No.6, 2002 (Total:No.6) Dcemeber 5th, 2002
"Haworth & Lexon Intellectual Property Law Newsletter" aims at introducing new cases and legal tendency in IP fields. All the comments do not mean the legal opinion of our firm and the firm does not have any legal liability for such comment. If you require any legal advice, we are willing to offer you considerate service. You can write E-mail to hl@hllawyers.com. If you have any interests and suggestions, or have any interests on some topics listed in this law newsletter, please contact with us.
Guidelines
★ Bubugao's patent right of design has been confirmed by initial court★ Initial court made decision of the Sina Vs. Sohu infringing case ★ Foreign software owner was compensated RMB 500,000 in the first instance★ The Lao Ma of Imperial City won its case of trademark & copyright infringement★ Hengsheng case on trademark has been settled in the final judgment★ Bone Power of the TianLion was not found infringement, defendant won the case in the second instance★ The newly established corporation selling the same product of the original company was found infringement in final court
Bubugao's patent right of design has been confirmed by initial court
Recently, Beijing No.1 Intermediate People's Court made an initial judgment in the case of Bubugao Vs. the Patent Reexamination Board of State Intellectual Property Office on invalid patent dispute, and ordered the Patent Reexamination Board to revoke its decision, which found the Bubugao's patent of design on its VCD Player was invalid.
Bubugao has been granted a design patent for its NO.99335291.X VCD Player on Apr. 12,2000.On Dec.24, 2000,Sony Entertainment brought up a request for invalid declaration, and believed that Bubugao's design patent has an resemblance with the prior existed design patent owned by Sony for its PC game machine. The Patent Reexamination Board adopted Sony's opinion, and made an announcement of invalid for Bubugao's VCD Player on Sep.5, 2001. Bubugao brought up for an administrative litigation.
After hearing the case, the court ensured that there is a lack of evidence in concluding that VCD Player and PC game machine both can play VCD disks, and there is no comparability between these two things. Furthermore, the patent document of PC game machine doesn't reveal the technique used for playing VCD disks, though the machine contains this kind of technique. Bubugao's reverse on this fact doesn't mean they accepted this contrast. Thus, there is a lack of evidence for defendant's invalid announcement, and the court ordered it be revoked.
The infringing case of Sina Vs. Sohu has been decided by initial court
Beijing No.2 Intermediate People's Court has made Civil Initial No.1754 court verdict on the case Sina Vs. Sohu.
The court states that Sohu's plagiarism of Sina's form of MP pictures and financial channels has already constituted an infringement of Sina's Copyright. The court ordered an immediately removing of the 388 MP pictures as well as the form of Top 100 entrepreneurs' success, all of which related with this case and whose copyrights belong to Sina. The court also ordered Sohu for a public apologize to Sina for 24 hours in Sohu's homepage and a compensation of RMB150, 000 with the litigation fee of RMB61, 813. The court rejected Sina's other litigation requests.
Foreign software owner was compensated RMB 500,000 in the first instance
In this case, Discreet logic Inc, a Canadian corporation, the plaintiff, is the copyright owner of the FLAME software. The plaintiff found that the defendant, a culture transmission corporation installed a set of FLAME utilizing for products making and development design, so the plaintiff brought up a complaint asking for a stop of infringe, an apology and compensation for their loss of RMB 1 million approximately.
During the trial, defendant apologized for their installation of FLAME without authorization, but they also defended that because the software related in this case hadn't registered in State Intellectual Property Office,the defendant couldn't sell it according the law.
After hearing the case, Beijing No 1 Intermediate People's Court believes that considering the facts that plaintiff, a Canadian corporation and our country are both the member of the Berne Convention,thus the copyright of the plaintiff is also under the protection of Chinese law. Even if the software hasn't been sold in China, it doesn't mean that the plaintiff's copyright can be utilized for free. As the defendant had already infringed the copyright of the plaintiff, the court ordered the defendant to stop infringement and make a public apology as well as a compensation of RMB 500,000.
The Lao Ma of Imperial City won its case of trademark & copyright infringement
On Dec 13,2002, Beijing No.1 Intermediate People's Court made decision of the Lao Ma of Imperial City Vs. the Lao Ma of Huangrong, and ruled that Huangrong failed the case and should stop their infringement immediately, and make public apology together with a compensation for RMB110, 000.
The plaintiff was founded in 1997. After registering several trademarks as "the Lao Ma of Huangcheng" and "Lao Ma Red", they used these trademarks with a slogan of "special flavor of Shichuan"in their own propaganda materials. Defendant, the Lao Ma of Huangrong, which was founded in 2001, also used the slogan of "special flavor of Shichuan"in their propaganda materials together with the trademark of "the Lao Ma of Huangrong" in their advertising light, which looks like the trademark of the Lao Ma of Huangcheng.
The court believes that the defendant's use of the other party's slogan without authorization infringed the right of the Lao Ma of Imperial City, and the prominent use of like trademark in the same field of service will lead to a misunderstanding of the consumer, thus the defendant constitute a infringement of the trademark.
Hengsheng case on trademark has been settled in the final judgment
Recently, Beijing Higher People's Court rejected the claim of Beijing Far east Hengshen electronic computer Group.
In this case, Beijing Hensheng science and technology develop corporation registered the trademark of "Hensheng", and after initial examination the Bureau of Trademark publicized the trademark on Apr 21,1999, objection time ending in July 20,1999. In the same year, the trademark of Henshen was registered by the Weichuang electronic co., and transferred to Beijing Far east Hengshen electronic computer Group. (Hereafter referred as "The Hengshen")
The Hengshen put forward a piece of objection letter to the Bureau of Trademark, and was rejected because the objection period was overdue.
Beijing Higher People's Court concluded that according to the law of Chinese trademark administration, a trademark after initial examination can be objected in the first three month after it making public, and because the Hengshen Group was overdue, the decision of Trademark Bureau was reasonable.
Bone Power of the TianLion was not found infringement; defendant won the case in the second instance
Beijing Higher People's Court rejected the pleading of plaintiff Chengyong suing the Tianjin TianLion biology engineering Corporation and the TianLion financial development co. Now the case has been submitted to the Supreme Court of PRC.
The plaintiff of this case has been granted the patent of invention of the technological process of high-Calcium bone power, the patent number ZL92113520.3. The plaintiff believes that TianLion Biology-engineering Corporation infringed his patent through the utilizing of the plaintiff's patent technology and the sale of the high-Calcium product. Thus, the plaintiff sued for an injunction and a compensation of his financial loss of RMB 10 million.
Beijing Higher People's Court entrusted Beijing Zitu Patent Consultation Center to take an expert evaluation on the problem whether the defendant's technology has a similarity with the plaintiff's. The result of the evaluation shows that the whole technology is not same or alike.
According to the evaluation, Beijing Higher People's Court concluded as follows: the plaintiff didn't have any evidence to testify that the defendant have infringed his patent, and the result of expert evaluation also doesn't support plaintiff's pleading.
The newly established corporation selling the same product of the original company was found infringement in final court
Beijing Genyun Electron Develop Center won its case suing for infringement of copyright and anti-malfeasance competition. Beijing No.1 Intermediate People's Court ruled that defendant stop the infringement, make public apology and compensate for the plaintiff's loss of RMB 1 million. The defendants submitted the case to Beijing Higher People's Court, and the Beijing Higher People's Court rejected appeal.
Through the investigation, the court made clear that at the time Beijing Genyun Electron Develop Center was founded, defendant Yangxiaobin was a member of the Center working on the spark title generator related to the software concerned. The defendant was then appointed the deputy manager as well as an engineer who is also working on sales. According to the law of software, the software copyright of Yang's work belongs to the Center, here, the plaintiff.
During the employment period under Beijing Genyun Electron Develop Center, Yang established Beijing spark electron science and technology development corporation on Aug 10,1999. After 15 days of its foundation, Yang advertised that spark title generator was invented after 10 years research, and then began to sell spark title generators. Yang as the designer and sales of Beijing Genyun Electron Develop Center brought the software belonging to the Center to his own corporation copying for sales. Yang and Beijing Spark Electron Technology Development Corporation is against the principle of "In good faith" and infringed the plaintiff's software copyright. Meanwhile, it also forms unfair competition to Beijing Genyun Electron Develop Center.
相关法律服务
杨春宝一级律师简介
杨春宝一级律师,大成上海高级合伙人、资本市场部主任、国资基金研究中心主任,大成中国区私募基金专业带头人、科技与文化法律研究中心联合牵头人。执业30余年,长期从事私募基金、投融资、并购重组法律服务,尤其对对赌研究颇深且具有非常丰富的实战经验,并专注于金融机构股权投资业务。2004年起多次入选The Legal 500"私募基金"和"公司与商业"等境内外各类律师榜单,代理的中国法院首例适用外国法律审理外国公司的董事损害小股东权益纠纷案入选上海高院发布的《上海法院域外法查明典型案例》和威科先行"要案头条"。入选上海涉外法律人才库、上海市司法局鼎新法治人才库、上海国有企业改制法律顾问团,具有上市公司独立董事任职资格,系多家知名高校的兼职教授或兼职研究生导师及上海市商务委跨国经营人才培训班讲师。出版《私募股权投资基金风险防控操作实务》等16本投融资法律专著。了解更多常见法律问题
外观设计专利确权案件中如何判断可比性?
外观设计专利确权案件中,判断两项设计是否具有可比性,核心在于产品种类、用途及功能是否相同或相近,以及是否属于同一消费群体和销售渠道。若产品在用途、功能上存在实质差异,即使部分技术功能重叠,也不能简单认定二者具有可比性。法院在审理此类案件时,会重点审查专利文件是否揭示了相关技术特征,以及当事人是否对对比关系予以认可。行政机关在作出无效宣告时,必须基于充分证据和正确对比基础,否则其决定可能因缺乏证据而被撤销。
在步步高诉专利复审委员会案中,步步高拥有VCD播放机外观设计专利,索尼公司以该专利与其PC游戏机外观设计相似为由请求宣告无效。专利复审委员会采纳索尼意见,宣告步步高专利无效。法院经审理认为,VCD播放机与PC游戏机在用途和功能上存在差异,虽然二者均可播放VCD光盘,但PC游戏机的专利文件并未揭示其具有播放VCD的技术功能,因此二者不具有可比性。步步高的反驳也不意味着其认可这种对比。法院最终以缺乏证据为由撤销了专利复审委员会的无效决定。
实务中,企业在应对外观设计专利无效宣告时,应着重论证对比产品在用途、功能、消费对象等方面的差异,并审查对比文件是否充分公开了相关技术特征。行政机关在作出无效决定时,必须确保对比基础正确、证据充分,否则将面临被法院撤销的风险。同时,专利权人应积极举证证明其设计与对比设计存在显著区别,以维护自身合法权益。
外国软件著作权在中国如何获得保护?
外国软件著作权在中国获得保护的法律基础主要源于国际公约和国内著作权法律体系。根据伯尔尼公约等国际版权公约,成员国国民的著作权在其他成员国应受到同等保护,无需履行登记或销售等手续。在中国,外国著作权人只要其所属国与中国同为相关国际公约成员国,其软件著作权即自动受到中国法律保护。软件是否在中国境内销售、是否办理登记,不影响其著作权的存在和保护。未经许可安装、使用他人软件,即构成对著作权的侵害,行为人应承担停止侵害、赔礼道歉、赔偿损失等民事责任。
在Discreet Logic公司诉某文化传播公司案中,原告是加拿大公司,系FLAME软件的著作权人。被告未经许可安装了一套FLAME软件用于产品制作和开发设计。原告起诉要求停止侵权、赔礼道歉并赔偿约100万元。被告辩称该软件未在国家知识产权局登记,故不能依法销售。法院认为,中国和加拿大均为伯尔尼公约成员国,原告的著作权受中国法律保护;即使软件未在中国销售,也不意味着其著作权可以被无偿使用。被告的行为已构成侵权,法院判令其停止侵权、公开赔礼道歉并赔偿50万元。
实务中,外国软件著作权人应保留好软件权属证明、开发时间、首次发表等证据,以便在维权时证明其权利主体资格。使用方则应通过合法渠道获取软件授权,避免未经许可安装使用。企业应建立软件资产管理制度,定期审查内部软件使用情况,防范侵权风险。若发生纠纷,权利人可依据国际公约和国内法律主张权利,要求侵权人承担相应法律责任。
商标侵权案件中如何认定类似商品或服务?
商标侵权案件中,认定类似商品或服务主要依据商品或服务的功能、用途、生产部门、销售渠道、消费对象等因素,或者相关公众一般认为其存在特定联系、容易造成混淆的标准。类似商品或服务的判断,应以相关公众的一般注意力为准,综合考虑商标的显著性和知名度。若在相同或类似商品或服务上使用与他人注册商标相同或近似的标识,容易导致相关公众混淆误认的,即构成商标侵权。此外,擅自使用他人具有一定影响的宣传用语,也可能构成不正当竞争,即使该用语未注册为商标,仍受法律保护。
在皇城老妈诉皇蓉老妈商标侵权案中,原告成立于1997年,注册了皇城老妈、老妈红等商标,并在宣传材料中使用《四川特色风味》等宣传语。被告成立于2001年,在广告灯箱上使用与皇城老妈近似的皇蓉老妈商标,并同样使用《四川特色风味》宣传语。法院认为,被告未经许可使用原告宣传语,侵害了原告的合法权益;在相同服务领域突出使用近似商标,会导致消费者混淆误认,构成商标侵权。法院判令被告停止侵权、公开赔礼道歉并赔偿11万元。
实务中,企业在选择和使用商标时,应进行充分的商标检索,避免与他人在先商标构成近似。在宣传推广中,应避免擅自使用他人具有显著性的宣传用语,以免构成不正当竞争。权利人发现侵权行为后,应及时固定证据,包括侵权商标使用情况、宣传材料、销售数据等,以便在诉讼中证明侵权事实和损失。企业还应加强商标监测,及时发现并制止侵权行为,维护自身品牌权益。
以上内容仅供参考,不构成法律意见。如需专业法律服务,请联系杨春宝一级律师:chambers.yang@dentons.cn




