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AB - Copyright Protection for Works of Applied Art under the Berne Convention Berne Convention, Art. 2(7); Civile Code, Art. 1240 (former 1382) ‒ Knoll v Mobilier Headnotes by the Editorial Office 1. Pursuant to Art. 2(7) of the Berne Convention, for a work of applied art to enjoy copyright protection in France, that work must be protected under copyright and not exclusively under design rights in the country of origin. 2. For works originating from the US, it is therefore necessary to assess whether the work contains separable artistic elements that can in themselves be considered as pictorial, graphic or sculptural works. The integral shape of a chair does not satisfy the test, insofar as it is not possible to the separate the aesthetic value of the shape from its function. Court of Cassation (Cour de cassation), decision of 7 October 2020 – D 18-19.441 Facts and procedure 1. According to the decision under appeal (Paris, 13 April 2018), the American company Knoll Inc. and its French subsidiary Knoll International (hereinafter ‘the Knoll companies’) manufacture and distribute contemporary furniture. Claiming that Mr. N… M… an American designer-architect of Finnish origin, had assigned to them, on an exclusive basis, the property rights to two chair and armchair designs under the name Tulip, created in 1957, and that Mobilier et techniques d’organisation productive (MTOP) had supplied the Amiens-Picardie Chamber of Commerce and Industry with 80 chairs that appropriated the characteristics of the Tulip chair, the Knoll companies brought an action for infringement of copyright, unfair competition and parasitism. 2. The Italian company Matrix International, supplier of MTOP, intervened voluntarily in the proceedings. MTOP was declared bankrupt on 17 February 2015 and EMJ was appointed liquidator. 3. The Knoll companies’ claims were dismissed. Examination of the grounds of appeal On the second and third grounds, attached below 4. Pursuant to Art. 1014(2) of the Code of Civil Procedure, there is no need to give a specially reasoned decision on these pleas, which are clearly not of such a nature as to lead to a reversal on appeal on the law. On the first ground Statement of the ground 5. The Knoll companies complain that the judgment held that the Tulip chair and armchair were not protectable in France under copyright law and consequently rejected their claims for damages for infringement, arguing: ‘1. It is incumbent on the French judge who recognises the applicability of foreign law to investigate its content and to apply to the question at issue a solution that is in accordance with the foreign law. As a means of assessing the concept of separability in force in the field of copyright applicable to utilitarian objects, the Supreme Court of the United States, in a decision of 22 March 2017 (Star Athletica v Varsity Brands), established a methodology that is part of the applicable legal rule and requires the judge to consider whether certain aspects of the object can be identified as constituting distinct and intellectually separable pictorial, graphic or sculptural elements, and then to determine whether those distinct and intellectually separable elements, in themselves or applied to a different medium, can be considered independently of any utilitarian aspect. In order to assess the separability of the aesthetic elements, the judge must not take as an element of comparison the object already transformed by these aesthetic elements but a purely utilitarian object not already endowed with these elements. By holding that the law of the country of origin of the “Tulip” chairs, in this case the law of the United States, did not protect them under copyright, on the grounds that “the integral form of a chair or an armchair cannot be considered as a pictorial, graphic or sculptural work when it is closely linked to its function” and that “the form of the Tulip chair and armchair, although guided by the principles of modern design selected by N… M…, will not […] be perceived as anything other than a chair or an armchair”, which excluded the existence of separable aesthetic elements, und thus failing to implement the methodology established by the Supreme Court of the United States, which is a source of law in that country, the court of appeal distorted the foreign legal rule and violated Art. 3 of the Civil Code. 2. It is incumbent on the French judge who recognises the applicability of foreign law to investigate its content and to apply to the question at issue a solution that is in accordance with foreign law. In their appeal submissions of 10 January 2018, the Knoll companies expressly invoked the analysis adopted by the Supreme Court of the United States in its decision of 22 March 2017, which was submitted to the proceedings in French translation. By limiting itself, on the question of copyright applicable in the United States in the field of utilitarian objects, to adjudicating by way of assertion without specifying the provisions of US law set out in the Supreme Court's decision of 22 March 2017, which govern the matter, the court of appeal failed to provide a sound a legal basis for its decision in the light of Art. 2(7) of the Berne Convention. 3. A contradiction in the reasons is equivalent to a lack of reasons. By finding that the elements of furniture designed by Mr. N… M… were merely “useful articles” with no separable aesthetic element, while noting that “design patents No. 181.945 and 181.946 of 1958” and patent No. 2 939 517 relating to the disputed furniture items demonstrated the existence of “aesthetic choices (made by) Mr. N… M…”, which necessarily implied the possibility of the separability of these aesthetic elements, the court of appeal tarnished its decision with a contradiction and violated Art. 455 of the Code of Civil Procedure. 4. It is incumbent on the French judge who recognises the applicability of foreign law to investigate its content and to apply to the question at issue a solution that is in accordance with foreign law. By finding, in support of its decision, “that there is no registration of copyright by the author” and that “the contracts submitted by the Knoll companies do not mention any copyright”, when the fact that the Knoll company had not at the time registered its works with the competent office in order to benefit from copyright protection does not in any way prejudge the eligibility or otherwise of the items of furniture in question for protection under US copyright law, the court of appeal founded its decision on an inoperative ground, thereby failing to provide a sound a legal basis for its decision in the light of Art. 2(7) of the Berne Convention.’ The court’s response 6. Pursuant to Art. 2(7) of the Berne Convention of 9 September 1886 on the Protection of Literary and Artistic Works, works protected in the country of origin solely as designs and models shall be entitled in another country of the Union only to such special protection as is granted in that country to designs and models; however, if no such special protection is granted in that country, such works shall be protected as artistic works. 7. Relying on the consultations and confirmations of custom produced by the parties and on the US Supreme Court’s decision of 22 March 2017 in Star Athletica, LLC v Varsity Brands to determine under what conditions US substantive law protects works of applied art and what method should be followed in assessing whether such works are eligible for copyright protection, the appeal court held that such protection was excluded for a utilitarian object unless it contained separable artistic elements that could in themselves be considered as pictorial, graphic or sculptural works, in which case the protection would extend only to those elements. 8. Then, applying this method, which does not require the judge to take for comparison a similar, purely utilitarian object devoid of any aesthetic element, the decision found, on due and stated grounds, that the shape of the Tulip chair and armchair, pared down and guided by the principles of modern design according to which form follows function, of which Mr. N… M… was one of the proponents, was admittedly based on aesthetic pursuit, but also met functional objectives relating to economy of construction, solidity and user comfort, as the author moreover mentioned in the description of the patent application he filed. 9. Finally, holding that no artistic element can be separated from this functional form, the appeal court, by assessment at its supreme discretion of the meaning and scope of the applicable US law, held, on grounds that are free of contradiction or distortion, that the Knoll companies cannot seek copyright protection in France. 10. Consequently, the ground of appeal, the last part of which objects to a reason that is more than sufficient, is unfounded as to the remainder. For these reasons, this Court: dismisses the appeal; orders Knoll International and Knoll Inc. to pay costs; and pursuant to Art. 700 of the Code of Civil Procedure, rejects the application filed by Matrix International. Thus holds the Court of Cassation, First Civil Division, as delivered by the President in its public hearing of 7 October 2020. The grounds of appeal are appended to the present judgment. Grounds submitted by Mr. Bertrand, counsel for Knoll International and Knoll Inc. First ground of appeal The decision under appeal is contested for holding that the Tulip chair and armchair created by Mr. N… M… were not protectable in France under copyright law and consequently rejecting the claims of Knoll Inc. and Knoll International based on the existence of acts of counterfeiting. The ‘Pedestal’ furniture series of which the claimed armchair and chair are part was created by Mr. N… M…, of Finnish origin but a US citizen since 1940, before 1 March 1957, and probably during 1956, and was published in the United States. The determination of the applicable law therefore results from a conflict of laws rule set forth in Art. 2(7) of the Berne Convention, which is no longer contested in the appeal by the appellants, and the application of these provisions therefore obliges the court to examine the law of the country of origin, in this case the copyright law of the United States of America, before being able to determine whether the appellants can benefit in France from the copyright protection claimed. According to Art. 2(7) of the Berne Convention: ‘Subject to the provisions of Art. 7(4) of this Convention, it shall be a matter for legislation in the countries of the Union to determine the extent of the application of their laws to works of applied art and industrial designs and models, as well as the conditions under which such works, designs and models shall be protected. Works protected in the country of origin solely as designs and models shall be entitled in another country of the Union only to such special protection as is granted in that country to designs and models; however, if no such special protection is granted in that country, such works shall be protected as artistic works.’ This results, on the one hand, in the freedom of each member of the Union to organise the protection of applied works of art and to avail themselves or not of the possibility of accumulating the rights of copyright with those of designs and models, and on the other hand, in a conflict of laws rule that adjusts the applicable law according to the regime for creation in the work’s country of origin. In the present case it is therefore necessary to determine whether the United States protects the contested seats under copyright, in which case the law applicable to the benefit of the protection is the French law on author’s rights if protection is claimed in France, or whether, on the contrary, the United States only protects the seats claimed as designs and models, in which case they can only benefit from this special protection in France. The parties each give a divergent interpretation of US copyright law, the equivalent of author's rights, the Knoll companies maintaining that the Tulip chair and armchair benefit from such protection under US copyright, and Matrix and MTOP claiming, on the contrary, that they do not benefit from any protection under this heading. The Knoll companies have in particular submitted to the proceedings a letter-contract dated 2 May 1957 between N… M… and Knoll Associates Inc, a contract dated 25 April 1968 between the heirs of M… and Knoll Associates Inc, a certificate dated 3 July 2013 from an American lawyer reproducing the aforementioned documents in an appendix, and a report by Professor Q… X… of 20 November 2015 followed by two confirmations of custom dated 2 October 2016 and 21 November 2017, while Matrix, which has joined MTOP in the case, has also submitted to the proceedings a confirmation of custom from Professor G… D… dated 24 July 2013, reproducing the US case law in an appendix, followed by a letter dated 5 September 2013, a supplement dated June 9, 2014 and a second confirmation of custom dated 15 March 2016, an opinion of a French industrial property attorney, extracts from the American Catalog of Copyright Entries for the period prior to 1978, as well as an update of the confirmation of custom of Professor D… incorporating a decision of the US Supreme Court rendered on 22 March 2017. These elements enable this Court to know the content of the US law and its methods of application and to decide whether the armchairs and chairs created by Mr. N… M… and claimed by the Knoll companies are protectable by US copyright law or not, without it being necessary to proceed to a formal comparison of the opinions that were submitted to the discussions on the initiative of each of the parties or to pronounce on the respective competences of the consultants. When confronted with a utilitarian object, US copyright law excludes its protection unless there are separable artistic elements in that object that could in themselves be considered as pictorial, graphic or sculptural works, in which case protection will extend only to such elements. The question that arises in this case is therefore whether the claimed chair and armchair can be considered as ‘useful articles’ without separable aesthetic elements and therefore falling exclusively within the domain of designs in the United States. According to Knoll, the contested chairs have characteristics that are purely artistic and aesthetic such as the base consisting of a single column extending from a circular base and widening to be attached under the lower surface of the shell, the contrast in colour between the white shell and the (red or blue) cushion on the seat, and the curves of the armchair whose shapes evoke, depending on the observer’s perspective, the shape of a woman’s mouth, the shape of a tulip or the shape of a chalice or a wine glass. They indicate that all these perfectly aesthetic elements are clearly conceptually separable and functionally independent of the utilitarian role of an armchair or a chair, which is none other than to allow a person to sit down. However, the integral shape of a chair or an armchair cannot be considered as a pictorial, graphic or sculptural work since it is closely linked to its function. The form of the Tulip chair and armchair, although guided by the principles of modern design selected by Mr. N… M…, will not in fact be perceived as anything other than a chair or an armchair, since there is no separable aesthetic element, and in addition even if the base could be separated from the seat, it would still be a utilitarian part to support the latter, just like the seat or backrest, which are intended to enable the user to sit down. Furthermore, the seats themselves are monochrome, with only the cushion that constitutes the accessory and, incidentally, an addition as compared with the US designs, being of a contrasting colour. Accordingly, no artistic element can be imagined separately from the Tulip chairs, seen as a whole or in parts, in such a way that it can be protected in its own right as a pictorial, graphic or sculptural work by US copyright, contrary to the opinion of Professor Q… X…. These considerations are supported by design patents Nos. 181.945 and 181.946 of 1958 submitted by the Knoll companies as well as by patent No. 2 939 517 relating to the chair, claiming the very shape of the Tulip chair and that of the pedestal and the shell, and in which Mr. N… M… invokes the technical effect of the flare and the practical advantages associated with the shape of the seat. The patent explains why the shape of the pedestal of the chair is the best solution for diffusing the pressure of the weight of the chair user, the flared aspect of the pedestal at the points of contact with the floor and the seat being emphasised and expressly claimed (claims 1 and 5). The shape of the seat (the shell) is described therein and is also the subject of the 6th claim. Thus the patent applied for and obtained on 7 June 1960 demonstrates, both through the description and its claims, that the aesthetic choices of Mr. N… M… are closely linked to the function of the Tulip chair. The scope of the claims does not contradict the utilitarian character of the design of the chair as argued by Prof. X… since the Tulip chair, as marketed, corresponds to this description even if there may be some differences. It should be added that according to the free but uncontested translation of the design patents submitted by the respondents, the applicant indicated ‘The characteristic features of my design are to be found in the part indicated by solid lines on the drawing. I claim: the ornamental aspect for a chair or the like, essentially as I have illustrated and described it’, with the entire shape of the chair and the armchair being indicated in solid lines on the drawing, and with respect to the patent, it states (column 3 page 2), ‘When the shell and the column are assembled, a visual unity (unity of design) results that gives the feeling that the two parts belong together and are, in fact, parts of a unitary whole’. Moreover, there is no registration of the copyright by the author, although at the time of the creation of the Tulip chairs the US law then in force required that a work be registered with the competent office in order to benefit from this protection. Moreover, the contracts produced by the Knoll companies do not mention any copyright; the ‘licence’ of 2 May 1957, the copy of which submitted to the debates contains added comments which suggest the existence of an amendment in the form of a letter of 1 March 1962, which has not been submitted, only refers in Art. 4 to ‘invention patents’ and ‘design patents’, whereas the contract of 24 April 1968 lists exhaustively the industrial property rights to which the licence relates. These elements allowed Professor D…, after pointing out that the US legislator raised to the status of an archetypal example the shape of a chair which is essentially inseparable from its function, to usefully conclude that the Tulip chairs (and therefore the Tulip armchairs) are not protected under US copyright because they do not meet the conditions for such protection. It follows from all of these elements that the law of the country of origin of the Tulip chairs does not protect them under copyright but only grants them protection under the special rights of designs. It is therefore necessary to confirm the decision of 16 January 2015 insofar as it held that the ‘Tulip’ chair and armchair created by Mr. N… M… are not protectable in France under copyright law. The parties are agreed that for useful creations or creations with a function, which is the case of the Tulip chair and armchair, which are intended to be used for sitting on, US law only provides for copyright protection for the sculptural or decorative elements contained in the shape if these can be identified separately or if they exist independently of the utilitarian aspects of the article. In the present case, the confirmation of custom drawn up by Ms. G… D…, whose academic qualifications, publications and professorship constitute serious guarantees of the relevance of her statements to the subject matter of copyright, rightly points out that, in the light of these criteria and the case law to which she refers, the form of the Tulip chair and armchair, which is pared down and guided by the principles of modern design of which Mr. N… M… was one of the proponents and which lays down that form follows function, whether through the flared shape of its base at the point touching the ground and through the shape beneath the seat, as well as the shape of the backrest, admittedly follows an aesthetic pursuit but at the same time corresponds to functional objectives relating to the imperatives of economy of construction, solidity and comfort for the user, as the author moreover mentioned in the description of the application for a patent that he filed, and the usefulness of which was recognised since the patent was granted. It follows that, without ignoring the aesthetic pursuit of which the Tulip chair and armchair were the object, this pursuit cannot be separated from the functionality of these objects, so that these creations are not protectable by US copyright. Consequently, under the terms of Art. 2(7) of the Berne Convention, the plaintiffs can only invoke protection in France under the heading of designs and models. It follows that the Knoll companies’ claims for copyright infringement are to be rejected. The appellants argue that, firstly, it is incumbent on the French judge who recognises the applicability of foreign law to investigate its content and to apply to the question at issue a solution in accordance with the foreign law. In order to assess the notion of separability in force in the field of copyright applicable to utilitarian objects, the Supreme Court of the United States, in a decision of 22 March 2017 (Star Athletica v Varsity Brands), established a methodology that is part of the applicable legal rule and requires the judge to consider whether certain aspects of the object can be identified as constituting distinct and intellectually separable pictorial, graphic or sculptural elements, and then to determine whether these distinct and intellectually separable elements, in themselves or applied to a different medium, can be considered independently of any utilitarian aspect. In order to assess the separability of the aesthetic elements, the judge must not take as a basis for comparison the object already transformed by these aesthetic elements but a purely utilitarian object not already endowed with these elements. In considering that the law of the country of origin of the ‘Tulip’ chairs, in this case the law of the United States, did not protect them under copyright, on the grounds that ‘the integral form of a chair or an armchair cannot be considered as a pictorial, graphic or sculptural work when it is closely linked to its function’ and that ‘the form of the Tulip chair and armchair, although guided by the principles of modern design chosen by Mr. N… M…, will not be perceived as anything other than a chair or an armchair’, which would exclude the existence of separable aesthetic elements (decision under appeal, p. 10 para. 3), without applying the methodology established by the Supreme Court of the United States, which is a source of law in that country, the court of appeal distorted the foreign legal rule and violated Art. 3 of the Civil Code. Secondly and in the alternative, it is incumbent on the French judge who recognises the applicability of foreign law to investigate its content and to apply to the question at issue a solution in accordance with the foreign law. In their appeal submissions of 10 January 2018 (p. 11 end, and p. 21), the Knoll companies expressly invoked the analysis adopted by the US Supreme Court in its decision of 22 March 2017, which was submitted to the proceedings in French translation (exhibit 50, Matrix International). By limiting itself, on the question of the copyright applicable in the United States in the field of utilitarian objects, to adjudicating by way of assertion, without specifying the provisions of US law set out in the Supreme Court decision of 22 March 2017, which govern the matter, the court of appeal failed to provide a sound a legal basis for its decision in the light of Art. 2(7) of the Berne Convention. Thirdly, a contradiction of reasons is tantamount to a failure to state reasons. By affirming that the furniture items designed by Mr. N… M… were merely ‘useful articles’ with no separable aesthetic element, while noting that ‘design patents No. 181.945 and 181.946 of 1958’ and patent No. 2 939 517 relating to the disputed furniture items demonstrated the existence of ‘aesthetic choices (made by) Mr. N… M…’ (decision, p. 10 para. 5), which necessarily presupposed the possibility of the separability of these aesthetic elements, the court of appeal tainted its decision with a contradiction and violated Art. 455 of the Code of Civil Procedure. Finally, it is incumbent on the French judge who recognises the applicability of foreign law to investigate its content and to apply to the question at issue a solution in accordance with foreign law. By holding in support of its decision ‘that there is no registration of copyright by the author’ and that ‘the contracts submitted by the Knoll companies do not mention any copyright’ (decision under appeal, p. 11 para. 2), when the fact that the Knoll company had not at the time registered its works with the competent office to benefit from copyright protection does not in any way prejudge the eligibility or otherwise of the items of furniture in question for protection under US copyright law, the court of appeal decided on an inoperative ground and failed to give its decision a legal basis in the light of Art. 2(7) of the Berne Convention. Second ground of appeal The decision under appeal is criticised for holding that MTOP and Matrix had not committed acts of unfair competition to the detriment of the Knoll companies and for having consequently rejected the Knoll companies’ claims based on the existence of such acts. The court of appeal held that according to the operative part of their last pleadings before the court, the Knoll companies accuse MTOP and Matrix of having committed acts of unfair and parasitic competition by marketing on national territory, under the name Tulip and by using for this marketing the name of Mr. N… M…, chairs and armchairs that are slavish copies of the chairs and armchairs that they market themselves, thereby creating a risk of confusion with the products in the Tulip range and an association between (their) activities and those of ‘the Knoll company’. They explain more specifically that the seats in question slavishly reproduce Knoll ‘models’, that they use the colour combination white and red, that the entire range, i.e. the armchairs and chairs, has been appropriated, that the Tulip ‘trade mark’ which they have been using since 1957 to market the furniture created by M… was also appropriated, as was the name of the designer, with the aim of deceiving the Amiens Chamber of Commerce and Industry about the quality of the products supplied to it and taking advantage of their reputation. They added that the disputed products were intended to renew and complete the rooms of the Amiens Chamber of Commerce and Industry, and that by responding to the latter’s call for tenders, the respondent companies necessarily took advantage of the appellants’ investment and marketing efforts in order to follow in their wake. A design which is not protected by a private right may be freely reproduced, except in the event of fault, in particular where a risk of confusion is created. Matrix markets the disputed chairs under the references ‘SA04’ and ‘SA05’. The name ‘Tulip’ is the title of a creation by Mr. N… M… whose name is associated with the history of design. Finally the appellants cannot appropriate the combination of the colours white and red, which are particularly common in the field of furniture. Finally the CCI of Amiens, which is not a party to the proceedings, and which can be considered to be part of the informed public, placed an order for ‘80 office chairs which must be equivalent or similar to the existing chairs: ref. TULIP KNOLL’, chairs which it already had and whose price is much higher than those ordered. MTOP responded to this invitation to tender without itself referring to Knoll chairs. It follows from these elements that no fault arising from the reproduction of the contested chairs has been established by the appellants and that the first-instance judges were therefore right to reject the application made in respect of unfair competition. The appellants argue that firstly, a model that is not protected by a private right may be freely reproduced, except in the event of fault, in particular where a risk of confusion is created. In dismissing the Knoll companies’ claim for a finding of unfair competition to their detriment by Matrix and MTOP in connection with the manufacture of office chairs supplied to the Amiens Chamber of Commerce and Industry in the context of a call for tenders, on the sole ground that MOTP had ‘responded to this call for tenders without itself making reference to Knoll chairs’ (decision under appeal, p. 12 para. 3), without examining the existence of a risk of confusion between the chairs supplied by MTOP and the chairs produced by the Knoll companies, the court of appeal failed to give its decision a legal basis in the light of Art. 1382, now 1240, of the Civil Code and the principle of freedom of trade and industry; Secondly, in their appeal submissions (served on 10 January 2018, p. 35 para. 6), the Knoll companies argued that MTOP and Matrix International had been guilty of unfair competition by using ‘for the marketing of the disputed products the original name “Tulip”, which is the trademark used exclusively by the Knoll company’. By ruling out the existence of acts of unfair competition on the grounds that ‘the MTOP company responded to the call for tenders without itself referring to Knoll chairs’ (decision under appeal, p. 12 para. 3), without responding to the Knoll companies’ appeal submissions arguing that MTOP and Matrix had used the original name ‘Tulip’, which in itself, independently of any express reference to Knoll chairs, constituted an act of unfair competition, the court of appeal violated Art. 455 of the Code of Civil Procedure. Third ground of appeal The decision under appeal is criticised for holding that MTOP and Matrix had not committed acts of parasitism to the detriment of the Knoll companies and for rejecting, as a result, the Knoll companies’ claims based on the existence of such acts. The court of appeal held that it is common knowledge that parasitic conduct is the set of behaviours by which an economic agent follows in the course set by another in order to profit, without making expenditure of his own, from the other’s efforts, investments and know-how. In the present case, the Knoll companies, which merely state in their final pleadings that ‘the order from the Amiens CCI therefore necessarily resulted from their investment efforts since the launch of the Tulip line, a reference for the perfection of modern form among utilitarian creations (sic)’, have failed to submit any document that could corroborate their claims of parasitism, since they have not provided any information on the investments, whether financial or intellectual, that they have made specifically for the products concerned in the present dispute. The decision must therefore also be upheld insofar as it rejected the claims made in respect of parasitism. The appellants argue that the action for liability for parasitic acts is available to anyone who cannot rely on private rights, and the success of the action does not require the establishment of a risk of confusion. In their appeal submissions (filed on 10 January 2018, p. 39, paras. 7 to 9 and p. 40, para. 5), the Knoll companies argued that they had pursued promotional activities for many years and that they had made significant investments in the context of the manufacture and marketing of the Tulip models created by Mr. N… M…. In dismissing the Knoll companies’ claims based on the acts of parasitism of which MOTP and Matrix had been guilty, without taking into consideration the reputation acquired by the ‘Tulip’ model and the promotional activities pursued by Knoll, from which MOTP and Matrix had abusively benefited, the court of appeal failed to give its decision a legal basis in the light of Art. 1382, now 1240, of the Civil Code and of the principle of freedom of commerce and industry. Translated from the French by David Wright, Kilb, Austria. © Published by OUP and CH Beck on behalf of GRUR e.V. All rights reserved. For permissions, please email: journals.permissions@oup.com and GrurInt@ip.mpg.de This article is published and distributed under the terms of the Oxford University Press, Standard Journals Publication Model (https://academic.oup.com/journals/pages/open_access/funder_policies/chorus/standard_publication_model)
TI - Copyright Protection for Works of Applied Art under the Berne Convention
JF - "GRUR International: GRUR Journal of European and International IP Law (Formerly: Gewerblicher Rechtsschutz und Urheberrecht, Internationaler Teil)"
DO - 10.1093/grurint/ikab078
DA - 2021-06-30
UR - https://www.deepdyve.com/lp/oxford-university-press/copyright-protection-for-works-of-applied-art-under-the-berne-jnc5afsQyB
SP - 1
EP - 1
VL - Advance Article
IS - 
DP - DeepDyve
ER -