Panel Session 3: Design protection in practice April
Panel Session 3: Design protection in practice April 26, 14:00-15:15 www.aippi.org Sara Ashby, Wiggin (Moderator) Elisabeth Fink, Boards of Appeal, EUIPO Prof. Remdio Marques, University of Coimbra Fernando Rodrguez, FJF Legal 2 www.aippi.org Roadmap identification of the prior design
(Easy Sanitary Solutions) representation of the design (Nike) evidence of disclosure (Kneidinger, Crocs) Jurisdiction (BMW, Nintendo) copyright protection for designs (Cofomel) 3 www.aippi.org Elisabeth Fink Boards of Appeal, EUIPO
4 www.aippi.org Design protection in practice Points to be considered in the design invoked: C-361/15 and C-405/15 Shower drains T-90/16 Electronic wristband T-286/16 Toilet seats T-651/16 Crocs
w.aippi.org 5 www.aippi.org Identification of the prior design C-361/15 and C-405/15 of 21.09.2017 Shower drains Prior design invoked in the invalidityw.aippi.org application Contested RCD 6 www.aippi.org
Identification of the prior design C-361/15 and C-405/15 of 21.09.2017 Shower drains Picture of a cover plate for a drain collector submitted by the invalidity applicant w.aippi.org Contested RCD 7 www.aippi.org Identification of the prior design C-361/15 and C-405/15 of 21.09.2017 Shower drains
Invalidity Division: RCD declared invalid for lack of novelty. w.aippi.org Cover plate is the only visible element. Features differ in immaterial details. 8 www.aippi.org Contested RCD Identification of the prior design C-361/15 and C-405/15 of 21.09.2017 Shower drains Board of Appeal: Decision annulled and case remitted.
w.aippi.org Both parties appealed. Contested RCD 9 www.aippi.org Identification of the prior design C-361/15 and C-405/15 of 21.09.2017 Shower drains General Court: Decision annulled. Board was wrong only to w.aippi.org consider the cover plate as prior design. Holder and EUIPO appealed. 10
www.aippi.org Contested RCD Identification of the prior design C-361/15 and C-405/15 of 21.09.2017 Shower drains CJEU Appeals dismissed. Case pending before the Board as R2664/2017-3 w.aippi.org 11 www.aippi.org
Identification of the prior design C-361/15 and C-405/15 of 21.09.2017 Shower drains Cover plate is only one of several components for building a drainage device for liquid waste. Invalidity applicant failed to present a complete reproduction of the prior design ( 66). It is not for the Office to construe the prior design from the documents submitted ( 69). It must be clear if the prior design is for a part of a product or a product in its entirety. 12 www.aippi.org Identification of the prior design
C-361/15 and C-405/15 of 21.09.2017 Shower drains The product to which the conflicting designs are to be applied is irrelevant in the assessment of novelty ( 96, 104). Findings of the GC that the sector concerned is relevant in the assessment of individual character not challenged by the Office ( 135). The prior design must allow for an identification of the relevant product. 13 www.aippi.org Representation of the design T-90/16 of 4/07/2017 Electronic wristband
w.aippi.org Prior design 14 Contested RCD www.aippi.org Representation of the design T-90/16 of 4/07/2017 Electronic wristband Only features which are clearly visible in the representation as registered are relevant ( 55). Any explanations provided in the application or during the invalidity proceedings are irrelevant since they are not published ( 58, 59). You cannot rely on features not disclosed in the
representation. 15 www.aippi.org Representation of the design T-90/16 of 4/07/2017 Electronic wristband Where the RCD is reproduced in black and white and the prior design shows a feature in colour, such colour is irrelevant ( 65). Views in black and white do not save you from prior designs in colour. 16
www.aippi.org Representation of the design T-286/16 of 21/06/2017 Toilet seats Prior design 17 Contested RCD www.aippi.org Representation of the design T-286/16 of 21/06/2017 Toilet seats The cross section view submitted before the Court cannot be taken into account ( 38 42). Make sure the technical
drawing is clear. 18 www.aippi.org Evidence of disclosure T-651/16 of 14/03/2018 Crocs w.aippi.org Pictures from the holders website submitted before the Invalidity Division 19 www.aippi.org
Contested RCD Evidence of disclosure T-651/16 of 14/03/2018 Crocs w.aippi.org Pictures submitted before the Board 20 www.aippi.org Contested RCD Evidence of disclosure
T-651/16 of 14/03/2018 Crocs Declaration of invalidity confirmed. Board was correct to take the better versions into account under Article 63(2) CDR ( 51). One disclosure event, if proven, is enough ( 57). Holder failed to disprove disclosure ( 67). Make sure to have clear pictures of the prior designs. 21 www.aippi.org Fernando Rodrguez FJF Legal 22
www.aippi.org International design litigation Litigation in IP is quite often international when disputes are international, rules of jurisdiction must be taken into account to design a litigation strategy. in Europe jurisdiction is governed by the Brussels I Regulation (Regulation 1215/2012). However, for Unitary IP Rights the corresponding regulations establish their own rules. the rules on jurisdiction in the Unitary Rights Regulations are lex specialis (Judgment CJEU of 5 June 2014, Coty Germany (C-360/12) BMW and Nintendo are two new examples of this
lex specialis character of rules of jurisdiction in CD and EUTM Regulations. 23 www.aippi.org Judgment CJEU 13 July 2017 (C433/16) Acacia v BMW Proceeding that Acacia filed in Italy against BMW (action for declaration of non-infringement + action for abuse of dominant position + actions for unfair competition). In its first writ, BMW contested the jurisdiction of the Italian court Could the Italian Court declare jurisdiction with respect to the actions for the declaration of non-infringement? The answer of the CJEU is NO:
24 According to Articles 81(1)b and 82 CDR, when the defendant is domiciled in a Member State of the EU, an action for a declaration of non-infringement can only be filed before the Courts of that Member State alone The rule on jurisdiction in Article 5(3) of Regulation No 44/2001 does not apply to actions for a declaration of non-infringement under Article 81(b) of Regulation No 6/2002 www.aippi.org
Judgment CJEU 13 July 2017 (C433/16) Acacia v BMW The CJEU confirms what is set forth in Art. 82.5 CDR (the forum delicti commissi to an action for declaration of noninfringement is excluded by the CDR). The Judgement confirms a completely different approach to actions for declaration of non-infringement, depending on if they refer to national IP rights or Unitary IP rights. 25 for national IP rights, these actions can be brought before the
courts of the forum delicti commissi, pursuant to art. 7.2 (former 5.3) Brussels I recast Regulation (as it was declared in the Judgment ECJ of 25 October 2012, Folien Fisher and Fofitec (C-133/11) for Unitary IP Rights, the application of forum delicti commissi to these actions is excluded in Art. 82.5 CDR. The reason why the CDR includes a different approach is to try to avoid the so-called torpedo actions www.aippi.org Judgment CJEU 13 July 2017 (C433/16) Acacia v BMW What about the actions for abuse of dominant position and the actions for unfair competition? Do they fall within the scope of Art. 5(3) Regulation No. 44/2001 (forum
delicti commissi) or within the scope of the jurisdiction regime established by CDR? when filed in the wake of the actions for declaration of noninfringement, and if the basis for those actions is essentially that the design owner objects to the commercialization of replicas of that design, the determination of jurisdiction must be based, for the entire proceedings, on the regime established by the CDR being mainly based on the argument that the commercialization of alloy rims would be legitimate, if the court jurisdiction for handling these actions was based on Art. 7.2 (former 5.3) of the Brussels Regulation that would compromise the effectiveness of Art. 79.3 CDR 26 www.aippi.org
Judgment CJEU 27 September 2017 (Joined cases C24/16 and C-25/16) Nintendo v BigBen BigBen France produced accessories compatible with the Wii and sold them directly to consumers and to its subsidiary Big Ben Germany. Big Ben Germany did not have its own products Nintendo filed a civil action in Germany against Big Ben France and Big Ben Germany (action for a CD infringement in the whole territory of the Union) Did the German courts have jurisdiction to hear about the complaints filed against both defendants in respect of the acts of infringement in the whole EU? What was the law applicable to the dispute (action for infringement in various member states)? 27
www.aippi.org Judgment CJEU 27 September 2017 (Joined cases C24/16 and C-25/16) Nintendo v BigBen Jurisdiction: With respect to Big Ben Germany: clear (82.1 and 83 CDR) With respect to Big Ben France (not domiciled in Germany but in France) Was there any rule that gave jurisdiction to the German courts to hear about the complaint? 82.5 CDR? (limited to local infringement) 6.1 (now 8.1) Brussels I Regulation (global infringement). Art. 6.1 (now 8.1 Brussels I recast Regulation) Actions closely connected? YES Risk of irreconcilable judgments? YES
28 www.aippi.org Judgment CJEU 27 September 2017 (Joined cases C24/16 and C-25/16) Nintendo v BigBen The ECJ has deviated from its interpretation in relation to parallel IP rights: ECJ Judgement 13 July 2006, Roche Nederland (C-539/03): infringement of a European patent in multiple Member States by multiple codefendants belonging to the same group: there is neither the same situation of law nor the same situation of fact In Nintendo, the CJEU understands that in this case there is: The same situation of law
The same situation of fact 29 www.aippi.org Judgment CJEU 27 September 2017 (Joined cases C24/16 and C-25/16) Nintendo v BigBen Same situation of law Unitary character of the rights conferred by a Community design Partial harmonization of the means for enforcing Intellectual Property rights (Directive 2004/48) Same situation of fact Because of the connections between the defendants
The circumstances of the case reveal that this is a case in which two companies belonging to the same group follow a common policy decided by one of them (thus, the existence of the same situation of facts must cover all the activities of the various codefendants) 30 www.aippi.org Judgment CJEU 27 September 2017 (Joined cases C24/16 and C-25/16) Nintendo v BigBen Applicable Law: Art. 8(2) Rome II Regulation applies 2. In the case of a non-contractual obligation arising from an infringement
of a unitary Community intellectual property right, the law applicable shall, for any question that is not governed by the relevant Community instrument, be the law of the country in which the act of infringement was committed. In Nintendo it is difficult to determine what is/are that/those countries because the website is published in France but it is directed to several Member States 31 www.aippi.org Judgment CJEU 27 September 2017 (Joined cases C24/16 and C-25/16) Nintendo v BigBen
The CJEU provides some clarifying the expression (in Art. 8.2 Rome II Regulation) must be interpreted as the country where the event giving rise to the damage occurred When the same defendant is accused of various acts of infringement in various member states, the correct approach is to make an overall assessment of the defendants conduct 32 www.aippi.org Judgment CJEU 27 September 2017 (Joined cases C24/16 and C-25/16) Nintendo v BigBen
In that regard, the Court says that the act by which an operator uses electronic commerce to offer for sale infringing products on a website which is accessible to customers in multiple member states, constitutes an offer for sale of those goods (and therefore that operator is offering for sale and using within the meaning of Art. 19 CDR). Therefore, in these circumstances, the event giving rise to the damages is the act by which the operator offers the infringing goods by placing an offer for sale on its website. And consequently, the place where the event giving rise to the damage occurred is the place where the operator activated the process of putting the offer for sale online. 33 www.aippi.org
Judgment CJEU 27 September 2017 (Joined cases C24/16 and C-25/16) Nintendo v BigBen For Community designs, in those cases where the place of the initial act of infringement is located in the country of the defendants domicile or of its establishment in the EU, the court will be able to hear about the infringement of the community design in the whole territory of the EU and in accordance with the law of that member state However, for national IP rights: Art. 8.1 Rome II Regulation. 1. The law applicable to a non-contractual obligation arising from an infringement of an intellectual property right shall be the law of the country for which protection is claimed.
34 www.aippi.org To conclude Nintendo is a good judgment from the point of view of an IP litigator, since it will facilitate the enforcement of our clients unitary titles (and this holds true not only for the determination of jurisdiction over all the co-defendants but also for the determination of the law applicable to a pan-European injunction). As regards BMW, it is also positive, as it provides some clarity, reminds us of the character of lex specialis of the provisions contained in the CDR with respect to those of the Brussels I Regulation, and will serve to restrain attempts to circumvent the rules on jurisdiction of the CDR.
35 www.aippi.org Prof. Remdio Marques University of Coimbra 36 www.aippi.org EU National Design and Copyright Protection COFEMEL C-683/17) COFEMEL
(CASE CASE C-683/17 Defendant: Cofemel Sociedade de Vesturio SA Plaintiff's: G-Star Raw CV Questions referred (request for preliminary rulling lodged on 6 December 2017) publication (OJ C 52 from 12.02.2018, p. 23). w.aippi.org 37 www.aippi.org
COFEMEL CASE C-683/17 1) Does the interpretation by the Court of Justice of the European Union of Article 2(a) of Directive 2001/29/EC preclude national legislation in the present case, the provision in Article 2(1)(i) of the Cdigo de Direitos de Autor e Direitos Conexos (CDADC) which confers copyright protection on works of applied art, industrial designs and works of design which, in addition to the utilitarian purpose they serve, create their own visual and distinctive effect from an aesthetic point of view, their originality being the fundamental criterion which governs the grant of protection in the area of copyright? w.aippi.org 38
www.aippi.org COFEMEL CASE C-683/17 2) Does the interpretation by the Court of Justice of the European Union of Article 2(a) of Directive 2001/29/EC preclude national legislation in the present case, the provision in Article 2(1)(i) of the CDADC which confers copyright protection on works of applied art, industrial designs and works of design if, in the light of a particularly rigorous assessment of their artistic character, and taking account the dominant views in cultural and institutional circles, they qualify as an artistic creation or work of art? w.aippi.org
COFEMEL CASE C-683/17 New Radar 41 w.aippi.org www.aippi.org Arc Model COFEMEL CASE C-683/17 w.aippi.org
42 www.aippi.org COFEMEL CASE C-683/17 PORTUGUESE RELEVANT LEGAL PROVISIONS: Art. 2.(1)(i) Cdigo de Direitos de Autor e Direitos Conexos (Copyright Act, 1985): The intellectual creations in the literary, scientific and artistic domain comprise: (...) works of applied arts, industrial designs and design works which constitute artistic creation. w.aippi.org
43 www.aippi.org COFEMEL CASE C-683/17 DECISION OF THE COURT OF 1ST INSTANCE: The court of first instance (Intellectual Property Court) decided that it will always be said that in order for any work to benefit from the protection of copyright, it will have to be original in the terms above, being sure that Article 1, paragraph 1 of the CDADC requires that any copyrigtable work must belongs to the literary or artistic field. The reference, therefore, to Article 2 (2) (i), "artistic" creation seems to us to be mere redundancy when we speak of fashion designs. We interpret "artistic creation" as meaning a property of an "object" or design work, which can be enjoyed by the external senses (aesthetic
value), in this case, by the vision, with the potentiality of affecting a human being, emotional or cognitive level, regardless of any function or utility of the same object. 44 www.aippi.org COFEMEL CASE C-683/17 THE LISBON COURT OF APPEAL DECISION (FEBRUARY 21, 2017): The Court of Appeal confirmed the decision of the court of first instance, saying that industrial designs that are part of the world of fashion - namely, clothing (pants, t-shirts and sweatshirts) -, embodied in the final product for which they compete, may, according to the provisions of this legal provision, constitute a piece of art in the particular perspective for which they were created and as they are
understood and appreciated by the target audience for which they are intended, as well as by specialists and critics of the sector. 45 www.aippi.org COFEMEL CASE C-683/17 THE CJEU THERESHOLD: C-145/10 (Painer), 1 December 2011: an intellectual creation of the author reflecting his personality and expressing his free and creative choices. C-05/08 (Infopaq), 16 July 2009: if the elements thus reproduced are the expression of the intellectual creation of their author. C-168/09 (Flos), 27 January 2011: in the absence of harmonisation of
w.aippi.org copyright legislation, the principle of cumulation of protection under specific registered design protection law and under copyright law ( 38). 46 www.aippi.org COFEMEL CASE C-683/17 w.aippi.org 47 EU RELEVANT LEGAL PROVISIONS: Article 17 of the Design Directive provides: A design protected by a design right registered in or in respect of a Member State
in accordance with this Directive shall also be eligible for protection under the law of copyright of that State as from the date on which the design was created or fixed in any form. The extent to which, and the conditions under which, such a protection is conferred, including the level of originality required, shall be determined by each Member State. Article 96(2) of the Design Regulation contains an identical provision in relation to Community Designs. www.aippi.org COFEMEL CASE C-683/17 CUMULATIVE PROTECTION (COPYRIGHT / DESIGN RIGHT) In all the Member States, cumulative protection under copyright and design law is possible. In order to benefit from cumulative protection, the design needs to satisfy the requirements for copyright protection under copyright law, and the requirements
for protection under design law. In some Member States, the test for copyright protection is higher than for design protection; originality is more difficult to prove than novelty. In France and Belgium there is a total cumulative protection because of the doctrine of lunit de lart: those designs that are eligible for design right protection are also copyrightable. In Portugal, the requirement for copyright protection for designs used to be higher than that for copyright of other artistic works. This was due to the teaching of Prof. Oliveira Ascenso, as was the case in the Italian legal system. 48 www.aippi.org COFEMEL CASE C-683/17 Today (despite the provision of art. 200 of its Industrial Property Code) Portugal no longer imposes a higher threshold for the originality or more stringent requirements for the protection by copyright of the appearance of the products (doctrine of Remdio Marques,
Nuno Sousa E Silva, Menezes Leito). In the last few years, however, a few Member States copyright laws have changed due to the Flos decision declaring that EU copyright and design protection is cumulative. Even the German position had changed in a recent judgment where it was held the longstanding approach requiring a higher level of originality for applied art than for other w.aippi.org art forms should be changed; and the same test of originality should apply to all types of artistic works (Independent Toy Designer v Toy Manufacturer, Geburtstagszug/Birthday Train, German Federal Supreme Court, I ZR 143/12, 13 November 2013). 49 www.aippi.org
COFEMEL CASE C-683/17 The UK has amended its provision to remove the 25 year copyright limit on artistic works (Section 74, Enterprise and Regulatory Reform Act 2013). The Italian courts have commenced to give copyright protection to artistic works which have recognised artistic stature (e.g., Cassina SpA v Alivar Srl and Galliani Host Arredamenti Srl, Case C-198/10, 9th September 2011). In Portugal, it was wrongly held that, in order for a work of applied art to benefit from copyright, it must be eligible for registration as a design, which may not be the correct approach (Court of Appeal of Guimares, 27th February 2012). 50 www.aippi.org COFEMEL CASE C-683/17
THE SUPREME COURT (E.U.A.) DECISION IN STAR ATHLETICA V. VARSITY BRANDS, MARCH 22, 2017 (A NEW SEPARABILITY TEST) An artistic feature of the design of a useful article is eligible for copyright protection if the feature (1) can be perceived as a two or three-dimensional work of art separate from the useful article, and (2) would qualify as a protectable pictorial, graphic, or sculptural work either on its own or in some other medium if imagined separately from the useful article. The Supreme Court affirmed the Sixth Circuit's finding that Varsitys cheerleading uniform designs satisfy these requirements under the new test promulgated by the Supreme Court. Under the Star Athletica imagination test, if a design not affixed to a useful article can be protected by copyright, then it can be protected even if it is affixed to the useful article. The new test no longer considers the creator's intent, the designs marketability and the designs physical separability. w.aippi.org 51
www.aippi.org COFEMEL CASE C-683/17 THE DESIGNS DIRECTIVE 98/71 w.aippi.org 52 The Designs Directive 98/71 did not amended the law relating to forms of protection other than (national) registered designs. The fact that the design of a product is registered must not deny copyright protection which would have been available if the design had not been registered. There did not appear to be any requirement for amendment to the Portuguese Copyright Act 1985. Recital 32 of the Community Design Regulation reiterates that the recognition of the freedom of Member States to determine the threshold of
copyright protection is necessary in the absence of complete harmonization. Reaffirming the freedom of Member States even though, by 2002, there had been considerable harmonization of other aspects of copyright (most obviously via the Information Society Directive, 2001/29). www.aippi.org COFEMEL CASE C-683/17 PROBLEMS RESULTING FROM THE CUMULATIVE PROTECTION OF COPYRIGHT AND DESIGN RIGHT w.aippi.org 53 It is yet not unclear whether the 3-year unregistered Community Design, or even the 25-year Registered Community Design or national registered design regimes, will offer the equivalent
value as offered under the copyright umbrella, which comes with a 70 post mortem auctoris duration. The provisions in respect of defences, limitations of scope, and repair clauses applicable to design law do not currently align to those offered under copyright law. In fact, the Flos decision of the Court of Justice of the European Union concerning cumulation with copyright may enable an extension of copyright protection for spare parts (already in existence in some Member States) that likewise has the power both to divide the European market and to limit competition in the repair market which would be permitted in many countries under design law. The Court of Justice, in the Flos decision, and the AG Opinion in the Donner case, has given a strong indication that this implies total cumulation according to the French approach. www.aippi.org COFEMEL CASE C-683/17 Any extension of copyright law to spare parts also has the potential to divide the market as a
result of the different implementations of the discrimination provisions of Article 2(7) of the Berne Convention. The outcome of this scenario is as follows: component parts of complex products, which pass the design threshold will also probably be protectable by copyright law, especially with the new standards set by the CJEU in several copyright decisions. An extension of copyright laws to protect spare parts does not appear to have been an intended consequence. Neither the Design Directive nor the Design Regulation, or other EU legislation, provides explicitly for it. If this extension is considered undesirable, amendment to EU copyright legislation may be necessary. The repair clause of Article 110 of the Design Regulation does not create a freestanding right to repair, according to the Court of Justice in Case C-500/14 Ford Motor Company v Wheeltrims srl. 54 www.aippi.org
COFEMEL CASE C-683/17 Accordingly, consideration should be given to the competitive effects of this probable extension of copyright law to spare parts. It will be desirable to extend any introduction of a repair clause within EU design legislation to any copyright subsisting solely by virtue of Article 96(2) of the Design Regulation (and Article 17 of the Design Directive), for example, as otherwise those Member States which have liberalized their design laws relating to spare parts may find that liberalization undercut by the effect of cumulation with copyright. 55 www.aippi.org
COFEMEL CASE C-683/17 WHAT WOULD BE THE CORRECT APPROACH IN COFEMEL CASE? Article 17 of the Designs Directive and Article 9 of the Information Society Directive, both of which reserve the question of the conditions for, and content of, protection of copyright of designs to Member States Article 9 Directive 2001/29 states that This Directive shall be without prejudice to provisions concerning in particular patent rights, trade marks, design rights, utility models . Article 9 should be read as if it said that the Directive was without prejudice to design rights or copyright in designs (including copyright in works of applied art). Also Recital 60 Directive 2001/29 states The protection provided under this Directive should be without prejudice to national or Community legal provisions in other areas, such as industrial property...which may affect the protection of copyright or related rights. 56 www.aippi.org
COFEMEL CASE C-683/17 As I mentioned above, Recital 32 and art. 96(2) of the Community Design Regulation reiterates that the recognition of the freedom of Member States to determine the threshold of copyright protection is necessary in the absence of complete harmonization. So, if the Information Society had been intended to harmonize copyright law in relation to designs, then one would have expected this to have been acknowledged in the Community Design Regulation, passed only 7 months after the adoption of the Information Society Directive. In the travaux of the Designs Directive the Commission never stated that the cumulative application of design protection was mandatory, and that consequently national legislation needed to be amended where it provides that copyright protection cannot, or can only under certain conditions, be cumulated with protection under specific design protection law.
57 www.aippi.org COFEMEL CASE C-683/17 The Information Society Directive does not overrides the express terms of Article 17 of the Design Directive reserving the right to Member States to determine both the conditions and extent of protection. The focus of the copyright' directive was on the information society (and specifically implementation of the WIPO treaties, which are often referred to as the WIPO Internet Treaties). As the title of the (Copyright) Directive makes clear, its aim was only to harmonize certain aspects of copyright; not all aspects, including the originality threshold. The directive on copyright in the content and interpretation of which the European Union Court of Justice sometimes relies on determining the protection of copyright designs stands on a peculiar environment for dealing with copyright protection of
unregistered designs, the commercial implications of which are still very much grounded in the buying and selling tangible products and artefacts. w.aippi.org If the Court of Justice of the European Union is right in Flos decision, then conditions that are left to Member States to determine when protection arises are effectively removed, because the CJEU case-law has determined that the relevant threshold is authors own intellectual creation. 58 www.aippi.org COFEMEL CASE C-683/17 So, works in applied art only benefit from the rights conferred by
Directive 2001/29 or by the Portuguese Copyright Act if they constitute, per se, an artistic creation, in the light of a particularly assessment of their artistic character, and taking account the dominant views in cultural and institutional circles of applied arts, they qualify as an artistic creation or work of art (partial cumulative protection). But saying this means to say that, probably, the designs of the pants and the sweat shirts can be, in the main proceeding (Portuguese Supremo Tribunal de Justia), qualified as artistic creations in cultural circles of applied arts. 59 www.aippi.org Thanks for your attention!
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