Trademark, Design and Copyright Update For Fashion Brands - K&L Gates
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Luxury & Fashion Webinar Series – Facing the Future
March 21, 2019
Trademark, Design and Copyright
Update For Fashion Brands
Susan Kayser, Friederike von Brühl, Serena Totino, Anaïs Ligot,
Simon Casinader, Savannah Hardingham
© Copyright 2019 by K&L Gates LLP. All rights reserved.
TODAY‘S PRESENTERS – A WARM WELCOME
Washington DC Berlin London
Susan Kayser, Partner Friederike von Brühl, Partner Serena Totino, Associate
Paris Melbourne
London
Anaïs Ligot, Associate VIA RECORDING:
Simon Casinader,
Sr. Associate Savannah Hardingham,
Partner
klgates.com 2
OVERVIEW OF TOPICS
– U.S. Issues and Cases
Proving Irreparable Harm Continues To Evolve
Blurring The Line In Using Celebrity Names Or Images
Parody Or Infringement - How Funny Does It Need To Be?
U.S. Supreme Court Weighs in on IP Issues
– EU Directive 2015/2436
– EU Issues and Cases
– Brexit
– Australia Issues and Cases
Copyright protection for clothing
Google Ads and trade mark infringement
klgates.com 3
OVERVIEW OF TOPICS
– U.S. Issues and Cases
Proving Irreparable Harm Continues To Evolve
Blurring The Line In Using Celebrity Names Or Images
Parody Or Infringement - How Funny Does It Need To Be?
U.S. Supreme Court Weighs in on IP Issues
– EU Directive 2015/2436
– EU Issues and Cases
– Brexit
– Australia Issues and Cases
Copyright protection for clothing
Google Ads and trade mark infringement
klgates.com 4
U.S. ISSUES AND CASES –
“PROVING” IRREPARABLE HARM
Irreparable Harm Needed for Injunctive Relief
‒ May 2006 – eBay v. MercExchange – U.S. Supreme Court rejects
“presumption” in patent cases
– 2014
Ninth Circuit – Herb Reed Enterp. v. Florida Entertainment Mgmt. –
plaintiffs in trademark actions must show irreparable harm (no
presumption)
Third Circuit – Groupe SEB USA Inc. v. Euro-Pro Operating LLC –
“permissable inference” of irreparable harm
Supreme Court did not accept cert in Herb Reed
– 2014 – 2018
Continued split requiring “proof” of irreparable harm, “inferences”, or
middle ground – some “proof”
klgates.com 5
U.S. ISSUES AND CASES –
PROVING IRREPARABLE HARM CONTINUES TO EVOLVE
adidas v. Skechers*
9th Circuit
adidas asserted trade dress for Stan Smith design:
– three perforated stripes on the body of the shoe,
– prominent heel tab, and
– "a particularly flat sole," among other elements
Adidas Am., Inc. v. Skechers USA, Inc., 890 F.3d 747 (9th Cir. 2018)
klgates.com 6
U.S. ISSUES AND CASES –
THE STAN SMITH v. THE SKECHERS ONIX
adidas* proved irreparable harm:
1. Consumer surveys
2. Extensive marketing efforts
3. Controlled supply of Stan Smiths available for purchase
Adidas Am., Inc. v. Skechers USA, Inc., 890 F.3d 747 (9th Cir. 2018)
klgates.com 7
U.S. ISSUES AND CASES –
THE STAN SMITH v. THE SKECHERS ONIX
adidas built a specific reputation around the Stan Smith with “intangible
benefits”
– Extensive and targeted advertising
– Unsolicited media
– Survey
– Controlling Supply
Adidas Am., Inc. v. Skechers USA, Inc., 890 F.3d 747 (9th Cir. 2018)
klgates.com 8
U.S. ISSUES AND CASES –
THREE STRIPE MARK v. SKECHERS CROSS COURT
adidas failed to show irreparable harm
Three-Strip Mark The Skechers Cross Court
Adidas Am., Inc. v. Skechers USA, Inc., 890 F.3d 747 (9th Cir. 2018)
klgates.com 9
U.S. ISSUES AND CASES –
THREE STRIPE MARK v. SKECHERS CROSS COURT
Evidence of Loss of Control over Business Reputation and Damage to Goodwill
= Irreparable Harm
Provided “Concrete Evidence” in the Record
Post-sale confusion and “value” brand arguments not sufficient
– Not sufficient evidence that Skechers had less favorable reputation
– No evidence of consumer perception
klgates.com 10U.S. ISSUES AND CASES –
THREE STRIPE MARK v. SKECHERS CROSS COURT
Judge Clifton’s Dissent:
Lesser quality imitator could harm value of prestige brand
Record evidence to support irreparable injury
– Employee testimony: adidas is “premium sports brand” and Skechers is
“value brand”
– Value of adidas’ mark
– Investment
– Quality control
klgates.com 11U.S. ISSUES AND CASES –
TAKEAWAYS ON PROVING IRREPARABLE HARM
– Venue matters
– “Prestige” v. “Lower Quality”
– Employees ≠ Consumer Perception
– Advertising
– Unsolicited media
– Controlling Supply
– Surveys
klgates.com 12U.S. ISSUES AND CASES –
BLURRING THE LINE IN USING CELEBRITY NAMES OR
IMAGES
Use of celebrity’s name might be legal even
when clearly chosen to capitalize off
famous singer’s name
– Feyoncé Inc. selling T-shirts and other
goods featuring “Feyoncé”
– References Beyoncé’s 2008 “Single
Ladies” track
Knowles-Carter et al. v. Maurice et al., 1:16-cv-02532 (S.D.N.Y.)
klgates.com 13U.S. ISSUES AND CASES –
BEYONCÉ v. FEYONCÉ
– Use of letter “F” in “FEYONCÉ” was a
play on words to sound like “fiancé”
– A pun the court found could dispel
consumer confusion
– SJ and a permanent injunction denied
– Case dismissed
– Number of FEYONCÉ items currently for
sale by third parties
Knowles-Carter et al. v. Maurice et al., 1:16-cv-02532 (S.D.N.Y.)
klgates.com 14U.S. ISSUES AND CASES –
PARODY OR INFRINGEMENT - HOW FUNNY DOES IT
NEED TO BE?
Louis Vuitton Malletier SA v. My Other Bag Inc., 1:14-cv-03419 (S.D.N.Y.)
klgates.com 15U.S. ISSUES AND CASES –
PARODY OR INFRINGEMENT - HOW FUNNY DOES IT
NEED TO BE?
klgates.com 16U.S. ISSUES AND CASES –
LOUIS VUITTON v. MY OTHER BAG
A parody must convey two simultaneous and contradictory messages:
– that it is original
– but also that it is not the original and is instead a parody
– MOB met this standard
Louis Vuitton Malletier SA v. My Other Bag Inc., 1:14-cv-03419 (S.D.N.Y.)
klgates.com 17U.S. ISSUES AND CASES –
LOUIS VUITTON v. MY OTHER BAG
– “My Other Bag is a…” = a designation of source
Makes clear that MOB’s tote bag is not a LV-branded bag but merely
a parody
– LOC = extremely low
– MOB's parodic use of LV's designs:
produces a “new expression [and] message”
constitutes transformative use
klgates.com 18U.S. ISSUES AND CASES –
TAKEAWAYS
– Parody part of initial confusion assessment
– Play on Words
– Merely co-opted the mark? Or repurposed it?
– Third Party Use
– Negative Press / “Bullying” Charges Against Big Brands
klgates.com 19U.S. ISSUES AND CASES –
U.S. SUPREME COURT RESOLVES CIRCUIT SPLIT ON
COPYRIGHT REGISTRATION REQUIREMENT
– Supreme Court unanimously held: copyright
owners must obtain a registration from the
U.S. Copyright Office prior to filing an
infringement action
– Impact: likely to be a flood of copyright
applications at the U.S. Copyright Office
low cost to file
average seven-month wait time to receive
registration
Fourth Estate Public Benefit Corp. v. Wall-Street.com, LLC, 586 U.S. __ (slip op., March 4, 2019).
klgates.com 20U.S. ISSUES AND CASES –
FOURTH ESTATE PUBLIC BENEFIT CORPORATION v.
WALL-STREET.COM
Brands in the luxury goods and fashion industries should routinely file
copyright applications
– Fashion companies regularly create seasonal designs used on handbags
or clothing (floral prints, animal designs, and other pictorial
features/arrangements)
– Packaging designs may be protectable through copyright
– Notorious infringers frequently create replicas of designs, and brands
need to be armed and ready with copyright registrations for immediate
action upon learning that the brand’s design has been copied
– Registration = prerequisite for statutory damages and attorneys’ fee
Fourth Estate Public Benefit Corp. v. Wall-Street.com, LLC, 586 U.S. __ (slip op., March 4, 2019).
klgates.com 21U.S. ISSUES AND CASES –
DEFINING RECOVERABLE COSTS IN COPYRIGHT
LITIGATION
The Supreme Court recently determined that “full costs” under § 505 of the
Copyright Act did not authorize the appellate court to award litigation expenses
beyond those specified by Congress in the general costs statute
– Not included: expert fees, consultant fees, and electronic discovery costs
– Included:
1. clerk and marshal fees
2. transcript fees
3. printing and witness fees and costs
4. exemplification and copying fees
5. docket fees
6. compensation of court-appointed experts and interpreters
Rimini Street, Inc. v. Oracle USA, Inc. 586 U.S. ___ (slip op., March 4, 2019).
klgates.com 22OVERVIEW OF TOPICS
– U.S. Issues and Cases
Proving Irreparable Harm Continues To Evolve
Blurring The Line In Using Celebrity Names Or Images
Parody Or Infringement - How Funny Does It Need To Be?
U.S. Supreme Court Weighs in on IP Issues
– EU Directive 2015/2436
– EU Issues and Cases
– Brexit
– Australia Issues and Cases
Copyright protection for clothing
Google Ads and trade mark infringement
klgates.com 23EU DIRECTIVE 2015/2436 –
HARMONIZATION OF EU TRADEMARK REGISTRATION
PRACTICE
EU Directive 2015/2436
Aims
Strengthening TM owners’ rights
Harmonization of EU TM systems
Timing
Implementation deadline: January 14, 2019
Almost half of the member states have not implemented yet!
klgates.com 24EU DIRECTIVE 2015/2436 –
HARMONIZATION OF EU TRADEMARK REGISTRATION
PRACTICE
German Trademark Modernization Act (14 January 2019)
New registration options
Before: only graphic display; now: any form of display!
Licenses
New technical framework
QR-Code on TM certificate
Use of key words for TM research
New TM types
Sounds, animations, holograms
Certification marks
klgates.com 25EU DIRECTIVE 2015/2436 –
HARMONIZATION OF EU TRADEMARK REGISTRATION
PRACTICE
Certification Mark
Guarantee for certain characteristics of the goods/services
Applicants provide a statute
Reliability
Relevance for fashion industry
Guarantee for standards of material, fabrication, quality
e.g. Fair Trade Rules and Environmental Protection
klgates.com 26OVERVIEW OF TOPICS
– U.S. Issues and Cases
Proving Irreparable Harm Continues To Evolve
Blurring The Line In Using Celebrity Names Or Images
Parody Or Infringement - How Funny Does It Need To Be?
U.S. Supreme Court Weighs in on IP Issues
– EU Directive 2015/2436
– EU Issues and Cases
– Brexit
– Australia Issues and Cases
Copyright protection for clothing
Google Ads and trade mark infringement
klgates.com 27EU ISSUES AND CASES –
CJEU – JUDGMENT C-163/16 LOUBOUTIN
Description of Trademark Registration EU
008845539:
“The trademark consists of the color red
(Pantone 18.1663TP) applied to the sole of a
shoe as shown (the outline of the shoe is
therefore not part of the trademark but serves
to show the positioning of the trademark).”
Notion of “shape”, Article 3(1)(e)(iii)
Directive 2008/95:
”A set of lines or contours that outline the
product concerned.”
klgates.com 28EU ISSUES AND CASES –
FERRAGAMO v. RIPANI & VAL VIBRATA
FERRAGAMO’S TRADEMARK RIPANI & VAL VIBRATA
Italian Supreme Court – 2018
–klgates.com –29EU ISSUES AND CASES –
COURT OF MILAN
Ferragamo filed a lawsuit agaist Ripani and Val
Vibrata claiming:
– Infringement of its iconic «omega» trade
marks
– Unfair competition
The Court of Milan decided in Ferragamo’s favour
klgates.com 30EU ISSUES AND CASES –
COURT OF APPEAL
2013 – The first instance decision was overturned:
– Similarity does NOT imply likelihood of confusion in the market
– Ripani & Val Vibrata’s signs held an instrumental function, while
the Ferragamo trade mark has an ornamental function
klgates.com 31EU ISSUES AND CASES –
THE ITALIAN SUPREME COURT
Marks with reputations should be protected:
‒ Independently from the likelihood of confusion
of the relevant public
‒ If the infringing mark takes unfair advantage of,
or is detrimental to, the distinctive character or
repute of the earlier mark
STAY TUNED…
Court of Appeal will have to decide the case
taking into account the reputation of the earlier
mark
klgates.com 32EU ISSUES AND CASES –
LANDOLL v. MECS SRL
LANDOLL’S TRADE MARK MECS SRL
Unauthorised reseller of NASHI
SELECTIVE DISTRIBUTION products on its website and on a
AGREEMENT third party online marketplace
PRINCIPLE OF
EXHAUSTION
Court of Milan – 2019
klgates.com 33EU ISSUES AND CASES –
PRINCIPLE OF EXAUSTION
A trade mark owner may not oppose the further commercialization of its
branded goods that are distributed in the EEA with its consent
unless there are LEGITIMATE REASONS:
– Conditions of the goods are changed or impaired
– Legitimate selective distribution agreement in place
klgates.com 34EU ISSUES AND CASES –
COURT OF MILAN
PRELIMINARY INJUCTION:
‒ Principle of exahustion does not apply
‒ Selective distribution agreement may be a
«legitimate reason»
– Infringement of Nashi Trade mark
– Withdrawal of Nashi’s products from the
market within 3 days + legal costs
– Publication of the preliminary injuction on
the the reseller’s homepage for 30 days
Will the Court of Milan uphold this decision?
Will this decision be persuasive for other EU Courts?
klgates.com 35EU ISSUES AND CASES –
WHAT IS A SELECTIVE DISTRIBUTION SYSTEM?
“A distribution system where the supplier undertakes to sell the contract goods
…, either directly or indirectly, only to resellers selected on the basis of
specified criteria
and
where these resellers undertake not to sell such goods …to unauthorized
resellers within the territory reserved by the supplier to operate that system…”
Article 1(e), EC Regulation No. 330/2010
(“Vertical Block Exemption Regulation”)
klgates.com 36EU ISSUES AND CASES –
HOWEVER…
Many luxury brands already operate a
“DE FACTO” selective distribution system
BUT unless structured in accordance with EU laws:
– May not be legally enforceable – so of little/no protective value to brand
– May include terms or practices which expose the company to significant
legal risk (see Guess case)
Cross-sale restrictions?
Territory restrictions?
Online sales restrictions?
Resale pricing pressures?
klgates.com 37EU ISSUES AND CASES –
LIONEL MESSI v. EUIPO & J.M.-E.V. E HIJOS SRL
Are these trademarks similar?
Trademark
Action Opposed by
registration filed by
Party Messi J.M.-E.V. e hijos SRL’s prior trademark
Word trademark Word trademark
Trademark “MASSI” No “MASSI” No
3436607 414086
9
9
Classes 25 25
28
28
Court of the EU – 26 April 2018 No T-554/14
klgates.com 38EU ISSUES AND CASES –
LIONEL MESSI v. EUIPO & J.M.-E.V. E HIJOS SRL
Are these trademarks similar?
– According to the Court of the EU:
Visually: Average degree of similarity
Phonetically: Strong degree of similarity
Conceptually: Different since Lionel Messi is famous for any average
consumer of sports goods
– Decision of the Court of the EU:
No likelihood of confusion
The relevant public will associate the term “Messi” with the name of
the football player, not with the trademark “Massi”
Court of the EU – 26 April 2018 No T-554/14
klgates.com 39EU ISSUES AND CASES –
CROCS v. EUIPO AND GIFI DIFFUSION
“Unluxury” shoes – Take 1
Design registration Declaration of
Action
filed by invalidity by
Party Crocs Gifi Diffusion
Design
Court of the EU – 14 March 2018 No T-651/16
klgates.com 40EU ISSUES AND CASES –
CROCS v. EUIPO AND GIFI DIFFUSION
“Unluxury” shoes – Take 1
– Considering the three disclosure events: The Crocs’ design had been
made available to the public prior to the 12-month period preceding the
date of priority claimed
– No demonstration by Crocs that three disclosure events could not:
reasonably have become known
in the normal course of business
to the circles specialized
in the sector concerned
operating within the EU
– Decision: Lack of novelty
Court of the EU – 14 March 2018 No T-651/16
klgates.com 41EU ISSUES AND CASES –
BIRKENSTOCK v. EUIPO
“Unluxury” shoes – Take 2
Trademark
Action Refused by
registration filed by
Party Birkenstock EUIPO
Trademark
Court of the EU – 13 Sept. 2018 No C-26/17
klgates.com 42EU ISSUES AND CASES –
BIRKENSTOCK v. EUIPO
“Unluxury” shoes – Take 2
Criteria for distinctive character for surface patterns
– Criteria for trademarks that coincide with the appearance of the goods is
applicable to surface patterns trademarks.
When the use of a pattern is unlikely in the light of the nature of the
products at issue -> no coincidence with the goods and services =
distinctive trademark
When the use of a surface pattern for fashion items is made up of
elements which are repeated regularly and can be extended ad
infinitum, it lends well to being used as a surface pattern -> it
coincides with the goods and services = no distinctive trademark
Court of the EU – 13 Sept. 2018 No C-26/17
klgates.com 43OVERVIEW OF TOPICS
– U.S. Issues and Cases
Proving Irreparable Harm Continues To Evolve
Blurring The Line In Using Celebrity Names Or Images
Parody Or Infringement - How Funny Does It Need To Be?
U.S. Supreme Court Weighs in on IP Issues
– EU Directive 2015/2436
– EU Issues and Cases
– Brexit
– Australia Issues and Cases
Copyright protection for clothing
Google Ads and trade mark infringement
klgates.com 44BREXIT –
WHAT DOES IT MEAN FOR IP?
– …
…
klgates.com 45BREXIT –
WHEN?
klgates.com 46BREXIT –
DESIGNS
– No loss of rights in UK due to Brexit
UK registered and unregistered designs
Unchanged
EU registered designs
Equivalent rights to be created in UK
Pending EU design applications
Priority for UK applications
Continuing Unregistered Designs
Supplementary Unregistered Designs
– Inability to rely on UK rights in the EU post Brexit
klgates.com 47BREXIT –
DISCLOSURE OF DESIGNS
klgates.com 48BREXIT –
TRADE MARKS
– No loss of rights in UK due to Brexit
UK registered and unregistered trade marks
Unchanged
EU registered trade marks
Equivalent rights to be created in UK
Pending EU trade mark applications
Priority for UK applications
– Inability to rely on UK rights in the EU post Brexit
klgates.com 49BREXIT –
ENFORCEMENT/OPPOSITIONS
– UK proceedings based on UK rights
Unchanged
– EU proceedings based on EU rights
Unchanged
– UK proceedings based on EU rights
Will proceed on basis of newly created rights
– EU proceedings based on UK rights
Terminated
Possibility for new UK proceedings if relevant
– Existing EU wide injunctions will still apply in UK
– New EU wide injunctions from UK Courts or including UK not possible
klgates.com 50BREXIT –
IP AGREEMENTS
– “Future proofing” required
– License Territory – EU, Europe, country list
– Governing law and dispute mechanism
– Diligence existing material settlement and co-
existence agreements before Brexit day
– Have Brexit as a live issue for all new agreements and term
sheet discussions
klgates.com 51OVERVIEW OF TOPICS
– U.S. Issues and Cases
Proving Irreparable Harm Continues To Evolve
Blurring The Line In Using Celebrity Names Or Images
Parody Or Infringement - How Funny Does It Need To Be?
U.S. Supreme Court Weighs in on IP Issues
– EU Directive 2015/2436
– EU Issues and Cases
– Brexit
– Australia Issues and Cases
Copyright protection for clothing
Google Ads and trade mark infringement
klgates.com 52AUSTRALIA ISSUES AND CASES –
COPYRIGHT PROTECTION FOR CLOTHING IN AUSTRALIA
– No unregistered design right in Australia
– Copyright cannot generally be relied
upon to protect garment cut
– Copyright can be relied on to protect
fabric prints & other 2D designs applied
to garments
klgates.com 53COPYRIGHT PROTECTION FOR CLOTHING IN AUSTRALIA –
INFRINGEMENT OF COPYRIGHT
– Works that reproduce the whole or a “substantial part” of a copyright work,
without authority, will infringe
– Two elements:
Reference/ copying
– Established by evidence of direct copying or inferred if access to the
copyright work was possible and designs are similar
Substantial part
– Quality rather than the quantity of the part taken – no “safe” amount
to copy
– Is the part taken an ‘essential’, ‘material’ or ‘recognisable’ part of the
copyright work?
klgates.com 54COPYRIGHT PROTECTION FOR CLOTHING IN AUSTRALIA –
SEAFOLLY v. FEWSTONE (CITY BEACH)
City Beach found to have infringed copyright in two original Seafolly
fabric prints and an embroidery design
klgates.com 55COPYRIGHT PROTECTION FOR CLOTHING IN AUSTRALIA –
PRINTS
Seafolly’s English Rose City Beach’s Rosette/ Rosario
klgates.com 56COPYRIGHT PROTECTION FOR CLOTHING IN AUSTRALIA –
PRINTS
Seafolly’s Covent Garden City Beach’s Sienna
klgates.com 57COPYRIGHT PROTECTION FOR CLOTHING IN AUSTRALIA –
EMBROIDERIES
Seafolly’s Senorita City Beach’s Richelle
klgates.com 58COPYRIGHT PROTECTION FOR CLOTHING IN AUSTRALIA –
FINDINGS
– City Beach infringed copyright in all 3 works
– Ordered to pay damages – AU$250,000
– Injunctions – cease making/selling the garments
klgates.com 59COPYRIGHT PROTECTION FOR CLOTHING IN AUSTRALIA –
WHY WAS SEAFOLLY SUCCESSFUL?
– Seafolly kept design files
– Evidence of direct copying by City Beach
– Generous approach to “substantial part” (although many differences)
– Once copying proven, difficult to avoid “substantial part” and infringement
klgates.com 60AUSTRALIA ISSUES AND CASES –
GOOGLE ADWORDS & TRADE MARK INFRINGEMENT
Keyword search
Sourced from: https://www.sharetribe.com/academy/get‐started‐google‐adwords‐marketplace/
klgates.com 61GOOGLE ADWORDS & TRADE MARK INFRINGEMENT –
VEDA ADVANTAGE LTD v. MALOUF GROUP
ENTERPRISES (2016)
TM Infringement Not TM Infringement
Use of the trade mark in the text of a Merely selecting and bidding on a trade
sponsored link as a badge of origin and mark in Google Ads on its own, or in
in relation to the same or similar combination with another word or in any
goods/services for which the trade mark format
is registered
Descriptive search terms or descriptive
use of a TM
klgates.com 62GOOGLE ADWORDS & TRADE MARK INFRINGEMENT –
ACCC v. TRADING POST AUSTRALIA (2011)
Use of a competitors’ business name as an Adword can constitute misleading
and deceptive conduct
– When Internet users conducted a search for “Kloster Ford”, the following
sponsored link appeared:
Kloster Ford
www.tradingpost.com.au New/Used Fords – Search 90,000 + auto ads online.
Great finds daily!
klgates.com 63GOOGLE ADWORDS & TRADE MARK INFRINGEMENT –
GOOGLE v. ACCC (2013)
– Google itself is not liable
– Liability rests with AdWords subscriber
(need to sue subscriber)
– Google will no longer remove keywords at trade mark owner’s request
klgates.com 64GOOGLE ADWORDS & TRADE MARK INFRINGEMENT –
KEY TAKEAWAYS
– Conduct regular Google searches of your trade marks
– You may use descriptive terms or use a trade mark in a way that is
descriptive
– Do not use another’s trade mark (or similar mark) in the Google Ad or
sponsored link of a Google Ad
klgates.com 65PLEASE DO NOT HESITATE TO BE IN TOUCH!
Susan Kayser Friederike von Brühl
Washington DC Berlin
T +1.202.778.9421 T +49.(0)30.220.029.415
susan.kayser@klgates.com friederike.bruehl@klgates.com
Serena Totino Anaïs Ligot
London Paris
T +44.(0)20.7360.8145 T +33.(0)1.58.44.1529
serena.totino@klgates.com anais.ligot@klgates.com
Simon Casinader Savannah Hardingham
London Melbourne
T +44.(0)20.7360.8256 T +61.3.9205.2043
simon.casinader@klgates.com savannah.hardingham@klgates.com
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