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24 - “Accessory Exhaustion” – and Use of a Work as a Work

from A - Intellectual “Property” and its Limits

Published online by Cambridge University Press:  29 December 2020

Niklas Bruun
Affiliation:
Hanken School of Economics (Finland)
Graeme B. Dinwoodie
Affiliation:
Chicago-Kent College of Law
Marianne Levin
Affiliation:
Stockholm University Department of Law
Ansgar Ohly
Affiliation:
Ludwig Maximilian University of Munich Faculty of Law
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Summary

The question of how to handle overlapping IP rights is central to Annette Kur’s scholarship. In addition to her unique overview of and deep insights into all disciplines of IP, she has always been concerned with fairness and balance in IP law. This is a concern that I share, and in the late 1990s, when I was working on finishing my doctoral dissertation on copyright exhaustion, I came to reflect on the interrelationship between the Dior/Evora decision of the Court of Justice of the European Union (CJEU) and the Astra decision of the European Free Trade Association (EFTA) Court.2 Although both the facts of and the reasoning in these two cases were quite different, the common feature of the decisions was the conclusion that the trade mark holder3 was unable to invoke copyright to ancillary material in order to prevent parallel imports of the goods. While reflecting on this, it hardly came as a surprise when Annette simultaneously published an article where she analyzed the trade mark/copyright interface under the viewpoint that the Dior/Evora decision in effect provided for the exhaustion of the copyright holder’s reproduction right,4 also making the link to the Astra decision of the EFTA Court.5 Her article inspired me to introduce the term “accessory exhaustion” to describe the non-application of copyright as an accessory to trade mark exhaustion.6

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Transition and Coherence in Intellectual Property Law
Essays in Honour of Annette Kur
, pp. 294 - 304
Publisher: Cambridge University Press
Print publication year: 2021

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