South African Apartheid Museum at Freedom Park v Stainbank and Another (10152/08) [2010] ZAGPJHC 143; 2010 BIP 148 (GSJ) (23 February 2010)

South African Apartheid Museum at Freedom Park v Stainbank and Another (10152/08) [2010] ZAGPJHC 143; 2010 BIP 148 (GSJ) (23 February 2010)

The court found that the trade mark 'THE APARTHEID MUSEUM' had not been used by the first respondent in the manner required by section 27(1)(b) of the Trade Marks Act. Furthermore, the mark was not capable of distinguishing the services of the first respondent from those of others, particularly given the historical...

Source-derived case information.

Citation
[2010] ZAGPJHC 143
Parties
Applicant: The South African Apartheid Museum at Freedom Park; Respondent: Arnold Michael Stainbank; Respondent: The Registrar of Trade Marks
Court
South Gauteng High Court, Johannesburg
Jurisdiction
South Africa
Case Number
10152/08
Procedural Posture
Review Application / Judgment
Outcome
Application granted; the trade mark registration is to be expunged from the register.
Judges
Willis
Legal Topics
Trade Mark Expungement, Non Use of Trade Mark, Distinctiveness of Mark, Likelihood of Confusion
Intellectual Property Civil Procedure Trade Mark Expungement Non Use of Trade Mark Distinctiveness of Mark Likelihood of Confusion

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Parties

The South African Apartheid Museum at Freedom Park

Applicant

Arnold Michael Stainbank

Respondent

The Registrar of Trade Marks

Respondent

Procedural Posture

Review Application / Judgment

  1. 1 Whether the trade mark 'THE APARTHEID MUSEUM' registered by the first respondent should be expunged for non-use under section 27(1)(b) of the Trade Marks Act.
  2. 2 Whether the mark is capable of distinguishing as required by section 10(2)(a) read with section 9 of the Trade Marks Act.
  3. 3 Whether the use of the mark by the first respondent is likely to cause confusion under section 10(2) of the Trade Marks Act.

Ratio Decidendi

The court found that the trade mark 'THE APARTHEID MUSEUM' had not been used by the first respondent in the manner required by section 27(1)(b) of the Trade Marks Act. Furthermore, the mark was not capable of distinguishing the services of the first respondent from those of others, particularly given the historical and descriptive nature of the term 'Apartheid Museum'. The court held that the continued registration of the mark was likely to cause confusion among the public, as the term is associated with a public institution rather than a private entity. Accordingly, the entry was wrongly remaining on the register and should be expunged.

Court Disposition

Application granted; the trade mark registration is to be expunged from the register.

Orders

  • The Registrar of Trade Marks is directed to expunge trade mark Registration No 98/13337 'THE APARTHEID MUSEUM' in Class 35 from the register.
  • No order as to costs.