Saturday, 20 August 2016

What is the Accuracy of the Ruling in Beiersdorf East Africa Limited v Emirchem Products(2002) in Light of the Ruling in Lords Healthcare v Salama Pharmaceuticals (2007) ? Kenyan Intellectual Property Law

A proprietor of a trademark has the exclusive use of the mark and any person who wishes to use it has to do so with a license from the protection’
-         Per Mbaluto, J. In Beiersdorf Ag v Emirchem Products Ltd. 2002 KLR 1,7.

Discuss the accuracy of this statement in the light of the ruling in Lords Healthcare v Salama Pharmaceuticals, Civil Suit 334 of 2007 (Okwengu, LJ).

Facts
Beiersdorf East Africa Ag v Emirchem Products Ltd: In the seminal ruling by Judge Mbaluto that was delivered at the Nairobi High Court, the plaintiff had been manufacturing and selling products such as soaps, toilet paper, oils for the skin etc. under the registered trademark Nivea Crème worldwide for many years. One of the plaintiff’s products was Nivea petroleum jelly was sold in a rectangular jar. On the face of it was written Nivea and immediately below were the words pure petroleum jelly.

The defendant was manufacturing and selling a product that was called Nivelin pure petroleum jelly. The plaintiff’s grievance was that the defendant’s product was so similar to the plaintiffs registered trademark that it constituted infringement and that the defendant was also liable for passing off.  The plaintiff approached the honourable high court to seek for an interlocutory injunction and was granted.

Lords Healthcare v Salama Pharmaceuticals: In the jurisprudential ruling that was delivered by Judge Okwengu at the Nairobi Milimani High Court, the plaintiff was a distributor of medicine that bore the registered trademark ‘Budecort-200’ Budesonide Inhaler’. The defendant was also distributing medicine under the name ‘Budecort-200 inhaler’. The product is manufactured by a company in India called Cipla Ltd. The manufacturer had an agreement with the plaintiff that the plaintiff would be the sole distributor of the product in Kenya.  The defendant had also registered its interest with the manufacturer and was a parallel importer. The plaintiff represented by Senior Counsel Oraro unsuccessfully sought for an interlocutory injunction.

Differences between the two decisions that affect the question
The defense strategy- in the Nivea case the defendant alleged that the marks are not deceptively similar whereas in the Lord healthcare case the defense claimed that the products and the mark are the same as such no question as to deceptive similarity arose.
In the Lord Healthcare case there was an international registered trademark that belonged to the manufacturer and there was also a similar local registered trademark that belonged to the plaintiff. There was therefore conflict as to whether the local registration was valid. There was no conflict of international and national registration of the trademark in the Nivea case. The international registration was under the Paris Convention which Kenya is a signatory to.
In the Lord Healthcare case the manufacturer who supplied both the plaintiff and the defendant was the same whereas in the Nivea case the plaintiff was the manufacturer and distributor of its products through its subsidiary.
 In the Nivea case the plaintiff apart from claiming infringement also claimed passing of whereas in the Lord Healthcare case the plaintiff main weapon was only infringement.
In the Nivea case the plaintiff had acquired immense goodwill for distributing his products from 1971 to 2002 whereas this was not so in the Lord Healthcare case.
In the Nivea case there was the likelihood of bad faith by the defendant as he was the formerly employed production manager. He resigned without giving clear reasons and set up the defendant company.
In the Lord Healthcare case the certificate of registration did not provide that the certificate was for use in legal proceedings.
Section 7(1) of the Kenya Trademarks Act guides us that the proprietor of a trademark has the exclusive use to the use of the mark and anyone else who intends to use the mark must seek permission. Prof Lionel Bentley in his book Intellectual Property Rights[1]asserts that the presumption is that when a mark is registered it is deemed to have been registered duly. However this presumption is rebuttable. The facts are that in the Lord Healthcare case there was an international registration of the same mark under the Paris Convention under which Kenya is a signatory as such the Plaintiffs similar mark should not have been registered as there is a conflict between two registrations as there were to different people, the manufacturer and the plaintiff, as such the national registration was invalid.
The restatement of section 7(1) of the Trademarks Act by Judge Mbaluto was good law. However in light of the decision by Judge Okwengu we find that section 7(1) is inaccurately limited as it does not take into account particular extraneous circumstances. These circumstances include;
1.      The fact that international registration of the mark is not considered.
2.      The fact that a certificate for registration must indicate if it for use in legal proceedings.
3.      The fact that a parallel importer does not gain exclusive rights to use a mark in relation to parallel importers.
4.      The fact that can a parallel distributor register a mark that is similar to products that are sold by other distributor and thereby gain exclusive rights to the mark?
5.      The fact that a distributor can only register a mark that is for a distinct product to gain exclusive use and not in relation to a product that is lawfully supplied to other distributors by the manufacturer.
6.      The fact that a registered trademark owner who is a manufacturer must himself first grant an exclusive license to a distributor in order for the distributor to have exclusive rights to sue and therefore gain locus.section7(1) must consider the intricate detail of locus standi in light of the new circumstances that were evident in the Lord Healthcare case
7.      The fact that an exclusive right to distribution does not encompass the exclusive right to use a mark.
The above outlined circumstances must be deeply considered by a court of law in order to determine exclusive use of a mark. There cannot be an iota of doubt as to the exclusive use of a mark.  As such the ruling by Judge Mbaluto was to some extent inaccurate as it did not fathom these circumstances.
Bibliography
1.      The Kenya Trademarks Act
2.      Beiersdorf Ag v Emirchem Products Ltd. 2002 KLR 1,7
3.      Lords Healthcare v Salama Pharmaceuticals, Civil Suit 334 of 2007
4.      L. Bently, Intellectual Property Law, 4th edn, Oxford University Press




[1] L. Bently, Intellectual Property Law, 4th edn, Oxford University Press

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