In the latest guest post on the implementation of the EU Trade Mark Directive, Cristina Bercial-Chaumier discusses the Royal Decree-Law 23/2018 in Spain:

The Royal Decree 23/2018 of 21 December 2018 implementing the Trade Mark Directive 2015/2436 was published at the Official State Gazette on 27 December 2018 and entered into force for its main part on 14 January 2019.

The aim of the reform is to facilitate the registration of trade marks, reinforce their protection and to fight against counterfeiting. The role of the Spanish Trademark and Patent Office will be crucial after the reform.

The main change introduced will be the direct competence of the Spanish Trademark Office for invalidity and revocation proceedings. Nevertheless, the deadline for the implementation of this modification is not until 14 January 14 2023.

This change will accelerate and significantly reduce the costs for such proceedings.

It should be noted that from this date, it will be only possible to file invalidity and revocation actions before the courts as a counterclaim in infringement proceedings.

With respect to the most significant modifications that have already entered into force, we refer in particular to the following:

Elimination of the graphical representation requirement: this amendment will open the possibility to register so-called non-traditional marks such as sound, multi-media, motion marks and holograms.

Persons who can be proprietors of Spanish trade marks: any legal or natural person independently of his/her nationality, country of residence or establishment.

Clarification of the absolute grounds: inclusion of specific provisions for designations of origin (PDO), geographic indications (PGI), traditional terms for wine, traditional specialties guaranteed and vegetal varieties. Furthermore,  the prohibition of Article 5 (e) is drafted to include not only the shape but also other characteristics which will be imposed by the nature of the product, which will be necessary to obtain a technical result and which will confer a substantial value to the product.

Relative grounds: specification of PDOs and PGIs as relative grounds of refusal.

Reputation: The concept of well-known trade marks is eliminated from Article 8, while the concept of reputation is maintained benefiting from a higher protection. It will be irrelevant whether the goods and/or services involved are similar or dissimilar. An identity or similarity between the signs will be enough provided that an unfair advantage is sought or that the use of the latter sign is detrimental to the reputation or the distinctive character of the prior trade mark.

Rights conferred by the registration: the registration of a trade mark does not confer on its owner immunity from infringement actions. Contrary to the past, it will no longer be necessary to cancel the later infringing trade mark prior to initiating an infringement action. The specific cases on which the trade mark owner may prohibit the use of the later mark are specified in Article 34 including the right to use the sign in violation of Directive 2006/114CE on Comparative Advertising.

Goods in transit: The trade mark owner may seek an injunction against goods brought into Spain from third countries even when they are not released for free circulation in Spain. Nevertheless, this will not apply where the owner of the goods of the declarant proves that the registered trade mark owner is not entitled to stop the marketing of the goods in the country of destination.

Intervening right as defence in trademark infringing proceedings: The so-called intervening right of Article 16 of the Trade Mark Directive has been introduced in the Spanish Law as a mean of defence for the proprietor of a later registered trade mark in infringement proceedings in Article 44 bis. The trade mark proprietor shall not be entitled to prohibit the use of a later registered trade mark where the junior trade mark could not be declared invalid as a result of:

• limitation in consequence of acquiescence;
• the earlier mark was not distinctive or did not have a reputation; or
• the earlier trade mark would have been subject to a non-use revocation action.

This defence will require reverting to a point in time prior to the filing of the infringement action and will make it necessary for the parties to assess whether it is possible for the defendant to rely upon one of these defences and whether there is evidence in support thereof.

Licensee rights: the licensee may only bring an action for trade mark infringement with the proprietor’s consent. Nevertheless, the exclusive licensee will be entitled to bring an action if the trade mark proprietor has failed to do so after having been asked by the licensee. Furthermore, the licensee may intervene in proceedings initiated by the trade mark proprietor to obtain compensation from the infringer.

Use of the mark: Article 39 introduces the possibility of requesting evidence of use in opposition proceedings provided that the prior mark has been registered for more than five years. Furthermore, the possibility of requesting evidence of genuine use will also be foreseen in invalidity and revocation proceedings before the Office. In this respect, the obligation of providing evidence of use in opposition proceedings will only enter into force when the Implementing Regulation will be published and enter into force.

The proceedings before the Spanish Patent and Trademarks Office will, after the amendments introduced by the Royal Decree, be harmonized and in line with the EUIPO proceedings.

By Cristina Bercial-Chaumier, Casalonga, Alicante, Spain

In the latest Class 46 blog post on the transposition of the EU Trade Mark Directive, David Flynn and Niamh Hall summarise the reforms in Ireland – including the surprising decision to remove absolute grounds from opposition proceedings:

Important changes to Irish trade mark law came into effect on 14 January 2019. The European Union (Trade Marks) Regulations 2018 have implemented Directive (EU) 2015/2436 into Irish law.

In an extraordinary development, the Irish government took the unprecedented step of removing absolute grounds from Irish opposition proceedings. This was because of an unusual interpretation of Article 43 of the Directive from the European Commission as limiting the grounds for opposition (Member States shall provide for an efficient and expeditious administrative procedure before their offices for opposing the registration of a trade mark application on relative grounds).

Despite submissions by the Association of Patent and Trade Mark Attorneys arguing against the interpretation of this as an exhaustive list, with support from other EU sister organisations as well as a learned written opinion from an EU law expert, the Irish government has now removed the possibility of absolute grounds as a basis for opposition in Ireland.

In addition to the above, there are a further number of key changes of which trade mark owners and attorneys should be aware:

Abolition of absolute grounds from opposition proceedings

Oppositions can now only be based on relative grounds; not on absolute grounds. Therefore, it will no longer be possible to oppose an application on the grounds that the mark is non-distinctive, descriptive, generic, deceptive, contrary to law or public policy, or that the application has been filed in bad faith. Furthermore, the shape exclusions will also no longer be available as a ground of opposition.

However, it will be possible to base an invalidity action on any of these absolute grounds. The downside is that anybody who wants to bring an action based on absolute grounds will have to wait until the mark is registered. The possibility of filing unilateral observations against a pending application on absolute grounds still exists but this is not generally as effective as an invalidity action or formerly an opposition.

Proof of use/non-use as a defence in opposition, invalidity and infringement proceedings

If an earlier trade mark which forms the basis of an opposition, invalidity action or infringement action is over five years old, the owner can now be put on proof of use as part of those proceedings. If genuine use of the earlier mark cannot be shown within the relevant five year period, the opposition/invalidity/infringement action will fail (unless there are proper reasons for non-use).

This means that non-use can now be used as a defence in opposition, invalidity or infringement proceedings. Furthermore, for an infringement action, if an earlier trade mark is vulnerable to revocation based on non-use, a defendant does not have to initiate separate revocation proceedings or counterclaim for revocation to successfully defend the infringement action.

Own name defence

This is now limited only to persons who use their own name and address. It no longer applies to company names. In addition, use of a sign as a trade or company name can now be considered infringement without recourse to this defence.

Removal of graphical representation requirement

It is no longer a requirement that a trade mark be graphically represented for it to be eligible for protection. This means that it will now be possible to register non-traditional trade marks such as sounds, multimedia marks and holograms by uploading digital files such as MP3 and MP4. However, the trade mark must still be represented in a manner that enables the Controller and the public to determine the “clear and precise subject matter of the protection afforded to the proprietor”.

Brand owners should be aware that the Madrid System still requires graphic representation of a trade mark, so unless a trade mark application filed with the Irish Patents Office includes a graphic representation, it cannot be used as a base application for an international application.

Additional absolute grounds

The list of signs excluded from registration has been extended. Signs consisting exclusively of shapes or “another characteristic" will be refused registration if the shape or other characteristic results from the nature of the goods, or is necessary to obtain a technical result, or gives substantial value to the goods.

Furthermore, trade marks will be refused registration if their use is prohibited by any enactment or provision that safeguards Protected designations of Origin (PDOs), Protected Geographical Indications (PGIs), traditional terms for wine and traditional specialties guaranteed, and prior plant varieties. Therefore, from now on trade mark applications will be examined having regard to these additional absolute grounds.

Additional relative grounds

Going forward, PDOs and PGIs can be used as a basis to oppose or invalidate a mark on relative grounds.

Goods in transit

Infringing/counterfeit goods which are “in transit” but not intended for free circulation in Ireland can be detained by Customs with the burden of proof shifting to the importer or holder of the goods, who must show that the trade mark proprietor is not entitled to prohibit the placing of the goods on the market in the country of final destination.

Expansion of anti-counterfeiting measures including preparatory acts

A wider range of counterfeiting activities will now be considered to be acts of trade mark infringement. These include affixing a trade mark to packaging, security, authenticity features or devices, labels, and/or selling, stocking or offering such items for sale, or importing/exporting them.

Comparative advertising

The use of a mark by competitors in comparative advertising may now be prevented by the mark’s proprietor as being a trade mark infringement if it breaches the EU Comparative Advertising Directive (2006/114/EC).

Assignment of trade mark

While it has been always possible to transfer ownership of a trade mark under the Trade Marks Act 1996, there is a new provision whereby the transfer of a whole business shall include the transfer of the trade mark, except where there is agreement to the contrary, or circumstances clearly dictate otherwise.

Therefore, if a trade mark is not included in the transaction documents relating to the sale of a business, the seller will be automatically obliged to assign the mark to the buyer, unless there is an agreement to the contrary or the circumstances say otherwise.

Licensing

There are new provisions whereby, subject to the provisions of the licence, a non-exclusive licensee may bring proceedings for infringement of the trade mark only with the consent of the proprietor. However, the holder of an exclusive licence may bring infringement proceedings if the proprietor of the trade mark, after formal notice, does not bring infringement proceedings within an appropriate period.

Furthermore, a licensee will now have a right to intervene in infringement proceedings brought by the proprietor of the trade mark in order to seek compensation/damages.

Division of registrations

It will now be possible for the proprietor of a registered trade mark to divide the registration into two or more separate registrations.

Reproduction of trade marks in dictionaries, encyclopedias and similar reference works

If the reproduction of a trade mark in a dictionary, encyclopedia or similar reference work gives the impression that it is a generic term for the goods or services which the trade mark is registered for, the publisher of the reference work must now ensure that the mark, at the request of the trade mark proprietor, is accompanied by an indication that the mark is a registered trade mark.

Conclusion

The transposition of the Directive brings important modernizing changes to Irish trade mark law. We consider trade mark owners and attorneys will welcome these changes for the most part.

By David Flynn and Niamh Hall, FRKelly, Dublin & Belfast

Following yesterday’s blog post about the trade mark changes in the UK, Class 46 has received a number of contributions from other EU Member States, which will be posted over the next few days.

This article on the new law and fees in Lithuania has been contributed by Vilma Dauskurdiene:

Starting 1 January 2019 the new version of the Trade Mark Law implementing the provisions of the EU Trademark Directive 2015/2436 came into force in Lithuania and brought changes in the field of trade mark registration and protection. The most significant changes set in the new Law are:

Abolition of the requirement of graphic representation

As of 1 January 2019, applicants can file a trade mark without having to provide a graphical representation of the sign. The important requirement becomes that using developing technologies, the sign will have to be represented on the Register of the Lithuanian trade marks in a manner that enables the competent authorities and the public to determine the clear and precise subject matter of the protection afforded to its owner. This opened wide possibilities for registration of non-traditional signs, such as holograms, motion marks, sounds and colours.

Certification marks as a new kind of trade marks

The new Trade Mark Law recognizes certification marks.

Changes in stage of trade mark registration

The new Trade Mark Law extends absolute grounds for refusal of registration and sets prohibitions concerning designation of origin; geographical indication; traditional specialities guaranteed; traditional terms for wine; and plant variety rights protected at EU or international level which are used in a sign.

The new Trade Mark Law changes trade mark registration procedure from post grant to pre grant. That means after the State Patent Bureau conducts trade mark examination and ascertains that the mark satisfies absolute grounds for registration, the mark is registered after opposition term expires or, if an opposition is filed, after the opposition procedure ends.

The new Trade Mark Law introduces observations of third parties. Any interested persons may submit to the State Patent Bureau written observations as to the capability to register a trade mark based on absolute grounds ex officio. Such persons shall not be parties to the proceedings before the State Patent Bureau. The observations shall be communicated to the applicant only. Third parties’ observations shall be submitted before the end of the opposition period or, where an opposition against the trade mark has been filed, before the final decision on the opposition is taken. Such procedure shall give a possibility to protect public interests without entering into dispute.

An opposition is possible based on relative grounds only. The bad faith ground disappeared from the list of relative grounds. An interested person may ground its claim on bad faith only in trade mark invalidation cases.

The essential change in opposition proceedings is indeed that the applicant is entitled to claim proof of the genuine use of the opposing right if it is more than five years old. In the absence of proof of use, the opposition will be rejected in whole or in part. The new Trade Mark Law sets non-use of a trade mark as a measure of defence not only in opposition but also in invalidation of the trade mark proceedings.

Mandatory pre-trial procedure

In order to reduce the workload of courts, a mandatory pre-trial administrative procedure is established. Before the new Law, the trade mark could be recognized as invalid or cancelled only by filling a claim to the court. After the new Trade Mark Law came into force the Appeals Division of the State Patent Bureau is competent to examine such kinds of disputes and adopt decisions.

Examination of opposition remains the competence of the Appeals Division of the State Patent Bureau. However, the new Trade Mark Law stipulates that the opposition shall be filed within three months from the date of publication of the trade mark application but not after the publication of the trade mark registration.

The decisions of the Appeals Division of the State Patent Bureau can be appealed to the Vilnius District Court that hears such cases as the first instance court. It is important to note that the term to appeal decisions of the Appeals Division of the State Patent Bureau is shortened from six months to three months after adoption of the decision.

The new Trade Mark Law sets a possibility to settle trade mark disputes in an amicable way on the initiative of both parties by filing a common request or by using mediation. Not less than two months but not longer than a one year term is provided for amicable dispute settlement.

Elaborated rights and restrictions of the trade mark owners

In addition to rights of the trade mark owners provided in the old law, the new wording elaborates the rights of the trade mark owner in case of transit where the trade mark owner may prevent other persons to enter such goods to the Republic of Lithuania without placing goods freely on the market of the Republic of Lithuania, unless the person transporting the goods proves that the trade mark owner is not entitled to prohibit placing of those goods on the market in the country of final destination.

Recovery of non-material damage

The new Trade Mark Law sets out that a person who violates the rights of the trade mark owner must be liable for non-material damage. The monetary amount of this damage is determined by a court.

The entry into force of the new Trade Mark Law resulted changes to many official fees in the Law on Fees for Registration of Industrial Property Objects, which also came into force on 1 January 2019.

It is noted that the official fees have been increased. For example, the basic fee for trade mark registration by combining two currently applied fess (trade mark application filing and trade mark registration fees) increases from €138 to €180, if only one class of goods or services is indicated in application. For each subsequent class of goods or services an additional fee is paid, which increases from €34 to €40.  

The fee for filing an appeal increases from €34 to €60 and for opposition from €92 to €160.

The Law on Fees sets a new fee of €150 for accelerated examination and €180 for examination of request for invalidation or cancellation of a trade mark registration before the Appeals Division of the State Patent Bureau.

Summarizing changes in the law, trade mark owners now have new opportunities for registration of marks and developing strategies for protecting their trade marks and can expect an easier and faster administrative process to achieve results.

Vilma Dauskurdiene is a Trademark and Patent Attorney with AAA Law

Changes to the Trade Marks Act 1994 and the Trade Marks Rules 2008 came into effect today (14 January 2019). These changes implement the EU Trade Mark Directive 2015 in the UK.

14 January is the deadline for EU member states to comply with various requirements of the Directive, as set out in Article 54. However, they have until 14 January 2023 to comply with Article 45 (procedure for revocation or declaration of invalidity).

The UK Intellectual Property Office has a page on its website setting out the changes in detail. It states:

These changes have been made by the Trade Marks Regulations 2018 (TM Regs). These were originally published in draft as part of a consultation in February 2018. Following on from comments received, certain aspects of the TM Regs were amended to produce the final version. They give effect to the EU Trade Mark Directive 2015.

The guidance includes references to the relevant section or schedule of the Trade Marks Act (TMA) or rule of the Trade Marks Rules (TMR), and to the regulation in the TM Regs which introduces the change. An unofficial version of the TMA has been produced to show the changes. The unofficial version of the TMR will be updated in January, once the changes have come into force.

The main changes covered in this note fall within the following broad headings:

• applying for a trade mark
• objecting, challenging and resolving trade mark disputes
• managing trade marks

A list of national transposition measures communicated by EU member states to the European Commission relating to the Directive is provided here.

Class 46 welcomes contributions from readers in EU member states regarding other changes to national systems that have been implemented or proposed as a result of the Directive. Please email the editor at editor@marques.org

Readers might be interested in two events coming up soon in Europe.

EU Judges Meeting

There are still a few places left at the MARQUES EU Judges Meeting, taking place in Amsterdam (right) on Friday 18^th January.

This new one-day event brings together IP-specialist judges and practitioners from across Europe.

Speakers include judges from various EU member states as well as the General Court and EUIPO Boards of Appeal. They will address various current issues in IP law and practice in Europe, as well as taking questions from the audience.

Find out more on the dedicated page on the MARQUES website. Register now to secure your place!

EUIPO IP Mediation Conference

The second IP Mediation Conference is being hosted by the EUIPO Boards of Appeal, the EUIPO Academy and the International Cooperation and Legal Affairs Department of EUIPO.

It takes place in Alicante from 30^th to 31^st May 2019 and features experts from national and international institutions, academia and EUIPO.

The conference aims to explore the benefits and added value of mediation for all parties.

Find out more on the dedicated page on the EUIPO website.

By Nikos Prentoulis

In its judgment in Sekmadienis v Lithuania (application number 69317/14), the European Court of Human Rights (ECtHR) defined the contours of "public morals" and their punitive reach over commercial free speech.

Controversial adverts

Lithuania’s State Consumer Rights Protection Authority (SCRPA) fined Sekmadienis (Sunday in Lithuanian), a domestic ad agency, over a two-week campaign considered to violate Lithuanian public morals and, in particular, Christian religious sentiments.

The advertisements (below) ran during September 2012, in connection with a clothing line of a Lithuanian designer and in order to promote his (then) upcoming fashion show. The marketing effort to provoke Christian religious sentiment is rather obvious, and, in my view, disappointingly old fashioned.

The SCRPA did not act ex officio, but after receiving five separate (telephone) complaints. It found the ads to be in breach of Article 4, Section 2(1) of the Lithuanian Law on Advertising and fined Sekmadienis some €580.

It is interesting to note that during national proceedings, after Sekmadienis challenged the fine, the law was amended to include an express prohibition on the expression of contempt for religious symbols in advertising.

The ECtHR judgment

The case found its way to the ECtHR on the grounds of alleged violation of Article 10 of the European Convention on Human Rights, which protects freedom of expression, including commercial expression, such as advertising.

The ECtHR reiterated its key jurisprudence reminding us all that any interference with freedom of expression should be: (i) prescribed by law; (ii) in pursuit of a legitimate aim; and (iii) necessary in a democratic society.

In addressing the matter, the Court clarified that “not every use of religious symbols in advertising would violate public morals" and was critical of the fact that while the case was ongoing, the national authorities felt compelled to change the law. It did concede that the restriction pursued legitimate aims, namely the protection of morals arising from the Christian faith and the right of religious people not to be insulted on the grounds of their beliefs.

As regards “necessity”, the Court noted that, unlike political speech or the debate on matters of public interest, states have a “broad margin” of appreciation in the regulation of speech in commercial matters or advertising, but that margin is not “unlimited”. Sufficient explanation of the restriction should therefore have been provided by the Lithuanian courts and authorities. But the rationale supporting the legality of the fine fell short of being sufficient, according to the Court, which was also particularly critical of the reasoning adopted in SCRPA’s decision that the advertisements “promot[ed] a lifestyle which [was] incompatible with the principles of a religious person”, without even explaining why a lifestyle which is “incompatible with the principles of a religious person” would necessarily be incompatible with public morals.

Accordingly, the Court concluded that “the domestic authorities failed to strike a fair balance between, on the one hand, the protection of public morals and the rights of religious people, and, on the other hand, the applicant company’s right to freedom of expression”.

Comment

The inadequate reasoning behind the fine provided a quick way for a finding of an Article 10 violation. However, it would be a mistake to construe the judgment as a “carte blanche” to the use of religious symbols in advertising. The judgment reminds us that commercial expression is subject to a wider state margin of discretion (unlike for example political expression), which however must be exercised with caution and sound reason. It also affirms that rights under the ECHR, such as freedom of expression, must be exercised in a way that does not jeopardize the exercise of other rights under the ECHR, such as freedom of religion. In the end, national authorities must balance conflicting interests and also provide solid grounds for the outcome of such balancing.

The judgment was issued on 30 January 2018, shortly after the General Court of the EU issued its judgment in Fack Ju Göhte (Case T-69/17) and has been contrasted to that judgment, as a more liberal approach to commercial expression.

In my mind, there is little to compare between a word mark obviously reproducing vulgar language, and these ads. Would public morals be the reason for the EUIPO or the EU courts to reject these ads or a word mark "Jesus, Mary! What a style" in class 25? I am not so sure. "JESUS IS MY HOMEBOY" was actually registered as a (then) CTM back in 2003 in class 25, and so was "SECRET JESUS" in 2015 and in 2012, and even "GOD CAN'T DESTROY STREETWEAR" in June 2018. These examples show that filing the slogans in the ads as EUTMs might have been a reasonable and educated risk.

That being said, it may not be entirely unfair to say that the EUIPO and the EU courts, in interpreting the public morals bar to trade mark registration under the EUTM regulation or the Trade Marks Directive, are indeed less lenient. The recent General Court ruling in La Mafia se sienta a la mesa (Case T-1/17), accepting a cancellation action filed by the Italian state is perhaps a lucid example. The General Court took an unequivocal stand, ruling that “the contested mark, considered as a whole, refers to a criminal organisation, conveys a globally positive image of that organisation and, therefore, trivialises the serious harm done by that organisation to the fundamental values of the European Union … is therefore likely to shock or offend not only the victims of that criminal organisation and their families, but also any person who, on EU territory, encounters that mark and has average sensitivity and tolerance thresholds."

For those interested in the interaction between trade marks and free speech, the IP Emerging Issues Team has drafted a multi-jurisdictional booklet, which, with the help of colleagues around the world, sheds interesting light in how various jurisdictions around the globe approach this, uneasy at times, relationship. The booklet can be found here.

Nikos Prentoulis is a member of the MARQUES IP Emerging Issues Team and a Partner at PRENTOULIS GERAKINI Law Partnership

In a guest post, Jose Amorim of the MARQUES Education Team summarises some of the learning opportunities offered by the EUIPO Academy this year:

EUIPO’s Academy Activities and Learning Catalogue for the current year has just been launched and I recommend the IP world to have a look at it.

Webinars

I am sure that several topics will be considered interesting since the diversity of subjects is immense (an average of 20 webinars are produced on a quarterly basis) covering a wide range of topics for all types of audience (from basic to advanced contents).

For instance, every quarter there are two webinars on case law: EUIPO Board of Appeal and General Court/Court of Justice decisions. These are popular and useful for practitioners because they have the information summarised by the experts.

Out of the 82 webinars presented in the course of 2018, 19 had a certificate. Certificates are an added value for practitioners who receive credits for courses in EUIPO’s portal. And the webinars boast a 90% satisfaction rate overall.

Currently, EUIPO’s Academy is working on creating “interactive webinars”. The idea is to have a brief presentation on an IP topic, and during the webinar or afterwards, the audience can ask questions regarding the presentation directly to the speaker.

To access webinars and be permanently updated on contents, it is highly recommended to subscribe to Academy’s newsletter. Webinars always take place on Tuesdays.

IP Course for Paralegals

There is also an IP Course for Paralegals that has become increasingly popular since it addresses very specific and practical needs of users. This course, which is free of charge, takes place between 28 and 30 October in Alicante having as its goal to increase operational efficiency, not just of paralegals and practitioners but also of the EUIPO.

MARQUES has been present in the ECP3 Academy e-learning portal project in order to convey the perspective of Users Associations.

EUIPO Trade Mark and Design Education Programme

A new initiative in the Academy is the EUIPO Trade Mark and Design Education Programme, which is a training programme for IP practitioners. It is a practical programme, delivered by the EUIPO staff, leading IP professionals and academics.

The Programme focuses on the interaction between the EUIPO and IP practitioners in trade mark and design registration and prosecution and is aimed at increasing knowledge of the proceedings and practice of the EUIPO to improve the quality of the applications and submissions before the EUIPO and to provide sound bases to develop successful strategies for registering, defending or contesting EU IP rights using the EUIPO´s tools and systems.

Enrolment in the EUIPO Trade Mark and Design Education Programme takes place between May and June and the next course will start in September. MARQUES has been deeply involved in the Programme, providing speakers for the 150-hour course and members of the Examination Board and the Steering Committee.

Jose Amorim is a lawyer with Gastão da Cunha Ferreira Lda and a member of the MARQUES Education Team