Across the Pond: The territorial nature of trade marks, and taking your brand abroad

One of the most important things to consider ifIntellectual Property Organisation (WIPO) in
you intend to carry out business internationally isGeneva (see WIPO website for list of countries). 
whether you are able to export your brand. At the time of writing not all countries are parties
Developing brand equity can be arduous andto the protocol - for example Canada and South
expensive, an investment that might be wasted inAfrica are not parties - and so to protect your
cases where you cannot operate under yourmark in those jurisdictions it will be necessary to
brand abroad.file individual applications for each.
Territorial nature of Trade MarksUnder the Madrid system, you make a single
Trade mark registration provides you with aapplication, and name the countries in which you
monopoly over the use of your brand names andwish to obtain trade protection, and make the
images in connection with the products andappropriate payments for those countries, which
services you offer.  This helps to preventthen have 18 months in which to raise any
consumer confusion between your offerings andobjections to your application.  The basic fee for
those of competitors, and gives you thethe application is in Swiss Francs and additional
opportunity to nurture a relationship betweenfees are payable depending on the number of
your customers and your brand.  However, tradecountries in which you seek to register your
marks are territorial.  This means that they onlymark;  if you later decide to expand to further
provide protection in the countries in which theycountries it is possible to add them as and when
are registered.  For example a UK registration willrequired.
protect your mark within the UK, and aThe Madrid system offers a number of
registration through the USPTO will preventadvantages, in terms of cost, administration, and
competitors from using it in the United States. flexibility.  For example, Once you file an
Community Trade Marks and the Madrid Systemapplication under the Madrid system, if objections
While trade marks are territorial, there are twoare raised on it in some countries that you are
systems that facilitate the process of extendingunable to overcome, your mark will not be
your mark across a variety of differentaccepted in those countries.  However, unlike the
countries.  In order to register your markCTM, your application will continue to be
throughout Europe, rather than registering in eachacceptable in other countries unless there are valid
member state individually, you can apply for aobjections in any of those countries.
Community Trade Mark (CTM).  A CTM protectsInternational Trade Mark Registration
your mark in all 27 European states, however, ifThe important points to remember are that while
your mark fails to meet the requirements of ayour brand name might be available in the UK, if
single member state, then protection is notyou intend to carry out business abroad you
granted in any of the others.should check the trade mark registers of the
To extend your name protection to jurisdictionsdifferent countries in which you wish to operate
outside of Europe, you will have to makebefore investing in marketing.  Once you have
separate applications.  For this purpose your UKdetermined its availability, the most cost effective
or EU application may form the basis for anway of protecting your brand internationally is
application for trade marks in other countriesthrough the Madrid Protocol, or with a CTM if you
which are members of an international systemonly require protection throughout the EU.
known as the Madrid system, through the World