Friday, December 14, 2012

Can Trade dress protection thrive in Uganda’s copycat economy?


John Doe decides to open up a fast-food restaurant in a town suburb. He puts a lot of effort into the design and lay-out of the restaurant from color settings on the walls and tiles to arrangement of dining furniture and reception. The general ambiance is designed to perfection and, indeed, many agree that it has a huge role to play in the attraction of large patronage. John Doe rakes in huge profits as a result, until a few more restaurants start opening up down the street and in other parts of the locality. The newer restaurants are of inferior quality. Problem is, however – they have all copied the layout of his own business. Has his branding right been ripped off?  The more accurate issue is whether trade dress can suffice as a claim in Ugandan Trademark law where the copycat syndrome thrives deeply in the commercial industry.

John Doe’s story is a common experience amongst many start-up businesses in Uganda. They all fall victim to copycat businesses due to the limited level of innovation in the country. Most people are inclined to copy something else that is already out there and thriving rather than start something of their own. It becomes a case of unfair competition but does the victim legally have a case against the culprit(s)?

What is referred to as a “trademark” in the legal sense, is looked at as “branding” in the business sense. So, in effect, it is not just about the sign or mark on the product or service, but how well you can establish an identity for yourself so as to be associated as the source of a product or service. It is therefore unfortunate that the present (and fairly new) Trademark legislation in Uganda (Act No. 17 of 2010) does not have an adequate answer for situations where the concept and feel of one’s business is copied by another. Section 4, for instance, only provides for the protection of a sign or combination of signs. On the other hand, however, it is this concept and feel that applies to trade dressing as part of trade mark protection.

This problem is also heighted further by the fact that in jurisdictions in which trade dress protection is recognized, Courts have battled with deciding upon such verdicts. In the United States, for instance, there is no clear-cut position on trade dress protection. It has been argued in some Federal Court cases that a trade dress item which focuses on the image of a business, i.e the entire look and feel of a business or a service (product design and packaging) is purely functional in the sense that it is an essential part of the business that cannot be done away with in order for the business to function – as such, trade dress protection cannot be accorded to a particular individual. Protection of the trade dress would therefore have to go beyond the functional aspects of the product or service. On the contrary, other U.S. Courts believe in protecting the investments that have been put into creating the Trade dress and preventing unfair competition. As such, some of the judgments from these Courts have been in favor of Trade dress protection. Nonetheless, in deciding over trade dress protection, U.S Courts have also faced the challenge of making out a difference between product design and product packaging. In other words, if a restaurant owner seeks trade dress protection, is it so as to protect his attraction of customers who like his restaurant for the layout of the restaurant or those who like it because of the quality of the food?

Courts in the United Kingdom, on the other hand, have not directly addressed Trade dress but have instead passed judgment on matters affecting “passing off” of products or services under trade mark infringement, which are injurious to the reputation of the claimant. This is closer to the provision under section 35 of the Ugandan Trademark Act which creates a claim against passing off of goods or services. This provision, however, does not address the copycat syndrome experienced in the Ugandan economy.

One would argue therefore that our local Ugandan investors that thrive on copying existing businesses cannot and should not be labeled as infringing on any trademark laws – or trade dress for that matter, probably on the premise that they are not using similar signs for their products or services. However, it should also be considered that some of the customers that visit the copycat business may be inclined to believe that it is a branch or extension of the original business. The likelihood of confusion is thus established in this way and negatively affects the original business in terms of reputation and unfair competition. Now, is n’t this what Trademark law is meant to address?

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