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India Business Law Journal
17
Cover story
Intellectual property
May 2009
John Squires, a partner and co-chair of the IP practice
at Chadbourne & Parke in New York, tells a story
about Judge Rich, a former chief judge of the Federal
Circuit Court of Appeals (the highest patent court of exclu-
sive jurisdiction in the US) and the primary author of the US
Patent Act, 1952, which is still in effect today.
“Judge Rich was a young lawyer in the US during the
great depression,” recounts Squires. “My colleague asked
him what it was like being a patent lawyer during the great
depression. Judge Rich smiled and cheerily replied, ‘There
was no great depression for patent lawyers’.”
Judge Rich’s remarks hold true today, says Squires, even
though the current downturn can hardly be compared to
the economic disaster of 80 years ago. “Smart companies
are using and should use the downturn to expand their
reach and IP protections in order to better position them-
selves competitively as markets come back – and come
back they will,” Squires predicts confidently.
Such advice may seem easier said than done for cash-
strapped in-house legal departments, but many strate-
gies for protecting and enhancing the value of intellectual
property make good commercial sense, even in times of
The economic downturn must not deter rights owners
from deploying smart strategies to protect and build
their intellectual property portfolios
Vandana Chatlani reports
Making your mark
Cover story
Intellectual property

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India Business Law Journal
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Cover story
Intellectual property
May 2009

Page 3
India Business Law Journal
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Cover story
Intellectual property
May 2009
adversity (see Crisis management, page 20). Moreover, as
India Business Law Journal reported last month, the risks
and repercussions of hasty cost-cutting when it comes to IP
rights protection can easily outweigh any short-term finan-
cial gains.
“Companies do have specific expense control measures
they can deploy smartly, such as provisional patent applica-
tion filings where commercial markets are less mature and
developing,” explains Squires. “Companies can also ration-
alize certain patents in geographic markets where patent
coverage for products or services may no longer make
sense.
“In addition, in the US there are companies and even funds
that will buy patents or pending applications on the market,
so companies can sell those patents that they determine are
no longer core to them. That is a market dynamic that was
not available even a few years ago,” Squires adds.
Nicholas Studler is the trademark counsel for Eurasia and
Africa at Coca-Cola. He believes there are various ways to
achieve and protect innovations while keeping a tight control
on expenditure. Studler suggests leveraging the advantages
of modern software; allocating work for multiple countries to
one law firm to reduce the administrative burden and obtain
lower legal rates; reviewing and adapting internal processes
and procedures; and optimizing existing portfolios.
“Our budgets changed a lot. We had consecutive budget
reductions in a two-digit range for the last three years,”
reveals Studler, “but not since the beginning of the crisis.
Our management is very cost conscious and we have been
taking action in the last couple of years to reduce unneces-
sary expenses and to become more efficient.”
Saving by spending
It is futile to invest in the development of intellectual
property if one is going to adopt a penny-pinching atti-
tude towards its protection and enforcement (see Doing
away with false economies, page 22). The repercussions of
inadequate protection are severe; one act of breach can
destroy value that has taken many years and considerable
investment to build.
According to Jordanna Popli, a senior solicitor at Wragge
& Co in Birmingham, UK, proper protection is necessary
not only to prevent conscious infringement but also to avert
the copying of third party IP, which sometimes occurs out
of ignorance but in other cases is arguably more calculated
(see Bollywood remakes: Inspiration or infringement?, page 24).
“Companies may do this intentionally, but without knowledge
that it constitutes an infringement, or unintentionally due
to a lack of carrying out proper brand, design, technology
and third party searches,” she says. “Without continuing to
conduct IP audits and brand clearance, a business leaves
itself much more open to the risk of costly litigation.”
Even companies in the innovation stages of product
development are at risk of committing innocent infringe-
ment. “As a result of reduced budgets, some compa-
nies may attempt to minimize their costs associated with
producing a product by copying designs of competing
products or not expending time and money for per-
forming an adequate patent clearance search for the
product,” explains Jody Bishop, a partner at Fulbright &
Jaworski. “This may result in a greater likelihood of infring-
ing the IP rights of others.”
According to Constance Huttner, a partner at Vinson &
Elkins in New York, in-house counsel have a very impor-
tant role to play in minimizing the risks of IP violation by a
company. “One of the worst mistakes a company whose
business relies on its intellectual property can make is to
try to save money by not having an in-house intellectual
property attorney,” says Huttner, who has wide-ranging
experience advising clients in a variety of patent trials and
appeals in the biotechnology and pharmaceutical sectors.
Huttner believes that an in-house lawyer can understand
a company’s business, culture, policies, strategies, and
goals to a degree that cannot be achieved by an external
lawyer. “This knowledge is very important when deci-
sions regarding patent as well as trademark protection
are made,” she says. “The presence of an in-house patent
attorney will save money by the supervision of the outside
attorneys, ensuring that costs are contained as much as
possible and work is done as efficiently as possible.”
Good housekeeping
Several lawyers explain that considerable costs can be
saved simply by conducting periodical reviews of IP portfo-
lios, and that the overall importance of IP maintenance and
prescience (to sustain a long-term vision and to monitor
Without continuing to conduct
IP audits and brand clearance,
a business leaves itself much
more open to the risk
of costly litigation
Jordanna Popli
Senior Solicitor
Wragge & Co
The presence of an in-house
patent attorney will
save money
Constance Huttner
Partner
Vinson & Elkins

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India Business Law Journal
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Cover story
Intellectual property
May 2009
I would advise domestic companies to be very
careful of knowingly stepping on someone else’s IP toes,
because they’re certainly going to recoil. I don’t think
there will be any hesitation in retaliation
at this point of time.
Dev Robinson, Partner
Amarchand Mangaldas
Companies need to register their trademarks and
copyrights and designs on a priority basis. Their IP task
force should remain vigilant and report
any piracy detected.
Karnika Seth, Partner
Seth Associates
In the current environment, reputational threats are
potentially significant and increasing as we see adverse
press reports about some entities. There is potential for
them to suffer enormous and ongoing
damage to key brands.
Kim O’Connell, Partner
Mallesons Stephen Jaques
IP owners should offer real incentives for piracy
reporting to the general public as well as, critically, their
own employees. Link these incentives to seizure values.
Convert your work force into a ‘thousand eyes and ears’.
Ameet Datta, Partner
Luthra & Luthra
Code mechanisms should be in place so that internal
content cannot be used externally. Storage mediums
should be removed. Employees should have no access
to external e-mail and no storage mediums in the work
area. Sophisticated technology is necessary. These are
concrete steps that companies and employers can take
to prevent data theft and a breach of confidentiality.
Chetan Thakker, Partner
Kanga & Co
This is the perfect time to figure out alternative
research and development methodologies that cost less.
I think the downturn presents an excellent opportunity
for companies to introspect and move beyond their
conservative shackles.
Shamnad Basheer, Professor
National University of Juridical Sciences
Every IP-owning company should engage in
strategy management in order to understand the
changing economy and positively respond to such
changes. Companies should follow practices such as
risk management in order to make timely adjustments
and to preserve or enhance their market.
Rahul Chaudhry, Partner
Lall Lahiri & Salhotra
Companies, particularly, in the outsourcing area,
should discuss the issue of retention with their clients
and attempt to build in pricing to provide bonuses or
retention compensation to ensure some consistency in
the workforce. The use of appropriate contracts with
all personnel together with adequate, or slightly above
market, compensation may help to protect client and
company property from subsequent unauthorized
disclosure and avoid unnecessary enforcement costs.
Bijal Vakil, Partner
White & Case
Companies may consider reducing IP registrations
to a need-to-register basis. This will ensure that the IP
portfolio is managed in a cost-effective manner.
Anoop Narayanan, Partner
Majmudar & Co
At a time when a company is cash rich, it can go for
multiple protections ... If you’re at a time when cash is
a problem, you’ll concentrate on the core protections,
which means you’ll restrict it to some strategic
protections which will carry you over a reasonable
distance. You have to get very strategic at this time.
Pravin Anand, Managing Partner
Anand and Anand
Commercially realizing the value of IP can act as a
crutch in financial turmoil. Contractually safeguarding
rights licensed to companies minimizes the risks
associated with insolvency, default or breach.
Jordanna Popli, Senior Solicitor
Wragge & Co
Whether or not there is a recession, you have to
protect your patents.
Milind Antani, Partner
Nishith Desai Associates
Crisis management
Indian and international IP experts offer their tips on safeguarding
intellectual property during the downturn

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India Business Law Journal
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Cover story
Intellectual property
May 2009
Today’s economy dictates that
patents are not commodities
Bijal Vakil
Partner
White & Case
If you are in good hands law
firm-wise, a huge burden is
taken off your shoulders
Nicholas Studler
Trademark Counsel
Eurasia and Africa
Coca-Cola
existing assets) cannot be emphasized enough. Without
such reviews, companies often forget to renew their reg-
istration licences, and so retain unused or useless brands
instead of discarding them. Surrendering these non-
performing patents and applications saves maintenance
fees and prosecution costs, in some cases adding up to
significant amounts.
A common and costly error occurs when a company
simply fails to inform its legal team of its decision to drop
an existing infringement case which is no longer deemed
worthwhile. “Too often companies seek protection for intel-
lectual property, and then turn the prosecution over to the
legal group ... and for a variety of reasons, the business
group elects not to pursue the business opportunity related
to the intellectual property, but fails to advise the legal
group,” says Stuart McCormack, a partner at Stikeman
Elliott in Canada. “So money is spent pursuing something
which, from a business point of view, the internal client has
lost interest in.”
While audits can certainly reduce wastage, they can
also uncover untapped commercial opportunities. “An
audit may reveal forgotten, unknown or unattended IP
assets that may still have potential for exploitation,” says
Mahendra Singh, chair of the IP practice at Delhi-based
PSA Legal Counsellors. “For instance, a book publisher
whose rights in out-of-print titles are still subsisting may
explore the possibility of bringing out fresh, revised editions
or translations or adaptations of some of them, or it may
license such rights to others.”
Bijal Vakil, a partner at White & Case, agrees that unlock-
ing the value of a company’s core products is a vital
and complex process that requires careful assessment.
“Today’s economy dictates that patents are not commodi-
ties,” he says. “The days of simply referring to the size of
a patent portfolio are long gone. The quality of a patent is
much more important today. We have encountered numer-
ous situations where a single patent was much more valu-
able than hundreds of patents in a portfolio.”
Predicting the revenue-generating potential of products
is a challenge, as illustrated in the case of one of Squires’
clients, which ranked its invention disclosures in terms
of anticipated market value in order to determine patent-
spend priorities. “They ranked all their invention disclo-
sures in descending importance – A, B, C, with Cs being
those that looked somewhat interesting, but were not
expected to generate much commercial value,” explains
Squires. “Five years later, the company found that over
75% of its licensing revenue was being generated from
invention disclosures originally categorized as C – that is,
those that were anticipated to have little or no value at the
time of filing.
“The point is, since value in intellectual property is real-
ized over time and it is difficult, if not impossible to predict
the path that technology will take, companies nevertheless
should continue to think strategically and similarly deploy
their resources to the longer view,” Squires says.
Global vision, local focus
While most lawyers agree that long-term vision is criti-
cal to the success of any IP protection strategy, many also
stress the need for an international outlook. “Domestic
markets are important, but more frequently for long-term
business strategy, protection outside the domestic market
is desirable,” says McCormack. “It becomes easier to cre-
ate a joint venture in another country when you have solid
intellectual property protection in that country.”
Kim O’Connell, a Sydney-based partner at Mallesons
Stephen Jaques, believes that companies that lack inter-
national vision risk missing key opportunities and making
costly mistakes. She gives the example of Monster, an
energy drink brand that is at the centre of a protracted IP
dispute.
The drink was originally sold internationally by US-based
Hansen Beverage, which failed to register the trademark in
Australia. Australian manufacturer Bickfords subsequently
registered the Monster trademark in the country and cre-
ated its own energy drink under the same name. As a result,
Hansen is embroiled in an extensive and complex litigation.
It also has to overcome the damage caused to its brand in
Australia by the sale of Bickfords’ product. “What should
have been a simple brand launch is now considerably
more complicated,” says O’Connell. “Hansen has a longer,
harder and more expensive road ahead of it to successfully
establish the Monster brand in the Australian market.”
The Hansen case is indicative of the dangers that face
intellectual property owners in India. Indeed, many com-
panies are particularly vulnerable in India because their
past IP strategies failed to anticipate the significance of the
market and the speed with which it would emerge.

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India Business Law Journal
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Cover story
Intellectual property
May 2009
In the world of intellectual property, attempts to save
money in the short term can lead to serious long-term
losses. Smart IP managers will look instead to simple
measures that focus resources where they are really
needed, protecting valuable assets that are crucial to
the company’s current and future success. Thoughtful,
targeted spending using the strategies outlined below
might save a lot more money than false economies
ever can.
Effective and efficient invention disclosure
reports: Disclosure reports should be clear and com-
prehensive, including all needed drawings, descrip-
tions and models. Careful preparation by the inventor
helps ensure efficient processing of the report by the
drafting attorney, thereby minimizing costs.
Abandoning non-performing patents: The rel-
evance and rates of return of each asset should be
assessed to see if it is still needed. Some companies
are hesitant to abandon an unneeded patent for fear
that it is later found necessary to protect an impor-
tant product or technology. If so, a thorough and
blame-free identification process can be established,
whereby patents identified as unneeded are reviewed
and signed off by the legal, technical and business
groups within the company before being abandoned.
Jurisdiction-specific maintenance of IP: While the
protection of a patent or a trademark may have made
sense at the time of filing in a particular jurisdiction, it
need only be maintained there as it continues to return
value to the company. Using objective standards to
eliminate unnecessary coverage reduces maintenance
fees.
Making only the claims that are really needed:
During patent prosecution, attorneys usually include
claims with the broadest possible scope. However,
claims are often very difficult and expensive to procure
as well as unnecessary to achieve the company’s busi-
ness goals. A more cost-effective approach is to focus
on narrow claims that specifically cover the company’s
technology and its most important applications.
Using trade secrecy: A novel cost-saving meth-
odology has recently become more common: divid-
ing inventions into various parts and filing only one
of these as a patent, while keeping the others as
trade secrets. Under this approach, follow-on inven-
tions may also be kept as trade secrets. However,
this method is advisable only if the company has a
sound secrecy programme in place, and is confident
that competitors will not be able to arrive at the same
invention independently.
Benefiting from IP office delays: The lengthy
processing delays at IP offices can be used to appli-
cants’ advantage: while the upfront drafting and filing
costs of patent or trademark applications cannot be
avoided, the significant costs incurred during prosecu-
tion can be deferred until the economy stabilizes.
Besides these strategies to reduce IP-related costs,
there are also opportunities to enhance the value of an
IP portfolio:
Licensing strategies: These are now widely accepted
as key instruments for achieving corporate goals. Once
it is determined where licensing fits best into a compa-
ny’s overall business strategies, a licensing programme
can be developed to meet the identified aims.
Acquiring cut-price IP: The current economic envi-
ronment offers opportunities to acquire IP at favour-
able prices: cash-strapped investors, and small or
start-up companies that have lost funding, may well
be ready to sell IP reduced rates. It is important to
identify what the purchaser really needs, and to use an
effective valuation process before commencing with
negotiations over prospective purchases.
Audit existing IP agreements: A second look at a
company’s existing assets may reveal valuable back-
royalties that are owed and ready to be collected.
Many companies fail to carry out adequate accounting
of their various IP agreements, often because they are
hidden away in various internal factions of the com-
pany, making them difficult to track.
The cost of IP protection is a small but vital part of
a company’s total R&D investment; registering brands
and trademarks is the easiest and cheapest way for a
company to safeguard the whole process. Although
financial managers are now placing unrelenting pres-
sure on IP professionals to contain or reduce costs,
protection of assets is vital to assure long-term busi-
ness goals. The best answer to the dilemma lies in
auditing, assessing and streamlining IP portfolios.
Doing away with false economies
Rahul Chaudhry, a partner at Lall Lahiri & Salhotra,
explains how companies can maximize the value
and minimize the cost of IP protection
Rahul Chaudhry was called to the bar in September 2002. He joined
Lall Lahiri & Salhotra in January 2004 and became a partner just
four years later. Along with the firm’s founding partners, Anuradha
Salhotra and Amar Raj Lall, Chaudhry is regarded as one of the
most prominent faces of IP management in India.
He can be contacted at:
LLS House, Plot No. B-28
Sector – 32, Institutional Area
Gurgaon – 122001, National Capital Region
India
Tel: +91 124 238 2202
Fax: +91 124 403 6823
Email: rahul@lls.in

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May 2009
With Indian clients, it’s ‘What
is a trademark?’ rather than
a discussion about deceptive
similarity
Chander Lall
Managing Partner
Lall & Sethi
It’s really hard to predict what
kind of policies will be framed
in this environment
Shamnad Basheer
Professor in IP Law
National University of
Juridical Sciences
“India is a very promising and a diversified market where
people are brand-conscious,” observes Jyoti Taneja, a
partner at Akash Chittranshi & Associates. However, as
McCormack explains, “For many years, protecting intel-
lectual property in India through formal registration was
simply not on the radar screen of many companies in
Western countries.
“India’s rapid rise has left many companies lagging
behind in terms of obtaining protection,” he says.
Karnika Seth, a partner at Seth Associates, describes
some of the unique challenges that face IP owners in
the country: “Geographical markets differ significantly
throughout India. Manufacturers and sellers of pirated
goods may keep shifting their locations and appropri-
ate police assistance may be difficult to get in certain
territories.”
“The number of small scale infringers is extraordinarily
high,” adds Studler at Coca-Cola. “The trademark register
is crowded and I was surprised to see many co-existing
identical trademarks. The speed of change makes it hard
to keep up.
“India is a fascinating country, and not only from the IP
standpoint,” he enthuses.
Time for austerity measures?
Studler says that companies should think twice before
discarding any of their IP assets. “As the manager of an IP
portfolio you have to think ahead when making decisions
since all IP filings and applications take some time,” he
says. “One thing is for sure: the economic downturn will
not last forever. If you clean up your portfolio now in order
to save some bucks for your budget, you may end up
spending more at a later time to get the rights back when
you really need them.”
Daren Orzechowski, a partner at White & Case in New
York, says it’s especially important for companies with
international IP portfolios and exposure in India to include
IP related clauses in all contracts with employees and
consultants who may have access to (or may create) IP or
other sensitive information. “Such contracts should focus
on securing confidentiality and locking up intellectual
property rights, and avoiding any reversion rights, from
the moment of creation,” says Orzechowski. “Possessing
a breach of contract claim may ultimately prove more
advantageous than ordinary intellectual property protec-
tion,” he adds.
Regular, commonsense security measures are also
important, says Orzechowski: “In addition to legal pro-
tections, practical physical protections should be put in
place, including computer and office security policies and
restrictions. The legal protections should be the second
line of defence because by the time the legal rights are
analysed the actual security measures have often already
been breached.”
When things go wrong
In such circumstances, IP owners must decide whether
to turn to India’s infamously slow and over-burdened
judicial system in search of recompense. If they do, they
are likely to find that the country’s civil courts offer a more
attractive course of action than the criminal ones.
“In recent times, the Indian civil courts have begun
awarding fairly sizeable compensatory and punitive dam-
ages in IP matters,” says Nikhil Krishnamurthy, a senior
partner at Krishnamurthy & Co in Bangalore.
“Clever civil litigation strategies routinely result in quick
settlements and the payment of costs and damages by
infringers,” he adds. “While criminal remedies do have
the desired deterrent effect immediately following a raid,
criminal trials have their own inherent weaknesses and
rights owners may do well to adopt the civil route.”
Litigation of any sort has the tendency to be slow and
extremely costly, but as Orzechowski explains, costs can
be reduced substantially if the action is run through one
lead counsel and resources are shared. For example,
co-defendants of infringement claims can cooperate
to slash costs and maximize their access to prior art or
other assets that may be useful for leveraging a group
settlement.
Vakil notes that companies entering India (through
outsourcing or otherwise) often lack an adequate under-
standing of how the litigation process works in the coun-
try. “While injunctive relief is available [in India],” he says,
“damages awards are rare and often not commensurate
with the harm caused by an infringement. US companies
would not typically expect this result given the awards

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Intellectual property
May 2009
given through [the US] legal system.”
Vakil continues: “Companies outside India may be well
advised to seek arbitration in India or in accordance with
the appropriate legal principles for the ease of enforcement
in India to remedy this.”
Indian parties often prefer disputes to be adjudicated by
Indian courts, Vakil adds, but “this is often a difficult provi-
sion to obtain in view of the seemingly endless time to trial
along with the perceived bias in favour of Indian parties as
compared to non-Indian parties.”
Obtaining high-quality local legal advice is perhaps the
most sensible approach for multinational companies that
wish to resolve disputes quickly and comprehensively.
“If you are in good hands law firm-wise, a huge burden
is taken off your shoulders,” says Studler at Coca-Cola.
“Seek local expert advice to develop a good strategy;
have a clear defined plan of what your company wants to
achieve in India; be adventurous; and enjoy the opportuni-
ties that incredible India has to offer.”
Signs of improvement
Despite widespread international criticism of India’s judi-
cial system, many observers believe that things are improv-
ing. “Infringement cases are filed in very large numbers
at the Intellectual Property Appellate Board (IPAB),” says
Jyoti Sagar, senior partner of IP boutique K&S Partners and
managing partner of J Sagar Associates. “Delhi High Court
is very established in making judgments on IP,” he adds.
“Judges understand the trademark side and the cases are
procedurally quicker. When a case is made, your appeal is
heard virtually the next day.”
Kalpana Merchant, a Mumbai-based partner at AZB &
Partners, has also witnessed improvements. “The patent
office has better infrastructure [now],” she says. “Even
registration used to be cumbersome. Now it’s much more
efficient.”
Overall, however, India’s IP framework remains at a nascent
stage. Its development is promising, but frustratingly slow.
There is a general consensus that Bollywood is in
bad shape; yet films such as Chak De India, Welcome,
Partner, Taare Zameen Par, Singh is Kingg and Ghajini
have had cash registers ringing at box offices across
the country. So is creativity and originality booming in
Bollywood or not?
Will Smith’s Overbrook Entertainment and Sony
Pictures have their own views on this question, as their
film Hitch may have provided more than just inspira-
tion for the Indian hit Partner starring Bollywood actors
Salman Khan and Govinda. A similar close link exists
between the Denzel Washington film Man on Fire and
Ek Ajnabee with Amitabh Bachhan, and between the
film Momento and the 2008 hit Ghajini, which made
Rs2 billion (US$40 million). More recently, planned
Indian remakes of My Cousin Vinnie and The Curious
Case of Benjamin Button have goaded their Hollywood
owners into action to protect their IP.
A film as a whole is protected as a work, while
underlying elements such as screenplays, lyrics, musi-
cal compositions, sound recordings, photo stills and
set design also qualify for IP protection. A script or a
set of lyrics is a literary work and the Copyright Act,
1957, prescribes certain exclusive rights, including the
right to reproduce the work in any material form, or to
adapt the work in order to make a film.
Film copyright is infringed if the recorded moving
images constituting the film are copied, as in video
piracy. The copyright in a film is not infringed if the
subject matter of a film is remade as a new film; what
may be infringed in such a case are the script, screen-
play and other underlying elements.
This is the tricky part; copyright law does not pro-
tect ideas in themselves, but the expression of ideas.
While the central idea or theme of a story does not
attract copyright protection, the protectable elements
of a film include the textual aspect (the script), and
non-textual aspects including the combination of situ-
ations, events and scenes which constitute the form,
manner and working out or expression of the idea or
theme.
As in the case of a film which copies a theatri-
cal play, the substantial copying of a film’s script or
unique sequenced plot elements may allow a court to
find in favour of a plaintiff. The litmus test is the “lay
observer test”, which ascertains if there is an objective
similarity between two films. The test holds that there
is copyright infringement if the viewer, after having
seen both films, receives an unmistakable impression
that the subsequent film is a copy of the first film.
For example, the verbatim reproduction of dia-
logues (even if translated), “frame to frame” copying
or comparable sequencing of scenes and fleshing
out of characters will lead to a finding of copyright
infringement. Less-obvious copying will still face
close examination by a court, but assessment is more
difficult when there is only a non-textual copying
allegation.
The remaking of foreign films in India has sometimes
been ingeniously explained as “cultural copying”; as a
Inspiration or infringement?
Ameet Datta, a partner at Luthra & Luthra, uses
a case study of India’s film industry to highlight the
IP challenges facing foreign rights owners

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May 2009
Both at home and abroad, fears over the country’s weak
enforcement mechanisms and sluggish judicial system weigh
heavily on the minds of IP owners and their legal counsel.
Krishnamurthy acknowledges the system’s failings but
suggests they can be redressed through the better alloca-
tion of resources and the provision of appropriate training.
“One of the main areas of concern with protecting IP in
India is the lack of specialized courts to handle IP matters,”
he says. “I strongly believe that good precedents in IP
are more likely with specialized courts comprising judges
trained in the various types of IP. Specialized courts could
possibly ensure faster disposal of IP matters.”
Shamnad Basheer, professor in intellectual property law
at the National University of Juridical Sciences in Kolkata,
believes that the judiciary deserves more credit than it
receives. “It’s not that [judges] are stupid,” he says. “They
are trying really hardcore cases – dowry deaths and mur-
ders. When it comes to IP, they are blank. That’s what should
change.”
Krishnamurthy suggests that rights owners should finance
more training programmes for the IP enforcement depart-
ments of the police and customs. “This may in turn give impe-
tus to an increase in suo moto actions by such agencies, with-
out being a burden on the enforcement budget,” he says.
Education is key
Other observers echo Krishnamurthy’s call for a greater
emphasis on education. “Schools, teachers, press, televi-
sion and theatres are all good places to spread awareness,”
says Anand Desai, managing partner of DSK Legal. “Most
people don’t understand what piracy is and are generally
law-abiding.”
Chander Lall, managing partner of Lall & Sethi, takes
this assertion a step further, arguing that education is also
required for IP owners, particularly domestic ones. “They
are completely uneducated about it,” he tells India Business
Law Journal. “The level of understanding [by domestic
prominent director allegedly said: “When you take an
idea and route it through the Indian heart, it changes
entirely.” Such an opinion would probably fail to
impress American director Quentin Tarantino, given
that reports out of Los Angeles referred to Bollywood
film Kaante as a “singing, dancing Reservoir Dogs”.
In the case of RG Anand v Delux Films, the Supreme
Court held that if two authors independently develop
the same idea, there is no copyright infringement
even if there are similarities, saying: “The fundamen-
tal fact which has to be determined [is]… whether or
not the defendant not only adopted the idea of the
copyrighted work but has also adopted the manner,
arrangement, situation to situation, scene to scene
with minor changes or superficial additions or embel-
lishment here and there.”
In Barbara Taylor Bradford v Sahara Entertainment
Ltd, Calcutta High Court held that basic plots and
characters were not protectable under copyright
law. In this case Bradford sued Sahara for copyright
infringement by their use of the plot, theme and char-
acters from her novel A Woman of Substance in their
proposed serial Karishma – The Miracle of Destiny. It
was held that the mere similarities in plot lines and
thematic resemblance did not lead to a conclusion of
copying, and the court cautioned against over-protec-
tion, which could curb future original works.
In Zeccolla v Universal Pictures, Universal Pictures
sought to restrain the exhibition and distribution of
an Italian film, Great White, based upon similarities
to the cult film Jaws. In hearing a challenge by the
defendant to the granting of an interim injunction
wherein he claimed that Universal could not assert
a right on a genre film, the Federal Court of Australia
held that, “In general, there is no copyright in the cen-
tral idea or theme of a story or play however original
it may be; copyright subsists in the combination of
situations, events and scenes which constitute the
particular working out or expression of the idea or
theme. If these are totally different the taking of the
idea or theme does not constitute an infringement of
copyright.”
The court also observed that two questions were
involved: the degree of objective similarity between
the novel and the screenplay, and whether copying
was established. The appeal court upheld the single
judge’s finding: there was such a marked degree of
similarity between the two films that there was an ines-
capable inference of copying and that the respondent
had an excellent chance of success at the trial.
Practically speaking, a suit for copyright infringe-
ment by a foreign copyright owner in India will likely
be subject to the same standards. Were the tests
outlined above to be applied to many Bollywood films
that are defended by their creators as remakes, sev-
eral would be likely to find themselves on the wrong
side of the law.
The 2006 case of Sholay Media & Entertainment Pvt
Ltd & Anr v Mr Parag M Sanghavi & Ors before the Delhi
High Court – in which the Ram Gopal Verma film Ram
Gopal Verma Ke Sholay was restrained from release
due to copyright and trademark infringements in rela-
tion to the cult film Sholay – is a pointer that rights
owners may no longer be willing to let things slide.
Regardless of whether some Bollywood films are
classified as remakes or as cultural copies, the central
issue of infringement remains.
Ameet Datta is a partner with Luthra & Luthra Law Offices’ intellectual
property law practice as well as its media practice and entertainment
practice. He specializes in trademark, copyright and design prosecu-
tion, transactions and litigation, including film and music law, content
aggregation and licensing issues. Datta has represented the Indian
music industry’s two copyright societies for the past eight years. His
practice also includes tort-based litigation involving defamation, pri-
vacy and the right of publicity as well as disparaging advertising.
He can be contacted at:
Luthra & Luthra
103 Ashoka Estate
Barakhamba Road
New Delhi – 110 001, India
Tel: + 91 11 4121 5100
Fax: + 91 11 2372 3909
E-mail: adatta@luthra.com

Page 10
India Business Law Journal
26
Cover story
Intellectual property
May 2009
clients] is completely different [to that exhibited by for-
eign clients]. The level of conversation is completely
different. With Indian clients, it’s ‘What is a trademark?’
rather than a discussion about deceptive similarity. It
is ‘Why do I need to protect?’, ‘Can I get a worldwide
registration?’”
Mahua Roy Chowdhury, an attorney at IP firm Solomon
& Roy, believes that IP education should be extended
to cover the moral and social responsibilities of rights
holders. “India is a cost-sensitive market in which the
majority of the population is unable to afford branded,
copyrighted and patented products bearing a high price
tag,” she says. “Right holders have an equal responsibil-
ity in reducing costs, especially in terms of products of
necessity.”
Different responses
While education is undeniably part of the long-term
solution to India’s intellectual property woes, the chal-
lenges facing IP owners in today’s harsh economic envi-
ronment demand more immediate solutions.
“Almost all clients have become extremely cost-
conscious,” says Ameet Datta, a Delhi-based partner at
Luthra & Luthra. But while the need to cut costs may be
universal, Datta has noticed that companies in different
sectors are responding to the crisis in markedly different
ways.
“Client attitudes differ across sectors,” he says. “The
continuing need to protect and maximize IP continues to
be looked at closely by the music and software indus-
try. On the other hand, the manufacturing and even the
hospitality sectors, in contrast to the good times, are
wary about engaging in litigation and will often opt for
relatively low-cost options such trademark oppositions
and legal notices.”
Milind Antani, head of the pharmaceuticals, life sciences
and healthcare practice at Nishith Desai Associates, has
also noticed different responses. “There is no slowdown
in the pharmaceutical sector ... it’s countercyclical and
you’re seeing IP-driven collaborations and ventures,”
he says. “Pharmaceutical companies are known to have
large portfolios, so overall, they may decide to do away
with unnecessary domain names if they have for exam-
ple, 20,000 names registered, and they may also con-
centrate on fewer brands.”
Basheer believes it is difficult to forecast how compa-
nies will adapt their IP strategies to cope with the global
recession. “It’s really hard to predict what kind of policies
will be framed in this environment,” he says. “The worst
part is we don’t know how long the downturn is going to
last and how intensive it’s going to be.”
On a broader level, Basheer is reassured by the
thought that the financial turmoil will bring creativity to
the Indian market. “There will be a generation of more
ideas – different ways of doing things. Innovation, inno-
vation, innovation … This is the only way companies can
survive this downturn.” g
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