Trademark Law In Music and Film Industry – A Critical Analysis With Special Focus On India and Us
A trademark means a mark which uniquely identifies the commercial origin of a product and service. Nowadays, trademarks have become money makers in the music and film business.
The two main sectors – music and film are the emerging big markets globally which gives huge profits to the entertainment industry. Protection of commercial rights and interest for a song and film title plays a vital role when an legal issue arise. The paradigm shift surrounding the intellectual property issues plays a significant role surrounding various controversies relating to trademark issues such as deceptively similar song / film title, unauthorised use of film titles falling within the ambit of infringement of trademarks and remedy of passing off. Thispaper explores the potential application of the Indian & US Trademark Lawin relation to music and film industry focussing on the contemporary legal issues.
This paper mainly analyses the following aspects of music and film under the Trademark Law;-
I. Protecting “Song Titles” in India.
II. Protection of Trade Dress in the context of US & India.
III. Protecting “Film Titles” in US Trademark Law.
IV. Protecting “Film Titles” in India with special reference to Initial Interest Confusion Doctrine – Position in US & India.
In particular, it suggests that the Trademark Act provisions are being invoked by song writers/musicians and film producers/directors to gain reputation and brand value to their music and films.
A trademark or service mark, is a sign that distinguishes the goods and services produced and provided by one company from those of another. In the world of music, a band’s name is its brand, and as such, can be protected as a service mark. Examples of bands with trademarks include The Grateful Dead, Aerosmith and REM. Bands can also register trademarks in relation to their albums, t-shirts or any other merchandize they produce. With a trademark a band acquires the exclusive right to use its name, entertainment services and gains greater control over its identity. Acquiring a trademark can help secure additional sources of revenue, through licensing and merchandizing deals. Titles of songs are not normally eligible for trademark protection but may be so in relation to associated merchandize or if part of a series of works.An Asian-American rock-band (the Slants) with an eyebrow-raising name has scored a big victory in the Court of Appeals for the Federal Circuit. The court ruled that their name — The Slants — is private speech and therefore protected by the First Amendment. The government, the court writes, has no business trying to regulate it by denying the band a trademark. At issue in the case was Section 2(a) of the Lanham Act, which allows the U.S. Patent and Trademark Office (PTO) to deny or cancel a trademark if it is "disparaging" of persons, institutions or national symbols. In a 10-2 decision, the court decided parts of that section were unconstitutional. Conferring a trademark, the court argues, does not make the band's name government speech.
The name or title creates a sense of identity for a film among audience. All over the world, the makers of a film takes utmost care and importance in choosing an unique exclusively associated distinct title or name for their film to get popular & blockbuster hit among the all classes of audience. This association brings the audience to watch the film in theatres with their families as well as associate it with producers. Under Indian Trademark Act, 1999 the title of a film can be registered and protected in Class 41 of the fourth schedule of Trademark Rule, 2001. The title of a cinematographic film is protected in Trademark Law under two conditions:-
1) Series of Film Title – This series of film title can get easy trademark protection and registration when compared to the single film title. Examples of Series of Film Title include Singam franchise i.e., Singam, Singam II and Singam III. (Releasing this Diwali 2016)
2) Single Film Title –This condition of single film title has to pass the second qualification in order to acquire trademark protection and registration.
• Secondary meaning of the Single Film Title –Single literary work’s title:
• To satisfy or fulfil this condition of trademark protection, a secondary meaning of the title must have been acquired. Secondary meaning means, “The association of the title of the film with certain source, production house etc. by the movie goer or audience.” Even before the movie gets officially released in theatres, the pre-release publicity, promotions of the title of the film is sufficient for trademark protection underthe proviso clause stated under clause (1) of Section 9 of the Trademark Act, 1999 which specifically gives Trademark registration to a well-known mark or a mark which acquired distinctive character as a result of the use made of it.
• The court may take into considerations certain factors which decide the secondary meaning of the title of the film as listed below:-
# Continued Use and its Duration;
# The amount of money spent on extent of advertisement & promotion;
# The number of people who bought or viewed the owner’s work its Sales figures on purchase of tickets;
# Plaintiff and Defendant’s closeness of the geographical and product markets.
The researcher has relied upon doctrinal research by referring to cases laws, e-resources, articles in the journal & newspaper, magazines, etc.
Protecting “Song Titles” In India Under Trademark Act, 1999
The song title as a registered trademark in India was unprecedented for many years. The first song to acquire trademark protection on a song title in India is “Why this Kolaveri Di?” a viral blockbuster hit song. This Tamil-English mix song became an international youtube, facebook and twitter hit as it gained 4.10 million views in just 4 days of its official release. Sony music Entertainment India one of the biggest revenue generating music company in India recorded this song and filed for registration of a trademark (Application No. 2246257, Dec. 8, 2011)“Why this Kolaveri Di?”(the first line of the song). An application for trademark was sought under Class 9 and Class 41 logo was word mark respectively for protection of song lyrics. This allowed the launch of various products by Sony such as compact disks, cassettes and SD Cards including film and non-film entertainment content and discovery of talented programmes branded “Why this Kolaveri Di” and also prevented or restricted others from using it. This "Kolaveri di" song, written and sung by Actor Dhanush for the Tamil film '3', also shows how viral marketing can change the world within days of its digital release by Sony Music in the second week of November. When the original song has released, a never-before 20 million hits on YouTube, tens of different versions of the song in
several languages are coming up every day across the globe. The film“Jai Ho” by Salman Khan was release in Jan 2014 and it gave rise to legal issue for its film’s title. The blockbuster internationally recognised famous and popular song “Jai Ho” composed by A.R. Rahman from the movie Slumdog Millionaire (directed by Danny Boyle) made A.R. Rahman to trademark the title “Jai Ho” for which he won an Oscar and Grammy award for the best song composition. The issue raised in this case in respect of trademarking a song title is:-For registration of a song title, who is entitled? Is it whether the owner of the copyright in the song or the first person to file for registration of the title? The answer is the first person to file for registration of the title of the song is entitled to trademark registration and protection under the Indian trademark act. Although a trademark registration has never issued in India for a song title, registrations have issued for similar items, such as advertisement punch lines, quotations and television commercial jingles. For example, Nike International Ltd. has obtained an Indian registration for their well-known phrases JUST DO IT. Similarly, the owner of a trademark registration for the slogan “Writes Smoother, Darker. Lasts Longer” was able to stop the infringing use of its slogan by a competitor - Hindustan Pencils Pvt. Ltd. V. Suneja Copy Products. Indian trademark law does not allow registration of a trademark to continue if the mark remains unused for five years. Thus, if the applicant has no
intention of using the song/title mark for particular goods and services, but files an application to stop others from obtaining a registration, this could be viewed as unfair under the Trade Marks Act, 1999.If the party does intend to use a movie title as a mark in connection with merchandise, the title may be registered to protect the brand identity of the merchandise if the title is distinctive or has acquired secondary meaning in the course of its used as part of a particular work. Example - Kolaveri Di. It achieved extensive popularity in India in a very short period of time. According to Wikipedia, within a week of the official release of the video of this song, it received more than 3.5 million views on YouTube, more than 1 million shares on Facebook and extensive exposure on Twitter; became the top downloaded song on mobile devices within the first 18 days of release; and was the first Tamil film song to premiere on MTV India. This extensive exposure suggests that even within a very short period of time, the title of a song achieve secondary meaning.
Protecting “Song Titles” In Us
In US, unless otherwise you demonstrate that a particular song of a band is super hit, trademark cannot be obtained. Example, “Stand by your man” can be trademarked as it has been performed publicly two million times. “Better Class of Losers” a country song cannot be trademarked as it is performed only 47,000 times this ruling was held by the court in Tree Publishing Co. V. Warner Bros. Records ,. In EMI Catalogue Partnership V. Hill Holiday, Connors , the court conducted a poll in which it was accorded that “Sing, Sing, Sing” by Benny Goodman is the 100 most important musical works of the 20th century which acquired trademark protection for a song title. A trademark right in a song always depends upon the level of popularity it has acquired.
Scope of Protecting Trade Dress In Indian Context
Everybody is familiar with standard trademark forms – names, words, slogans, phrases and logos. These are the major factors which help in separation of one’s goods and service from another. However trademark takes a form of different shape and its less familiar because copyrights have gained much more significance and priority than trademarks in the music field. The concept of “trade dress” first originated in the US. This law can be traced back to doctrine prohibiting competition in an unfair manner under the statute of common law. Nowadays the name “trade dress” gains familiarity of reputation in the protection of trademarks. The federal law in US protects certain forms of “trade dress” meaning the product or packaging of its visual appearance. This unique feature of trade dress protection is designed in such a way as to eliminate the confusion in the minds of the audience. Trade dress is distinctive, non-functional, and distinguishes the products or services of trader’s and manufacturers from those of others. In Gibson Guitar Corp V. Paul Reed Smith Guitars , the court emphasised the importance of the concept of “trade dress” and “initial interest confusion” doctrine. Plaintiff Gibson stated that the defendant Paul Reed Smith had copied the exact same trade dress in the shape of Gibson guitar model where an normal consumer who fails to take a closer look on the Gibson guitar believed it to be Paul Reed Smith’s guitar has many chances for likelihood of confusion occurring in his minds and believes it to be true. The panel dismissed this theory by stating that Guitar shapes included many standards, elements, and so many of these conditions looks the same when viewed from far. There are lots of stores while display by them and consumer viewing will be difficult to fit into the ambit of “initial interest confusion” which is unworkable and complicated in court’s view
In the most controversial landmark case A.V.E.L.A Inc., V. The Estate of Marilyn Monroe, LLC, et al., “Publicity or Celebrity rights” concept has been elaborated and emphasized with utmost importance. AVELA is a company where nostalgia merchandise are specialised and produced. AVELA made images of Monroe by violating trademarks. For long time it was said that Monroe Estate, Monroe did not reside in California and for evasion of tax payment suddenly the statement was reversed and claimed that California was Monroe’s home. By this rule, the court held publicity rights is not applicable to Monroe.
Protecting Movie Title In Us and India’s Trademark Law
When one person copies the other person’s well-known product or trade dress, then it is necessary to protect these features so as to claim the defence of infringement by plaintiff or defendant. This proves that protection of trade dress is an important and crucial factor. The requirements under TRIPS and WIPO have paved way for Indian Trademarks Act, 1999 for remarkable expansion of including trade dress into its ambit. “Inherent Distinctiveness” is the key requirement in a trade dress to identify a particular product. Trade dress ‘per se’ cannot be registered under the act but colour combinations, shape, packaging of a particular product can be registered. The affected party has the remedy of passing off in India. Brand Usha Uthup -At a time when no performer in India, hired image managers or costume designers her brand image traditional silk sari, the flowers or the gajra her hair, bangles, bindi, and shoes, was the clevermarketing strategy used by her in the industry for reputation
The Application Of Initial Interest Confusion Doctrine In Trademarking A Movie Tile
The film title to acquire trademark protection must be first registered with USPTO. It refuses to grand registration of the proposed trademark if it relates to a surname, geographical description describing the origin of goods & services, disparagement, offensive in nature, a term which is foreign & that translates to a generic or descriptive of an individual’s name or likeness. The title of portion any work which is creative and single can be registered provided the applicant applying should show that title’s portion satisfies the following conditions:-
1) Apart from the entire or complete title, a separate commercial impression is created.
2) Series of work are used.
3) That series is promoted and recognised as a trademark.
In Paramount Pictures Corporation V. Pete Gilchrist the US court has given standard and uniform protection in trademark to single works of literary title establishing secondary meaning even when the contents of the work is not merely descriptive of the title. The respondent in this case took an unfair advantage and intention of using the domain name of the complainant’s rights in trademark. The court found that trademark of complainant is confusing and similar where it does not amount to fair or non-commercial use of the domain names. Therefore, the disputed domain name was restrained by the respondents for its use.
Film Titles And Their Protection - Registration with Industry Associations in India -Any cinematographic work is recognized by its "Title". Ownership and validity of titles can be registered with the Trademark Registry. Registration imparts exclusive right to the person who registers to use the title and restrain unauthorized use or adoption or infringement of the same. The Indian film and entertainment industry is one of the largest producers of world class films. It offers a big market in terms of consumers and has a significant growth potential with an expected growth rate of 20% per year. The grant of "Industry" status to the Indian film industry by the Government of India in 2001 resulted in its rapid evolution with the
foray of many foreign players and investors including 20th Century Fox, Viacom Motion Pictures, Warner Brothers etc. This paradigm shift is surrounded by IP issues mainly related to controversies over using deceptively similar titles or other ways of unauthorized adoption of titles of films, infringement of copyright and trademarks, passing off have also cropped up simultaneously.
Registration with Industry Associations-Indian Motion Picture Producers' Association (IMPPA), Association of Motion Pictures and Television Program Producers (AMPTPP) and Film and Television Producers' Guild of India, Film Writers' Association and Western India Film Producers Association (WIFPA) are the Industry associations that are consistently working with the objective of promoting and encouraging the production of feature films and protecting the commercial interest of films produced in India. Producers and writers (who are members) can also get the titles and scripts registered with these organizations. The film industry usually operates through these associations. Before registering the title, the association usually verifies with other associations as to whether the same or deceptively similar title has been registered with another association. However such registration only establishes priority in the adoption of title of film and authorship of the script and has no effect on any legal proceedings in the court.
Trademark Applications by leading Media and Production Houses in India -Leading production houses in India apply for registration of movie titles and labels in Class 41 that encompass a number of services including "entertainment". Phir Hera Pheri (1084237), MunnaBhai (1780467, 1780364) and Dhoom (2193798, 2095311 and 1319835) are examples of movie series where the producers have applied for registration of movie titles and labels in Class 41. On the other hand, as movies are also viewed on storage devices like DVDs, many applications are also filed in Class 9 that provides for, among other goods, "apparatus for recording, transmission or reproduction of sound or images...” The graph below depicts the number of applications filed for registration in Class 41 and Class 9 by some of the media houses in India. Bikramjeet Singh V. Anil Kapoor (CS(OS) 276/2008) - Anil Kapoor, an Indian actor and producer, had registered the title "shortkut" for his production -starring Akshaye Khanna, Arshad Warsi and Amrita Rao- with IMPPA. Later on, producer Bikramheet Singh Bhullar raised objection with the IMPPA, submitting that the same title has been registered by him prior to Anil Kapoor's registration. In this Title tussle, Anil Kapoor had to finally withdraw and change the title to "Shortkut- The Con Is On". Thoda Magic V. Thoda Life (CS(OS) 266/2008 Delhi HC Order dated February 6, 2008) - The Yash Raj Films production "ThodaPyaar, Thoda Magic" came under controversy over the title when opposed by actor-producer SaahilChadha on the grounds that the title of his film "Thoda Life, Thoda Magic" had already been registered with the Indian Motion Picture Producers Association (IMPPA). Kunal Kohli, Director of "Thoda Pyaar, Thoda Magic" in the counter argument said that the title of his movie was registered with the Film and Television Producers` Guild of India. Sahil later lodged a complaint with IMPAA. Later, both the movies were released without any change in their title. .
The Application of Initial Interest Confusion Doctrine In Trademarking A Movie Tile.
Sholay Media and Entertainment Pvt Ltd. V. Parag M. Sanghavi, Ram Gopal Verma's film "Ram Gopal Verma Ke Sholay" was restrained by an ex parte injunction in Delhi high court from release due to trademark infringements in relation to the cult film Sholay. The issue in this case was whether for a film title, trademark protection could be granted. In Biswaroop Roy ChoudharyV. Karan Johar, The plaintiff acquired an interim injunction for using the film’s title and registered it with Registrar of Trade marks to restrain the defendant from using the tile "KabhiAlvidaNaaKehna" for their movie. But the court held that even though the defendant did not register the title he was the actual user of the trademark as he has completed the film production and ready for release of the film. The court further stated that ‘the actual use of the trademark was always a relevant factor which would deter the court from granting injunction as relief. Hence there was denial to the plaintiff about the interim relief and held that Kabhi Alvida Naa Kehna was a common phrase, it cannot be used exclusively and the plaintiff approached the court in a delayed manner. These are the factors taken into account by the court for its denial of relief to the plaintiff.
In Nokia Corporation V. Movie Express, An interesting issue was raised before the Delhi high court. “Mr.Nookayya” (previously named as Mr. Nokia and Mr. No Keyia) is a 2012 Indian Telugu- action filmwritten and directed by Anil Kanneganti, produced by D. S. Rao under Shri Shailendra Cinemas. On March 8, 2012 this film released worldwide and after its release it ran into legal trouble where by one of the most leading telecommunication company Nokia Inc; sued the film makers of Mr.Nookayya for infringement of its registered trademark whereby they asked for interim injunction and ex parte order against the defendants. They stated that “Mr.Nokia” was deceptively and phonetically similar to their registered trademark of the company name “Nokia”. After nine days the film was named Mr.Nookayya Reloaded which was re-edited & re-released in theatres worldwide.
In Warner Bros Entertainment Inc V. Harinder Kohli, It was contended by Warner Bros that its trademark rights in Harry Potter series are infringed by a hindi movie “HarriPuttar”- A Comedy of Terrors. The Delhi High Court ruled that, analysing the two titles even though there is no much difference between the structural or phonetic similarity both an illiterate (who is likely to watch Hari Putter movie) as well as an educated movie goer (who is likely to watch a Harry Potter movie) has more chances of getting confused about the title of the movies with each other. Warner Bros lost the case and JusticeRevaKhetrapal stated that it is always difficult and not easy to draw a link or distinction for an illiterate between a Punjabi comedy movie and the English novel. The reason behind this is educated readers are treated class of consumers and illiterate movie lovers/audience are left out by a few film makers who are unaware or no knowledge on the subject matter. That apart, it fails to account for the fact that an average moviegoer in normal circumstances would not confuse or associate any movie merely because the title resembles a well-known mark. The thematic indication of the
film gives the best similarity. While choosing a title for a film, it must be chosen with utmost care, caution, and deliberate choice of intention which should be connected with the minds, taste and interest of the audience. As far as the Indian trademark law is concerned, the similarity between the title and the registered mark among the audience/film goers does not create any likelihood of confusion in the minds of the audience but it is only the mark which bears the goodwill is used to generate initial consumer interestamong audience.
‘Hamara Bajaj’ Case, In Oct 13, 2013 John Abraham’s film production house J.A. Entertainment Pvt Ltd. filed a trademark infringement case for its upcoming movie titled ‘Hamara Bajaj’. This movie title is derived from the story of the film which is centred on the life of ‘Sanjay Bajaj’. Bajaj Auto Ltd. used the same two words consistently as a tag line and advertised ‘Bajaj Chetak’, popular Bajaj scooters (now no more in production).
On Sep 21st 2013, the Bombay high court restrained the defendants from using the mark Bajaj and Hamara Bajaj anywhere in the contents of the proposed film or elsewhere in relation to the film, granted a permanent injunction against J.A. Entertainment Pvt Limited from using ‘Hamara Bajaj’ as a movie title. The title ‘Hamara Bajaj’, is used in the descriptive sense (movie is described) and not as a ‘trademark’. The goal of trademark law is to prevent confusion, and not to confuse the consumer about the two same titles. Kanungo Media (P) Ltd V. RGV Film Factory, This case is important in establishing the position of film’s single title can be protected under trademark act and it also made an appreciable effort in filling the gap of the judiciary. In this case court laid down certain guidelines as to classified them into two categories as series of film title where the protection of trademark is standard
and copyrighted works as single where it must be proved that wide reputation of such title is prevalent among the public at large and secondary meaning ofthe industry is acquired. The burden of proof lies on the plaintiff to establish that the title of the film has acquired secondary meaning and the court concluded by further stating that the trademark law with respect to protecting the title of a movie in India is similar to the US law of trademark. “Nishabd” was the film produced by Kanungo Media Pvt. Ltd and this film has also won many awards and the movie is in Bengali language. Because of insufficient amount of money it could not be commercially released and hence was not popular among the public. Ram GopalVerma used the same name “Nishabd” and produced a film in Hindi language and he filed an suit for infringement in the Delhi high court wherein it held that, since the film was not commercially released by Kanungo Media Pvt. Ltd, the public were unaware and not popular about the film. “Nishabd” word does not have any secondary meaning. The court further held that, ‘Only when a film’s title has a secondary meaning, trademark can be protected and registered and the court favoured RGV Film Factory.
Doctrine of ‘Initial Interest Confusion’ and its Legality - Thisdoctrine has its origin in the U.S and it is considered to be a handy tool for ascertaining the infringement. It is the liability of plaintiff to prove that defendant’s conduct at the time of interest in a product or service confused the consumer even if that initial interest is corrected at the time of purchase. For requiring the similarity of title to result in likelihood of confusion, that confusion about the similarity should relate to the origin of the product or service - Section 29(1) of the Trade Marks Act, 1999.When a film likely confuses the audience where the film is conceived as creative work of the registered mark, no establishment of confusion at its source at the purchase time is essential under the doctrine of initial interest confusion. That is to say, a mere commission of infringement of a known mark is sufficient under this doctrine
Dilution of a Trade Name - A known mark used by the producer of a film with a clear intention to gain commercial gain and reputation to his business. Under Sections 29(7) and (8) prohibits unfair trade representations by a trademark holder. A title of the movie is qualified as an advertisement as well as trade representation. If the proprietors establish that the title has contributed to their commercial gain or has affected their reputation, the movie makers could be liable.
In my opinion a new dimension is liberalised by analysing the aforesaid judgments which gives a new interpretation of the Trademarks Act, 1999. The judiciary should equip itself more to deal with such issues pertaining the entertainment industry and trademark protection in India and also should provide appropriate solution to the issues. Similarly while naming a film the producer’ slacks originality sample applies in case of song title and lyrics too. This should be avoided and a right balance should be accorded for musicians and film makers who wanted to protect their work as trademark because any new concept or idea for a song or a film is directly associated in the minds of the audience & trademarks plays a key role in brand building businesson developing instruments, sound systems by bringing music closer.
# Anchita Sharma, Trademarks: Case Study – TrademarkFor Film Titles, (last updated June 27, 2014).
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# Tree Publishing Co. V. Warner Bros. Records 785 F. Supp. 1272 (M.D Tenn. 1991).
# EMI Catalogue Partnership V. Hill Holiday, Connors, U.S. App. LEXIS 30761 (2nd Cir. 2000)
# Gibson Guitar Corp V. Paul Reed Smith GuitarsLP, 423 F.3d 539 (6th Cir. 2005).
# A.V.E.L.A Inc., V. The Estate of Marilyn Monroe, LLC, et al.,12 Civ. 4828 (KPF) (Date filed Sep 18, 2015)
# Paramount Pictures Corporation V. Pete Gilchrist(Administrative Panel Decision Case No. D2007-0128)
# Sholay Media and Entertainment Pvt Ltd. V. Parag M. Sanghavi,CS (OS). 1892/2006.
# Biswaroop Roy ChoudharyV. Karan Johar, 2006(33)PTC381(Del).
# Nokia Corporation V. Movie Express, (CS(OS) 286/2012 Delhi High Court Order dated February 6, 2012.
# Warner Bros Entertainment Inc V. HarinderKohli, CV 12-9547 PSG (CWx) decided on 12 December, 2012.
# Aparajita Lath, SpicyIPTidbit: J. A. Production permanently restrained from using ‘Hamara Bajaj’ by a consent order, http://spicyip.com/2013/10/spicyip-tidbit-j-a-production-permanently-restrained-from-using-hamara-bajaj.html (last updated October 13, 2013).
# Kanungo Media (P) Ltd V. RGV Film Factory, 2007(34) PTC 591(Del).
# Bikramjeet Singh V. Anil Kapoor (CS(OS) 276/2008).
# Thoda Magic V. Thoda Life (CS(OS) 266/2008 Delhi HC Order dated February 6, 2008).
# Hindustan Pencils Pvt. Ltd. V. Suneja Copy Products (2009) 39 PTC 648 (Del).
# http://www.sevenelementz.com/2014/01/11/kolaveri-fight/ (last updated January 11, 2014)
# It's great to be me: UshaUthuphttp://wonderwoman.intoday.in/story/its-great-to-be-me-usha-uthup/1/101089.html(last updated January 27, 2015)
# Article by Lucy Rana and Pooja Thakur, India: Film Titles And TheirProtection, S.S. Rana & Co. Advocateshttp://www.mondaq.com/india/x/455412/Trademark/Film Titles And Their Protection (last updated 5 January 2016).
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