Google's New AdWords Policy - What It Means for Brand Owners

A key risk for an intellectual property owner is an2) It may be more difficult to police advertising of
infringement action and a challenge to the validitycounterfeit products.
of the intellectual property rights. For the allegedHowever, there are still things that brand owners
infringer, a validity attack is often the first line ofcan do. For example, refer to and make use of
defence.(from 2011) the increased ASA powers (Asa will
As you know, Google's AdWords service allowshave new powers to regulate websites) which will
you to purchase a registered trademark ofextend to advertising online and on advertisers
another company (even a competitor) as anwebsites. Register a logo in addition to a word
advertising keyword in order to improve themark as a trademark for added protection. Make
ranking of your own website. A number ofappropriate use of copyright and design right
companies (owners of a trademark which werenotices, seek protection under confidentiality laws
used by Google as AdWords keywords) took(where applicable).
exception to this practice and challenged GoogleBrand owners seeking to enforce and protect
for infringement of their trademarks.their trademarks should also be aware of the
The dispute went up to the European Court ofremedies available to them in all circumstances,
Justice which as explained in my previous articleincluding:
(Google AdWords: an advertisers friend or foe)* Considering the possibility of reputation-based
allowed this use provided that certain conditionsinfringement for both major and secondary
were met.brands.
Following this, Google has announced that from* Keeping records of analysis of brand recognition
the 14th of September 2010, it will be revising itsand considering their potential worth (and potential
AdWords policy to allow the use of trademarksto cause damage) in infringement proceedings
by advertisers. The use of other businessshowing:
trademarks will be allowed in the EU and EFTA as- detriment (reduced willingness to buy);
keywords and in the UK, Canada and Ireland into- unfair advantage (increased willingness to buy);
the advertisement itself, prevent brand ownersand/or
from the possibility of complaining for unauthorised- impact on the ability of a mark to convey
use of their trademarks by other businessesvarious messages.
(even competitors).* Take special care when creating surveys in the
Use of trademarks as keywords: The instancescontext of infringement proceedings and, in
where businesses will be able to complain is whereparticular, bear in mind that all surveys (not just
they feel that the advertisement confuses thethose that are relied on) will be disclosable.
audience about the origin of the advertised goods* Keep contact details for potential consumer
and services. In this case the businesses will bewitnesses (including customer complaints) who can
able to use Google's online complain procedurespeak about confusion or a change in shopping
following which if Google deems that the text ishabits (for example, change in economic behaviour
confusing it will be able to remove the particularor willingness to buy).
advertisement.* Be on the look out for evidence of the
Use of trademarks in the text of theintentions of an infringer.
advertisement: in order for this to be allowed,* In comparative advertising, take care that any
1) the trademark must be used in a generic ordata relied on can be supported and meets the
descriptive way and not to indicate the trademarkconditions under the Comparative Advertising
owner of the related goods or services;Directive (2006/114/EC).
2) the advertiser must sell the goods or services* Be aware of the ability to play around with
corresponding to the trademark;others' marks (and the limits on this) in
3) the advertiser must sell replacement parts,comparative advertising.
components or compatible products; or* Watch for references to imitations or replicas: it
4) the advertiser must provide information aboutmay be that action is available where it was not
the goods or services whose trademarks arepreviously.
used, but not in a negative way.This article is for general purposes and guidance
What does this mean for brand owners?only and does not constitute legal or professional
1) Brand owners will need to keep an eye on theadvice.
use of their trademarks in the marketplaceCopyright 2010 Anassutzi & Co Limited. All rights
including Google and will must ensure that, thereserved. Information may be shared or
generic use refer to above, does not dilute thereproduced only if accompanied by the author's
trademarks causing it to lose its distinctiveness.name and bio.