclaimer- Edge v Nicholls - the disclaimer was ineffective
because consumers of the goods relied on the get-up, rather than the name of the
product
...


Whether the D is attempting a parody or satire- Miss World v James St
Productions -the audience needs to understand the D's aim to ridicule the original
...
4 PROVIDING DECEPTIVE MEANS OR INSTRUMENTS OF FRAUD
Passing off against someone who provides the means or facilities that enable the passing
off to take place in the first place
 Lever v Goodwin- D sold soap of a similar get-up with the C
...
The manufacturer in this case put 'an instrument of fraud' into the
retailer's hands
...
the means of deceiving the ultimate purchaser?' in this case yes
...
co
...
They were equipped with or intending to equip another with an
instrument of fraud
...

 French Connection v Sutton- D who registered 'fcuk
...
the court said that this was not an incredible
argument, because the letters FCUK was widely used by internet users as an
alternative to 'fuck' , usually to access sites containing pornographic material
...
DAMAGE
3
...
DIVERSION OF CUSTOM (LOST SALES)
A
...
The damage is self evident: it is the loss of profit on the sale of
goods/services that the claimant suffers
...

B
...

 Lego v Lemelstrich- loss of potential profits includes the loss of chance to
expand in a new field
...

On the basis that LEGO's reputation extended beyond children's toys to
include garden sprinklers, the court found that D's use of the LEGO name in
relation to garden equipment was likely to damage Lego's goodwill
...

C
...


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 Mirage Studios v Counter-Feat Clothing - the creators of Teenage Mutant
Ninja Turtles , suffered damage when the D licensed others to reproduce the
cartoon characters on clothing
...

Contrasting
 Stringfellow v McCain - D manufactured a new brand of long, thin ovenready chips called STRINGFELLOWS
...
C was the owner of a well
known nightclub called STRINGFELLOW's
...
the court refused to
grant relief on the ground that it was unlikely that the misrepresentation
would cause Stringfellow any damage
...
there should be clear and cogent proof of
actual damage or real likelihood of damage
...
INJURY TO REPUTATION
Damage to reputation where D's misrepresentation leads the public to believe that the
goods/services of the claimant and the D are somehow related
...

 eg Annabel’s v Schock [1972] FSR 261; Sony v Saray Electronics (London) Ltd
[1983] FSR 302 (CA)- A well knwon London club named 'Annabel's was granted
relief to prevent D from trading as Annabel's Escort Agency
...

 Mirage Studios v Counter-Feat Clothing- since the public associates the goods
with the creator of the characters, the depreciation of the image by fixing the
Turtle picture to inferior goods and inferior materials may seriously reduce the
value of the licensing right
...
LOSS OF CONTROL
 eg Associated Newspapers Ltd v Express Newspapers [2003] FSR 51- The
defendant proposed to use the names “The Mail”, “Evening Mail” and “London
Evening Mail” for its new free London newspapers
...

 Held: There was a real threat that the word “Mail” would feature prominently in
the new newspapers and that there would be no campaign to prevent confusion
among the public
...
The claimant had goodwill and reputation in the
name “Mail”, particularly in London and the South East
...
The passing off claim was therefore made out and an
injunction was appropriate
4
...

This applies where the public is not confused about the source of origin of the goods, or
where it's unlikely that the reputation will be damaged
...
C brought an action against D (producer of a non
alcoholic sparkling beverage called ELDERFLOWER CHAMPAGNE)
...
The D's use of 'champagne' had caused the requisite
damage to sustain a passing off action
...

Doubted Dilution in this case:
 cf
...
Harrodian School [1996] RPC 697 (CA) - Millett LJ held that it
was unlikely that as a result of the D's activites, the Harrods name would lose its
distinctiveness or become a generic term to refer to shops that sold luxury
goods
...

 Sir Robert McAlpine Ltd v Alfred McAlpine plc [2004] RPC 36 - D was guilty of
passing off when it decided to rebrand itself as MCALPINE
...

 British Telecommunications v One in a Million [1998] - CA held that people
who registered and dealt in Internet domain names, such as
'marksandspencer
...
uk, were liable in passing off
...


4
...
GOODWILL
Extended passing off recognises that a class or group of traders may share goodwill in a
name that is distinctive of a particular class of goods, such as ADVOCAAT, CHAMPAGNE,
VODKA, GREEK YOGURT
...
Claimant brought a passing off action against D for
selling a product called SPANISH CHAMPAGNE
...
This was because the name CHAMPAGNE indicated a
sparkling wine that came from the Champagne district in France, was made by a
particular method, and was made only from grapes sourced from the
Champagne region
...

 Warnink v Townend - HL held that extended passing off was not confined to
drinks or to indications of geographicaal origin
...
In this case, the C
produced ADVOCAAT, a drink manufactured out of eggs and a spirit called
'brandewijn'
...

The HL held that this amounted to passing off
...

Not necessary that the class of traders should be defined by reference to the
locality in which the product was produced; the crucial thing was that the
name was distinctive of a particular class of goods
...


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 Chocosuisse v Cadbury [1998] - For the C to succeed, it was necessary
doe rhwm to show that 'a significant part of the public took the words
'Swiss chocolate' to indicate a particular group of products having
discrete reputation for quality
...

Still, the C needs to show goodwill in the name
...

Classic goodwill- owned jointly, each owner cannot prevent other owners from
using the particular sign, all joint owners, however, may prevent others from
using the sign
...
All that
was required was that the designation 'Swiss chocolate' was takeb by a
significant section of the public to indicate a particular group of products
(chocolate made in Switzerland) having discrete reputation distinct from
other chocolate
...


2
...

In extended passing off, protection is given to a name or word that has come to mean a
particular product rather than a product from a particular trader
...
In the situation in which UK customers believed that
the phrase 'Greek yoghurt' meant that the yoghurt was made in Greece, it
was held that the D's use in the UK of the term 'Greek yoghurt' to
describe yoghurt made in the US plainly involved a misrepresentation
...
DAMAGE
The most relevant form of damage is dilution
...


UNFAIR COMPETITION
Does not exist in the UK
Unfair competition declares that anyone who for the purpose of competition commits
acts in the course of trade that infringe honest practice is liable to incur injunctions or
damages
...

This judicial tendency was reversed in : Cadbury Schweppes v Pub Squash - PC
made it clear that there is no cause of action for misappropriation as such
...
The courts had gone too far in Wanink and there was no interest in
developing passing off into a tort of unfair competition
...
The C tried to
convince the Court that this was a form of unfair competition that the law should
prohibit
...





Undesirable because it was a basic rule that competition was not only lawful but
the mainspring of the economy
...


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