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BROSS & PARTNERS

How to Tackle Trademark Backlog in Vietnam

Attorney Le Quang Vinh

Presented on the afternoon of October 23, 2023 at VNIPO

Le Quang Vinh | LinkedIn

vinh@bross.vn

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Over 60,000 trademark apps. annually filed, eight-fold greater than patent apps. and nearly twentyfold more than design apps.

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Trademark examination completion is now sluggish (2-3 times longer than 9-month statutory time limit)

Annual growth more than 10%

Huge Backlog of Unexamined Trademarks

  • Disappointing the society and enterprises
  • Unlikely to make the 2019 national IP strategy become true
  • Our proposal consists of two phases

> 60.000

> 8.000

> 3.000

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PHASE I

01

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Establishing general rules on conflict with prior rights

Exceptions to first-to-file rule and priority rule:

Articles 74.2i, 74.2g, 74.2k, 87.7

Appropriateness of relevant evidence

Clearly specifying the criteria for enjoying the exceptions

Current priority rule at Article 91 IP Law is interpreted too narrowly

Foreign laws and practice: famous trademark, widely-used-and-recognized trademark which are neither filed nor registered

generally considered to have priority right better than the filing date of the disputed mark

1. Completing Trademark Examination Guide

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Class 3

Class 43

Class 30

Class 6

2. Nice classification: Acceptable Identification of Goods/Services Updated and Public

Encourage the use of acceptable classification, ie. prioritizing examination of trademark apps. using acceptable goods/services.

  • TO REDUCE COMPLICATED TRADEMARK APPS.

Feasible because 60% total apps. are represented by IP agents those who can recommend their clients to use acceptable identification of goods/services

Regularly updating goods/services acceptable by VNIPO

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3. Quota and KPI for Examiner Should be Redetermined

Current norms are merely based on apps. receipt number, neither differing simple/difficult applications, nor single-class, nor multiple-class ones

Present norms should be redefined by ease/difficulty of applications to exactly assess examiner’s completion capacity and KPI as a basis for considering bonuses, salaries to create fairness and work motivation

Multi-class applications, or those containing both word and figurative elements are examined longer than those containing single-class or word mark only

Categorizing different applications

Quota for examination assigned

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4. Adequate investment in IT

Proposing to upgrade and use IT infrastructure to ensure efficiency and smoothness

Examination stopped in the past 5 months due to IT system changes caused:

* Frustrating applicants too much,

* Great pressure on the IP agents’ responsibility of explanation to their clients

* Continuing to increase new backlog to old backlog, causing more pressure on Trademark Examination Center

Proposing the Ministry of Finance to spend money for the VNIPO to implement the IP national strategy (not requiring spending money due to "specialized sector")

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5. Priority mechanism for accelerating some types of applications

Trademarks in dispute in market should be prioritised

Applications having unacceptable identification of goods/services; complicated trademarks (verbal & figurative elements combined)

Applications having long list of goods/services

Trademarks that has been in used

Trademark applications opposed

Consequence: Help reduce social frustration by satisfying their needs in time

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6. Internal Information System Significantly Improved

  • Ensure synchronous and effective coordination between Departments of VNIPO based on updated application status information
  • Minimize mistakes that result from lack of coordination and cross-exchange of information (especially between the Trademark Examination Center and Board of Appeals)

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7. Don't worry too much about the possibility of incorrect grant of protection

  • Wrong grant of title of protection is not a crime as Section 170 Penal Code 1999 was abolished.
  • VNIPO’s grant of protection is merely based on the minimum information source (not the maximum information source), so it cannot know or control whether a registered trademark conflicts with prior rights or not.
  • Registered trademarks may be challenged by validity cancellation or administrative lawsuit if a relevant party has substantiated evidence
  • Change in mentality would bring a positive significance in contributing to motivating other competent authorities (eg. courts) to participate in building a stronger IP system

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With respect to geographically misunderstanding, misdescriptive or deceptive marks, current pre-assumption mindset should be changed to post-assumption

IP5 countries do not automatically equate geographical names with geographical origins

Do not consider a sign automatically a false indication as to  as long as there is convincing evidence to the contrary

“Tên địa danh” (place name) should not be used since such term can be misundertood as the name of a place with reputation for a particular product. “Geographical name” should be adopted in replace

8. Mindset in Examining Location Names Changed

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9. Examination of Tradename and Business Name Should Change

The boundary between trade names and trademarks lies in the way the sign is used, specifically if it is used to identify one business with another, it is called a trade name; if it is used to distinguish the origin of this product from the same product of another business, it is called a trademark 

Even though the right over tradename is automatically established like copyright (but copyright only arises if both conditions are met: originality and material fixation) then it does not mean that such right automatically arises in the business name, but that right exists only when a subject claiming rights to a trade name can successfully prove that the business name satisfies the conditions for protection as a trade name

Neither advisable and nor necessary to equate

all business names (enterprise names) with tradenames by reason of:

VNIPO has no obligation to prove the existence of a trade name, but the burden of proof lies with the subject claiming rights to the trade name. Disputes related to trade names should be classified as disputes with prior rights, and it is best to let them be resolved by other procedures such as complaints, cancellation, or administrative or civil lawsuits

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PHASE II

02

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1. Trademark Examination Reformed

  • Proposal to continue amending the 2022 IP Law to change the examination process (current process is relatively outdated) because some steps therein not really necessary which can be cut off based on the practical experience of the US and China (where dealing with the persistent backlog)
  • Route 1: Cutting off formality examination and formality publication (Official Gazette A), integrating such formality examination with substantive examination, shortening 5-month opposition period to 3 months, changing the opposition mechanism (from opposition embedded in substantive examination stage to opposition after finishing the substantive examination) specifically after finding no absolute grounds or relative grounds, the VNIPO will announce the preliminary approval of the applied-for mark (this stage is equivalent to the notice of grant presently) for the third party to oppose within 3 months thereafter. Without opposition filed in 3-month period, the applied-for mark will proceed to the stage of grant of registration; or
  • Route 2: Like Route 1 but different in that according to Route 2, VNIPO only publishes preliminarily approved applied-for mark (having met protection criteria) for third parties to object, and if there is no objection, the applied-for mark will become registered without having to pay grant fee (VNIPO can include the grant fee in the application fee to compensate for not collecting grant fee).

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2. Similar Group Code Established

Class 30

3201

3209

3001

3003

3029

A system of similar group code helps automatically determine the similarity of goods/services

similar group code would enable examiner free up 50% of the examination time (he/she does not have to compare the identity or similarity of products bearing the trademarks, but only compares the likelihood of confusiong between the trademarks).

similar group code would decrease unnecessary controversies, disagreements, or inconsistencies between departments, especially reducing complaints.

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3. Revising the 2022 IP Law to Clearly Delineate Absolute and Relative Grounds

Article 73

Amending relevant Articles in the 2022 IP Law to operate new examination process, especially recasting absolute grounds and relative grounds (cần phân định rõ ràng 2 loại căn cứ này).

Article 74

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Thank you

Le Quang Vinh | LinkedIn

vinh@bross.vn