Article: Whether Transfer of IPR is Considered Supply of Service or Supply of Goods Under the GST Regime?

Introduction

Intellectual Property Rights are becoming more and more integral part of businesses. Right owners are expanding the usage of their intellectual properties by way of giving license or assignment. To expand market share, businesses are acquiring/using each-others’ intellectual properties. Transfer of intellectual property can be done in two ways. Right holders can either give their rights over by way of licensing agreement or by way of an assignment. 

Whereas licensing agreement does not actually transfer proprietary rights, assignment agreement transfers rights permanently, including proprietary rights. The applicable tax for these two different types of transactions is different as well. In this article, I shall be discussing the applicable tax on permanent transfer of intellectual property rights based on its nature.

Pre-GST Regime 

Prior to 2017, permanent transfer of intellectual property was not considered as supply of service. As per the C.B.E. & C. Circular F. No. B2/8/2004-TRU, dated 10-9-2004, “A permanent transfer of intellectual property right does not amount to rendering of service. On such transfer, the person selling these rights no longer remains a “holder of intellectual property right” so as to come under the purview of taxable service. Thus, there would not be any service tax on permanent transfer of IPRs” [1]. 

A permanent transfer of intellectual property right therefore did not amount to rendering of service as the person selling these rights no longer remains a “holder of intellectual property right”. In the case of AGS Entertainment Pvt. Ltd. vs. Union of India, [2013 (32) S.T.R. 129] [4], the High Court of Madras took a similar view. 

Another case wherein the court held that service tax is not applicable on permanent transfer is iIn the matter of SKOL Breweries Ltd. (Now known as Anheuser Busch InBev India Ltd.) Vs C.C.E & C.S.T. [Service Tax Appeal No. 2017 of 2012] [5], the Customs, Excise & Service Tax Appellate Tribunal, [Hon’ble Mr. S.S Garg &, Judicial Member, Hon’ble Mr. P. Anjani Kumar, Technical Member] vide its order dated November 10, 2020, took a similar view, and confirmed that there is no service tax applicable on permanent transfer of the intellectual property rights. With reference to the Finance Act, 1994, noting Section 65(55b) – “Intellectual Property Service”“(a) transferring, [temporarily]; or (b) Permitting the use or enjoyment of, any intellectual property right” read with Section 65(105)(zzr) – “Taxable Service” “to any person, by the holder of intellectual property right, in relation to intellectual property service.”, the Tribunal pointed out that one of the key ingredients for determining if any service related to intellectual property right is taxable under service tax or not, is to see if there has been “…temporary transfer of any intellectual property right OR there has to be the permission to use or enjoy any intellectual property right” [Emphasis supplied].  It is clear when there is a transfer of intellectual property rights, it has to be temporary in nature to apply service tax on the same.

Introduction of GST

As per Section 9 (1) of the Central Goods and Services Tax Act, 2017, “there shall be levied a tax called the central goods and services tax on all intra-State supplies of goods or services or both, … as may be notified by the Government on the recommendations of the Council…”. As per the Central Tax (Rate), under the category of service, under heading 9973, “Temporary or permanent transfer or permitting the use or enjoyment of Intellectual Property (IP) right in respect of goods other than Information Technology software” is taxed at 12% (6% CGST+6% SGST) [2], and under the category of goods, “Permanent transfer of Intellectual Property (IP) right in respect of goods other than Information Technology software” is taxed at 12 % (6% CGST+6% SGST) [3] [Emphasis supplied]. 

Since  the term ‘permanent transfer’ is mentioned for both categories viz. goods and service, it may seem like all kinds of services are capable, potentially, of involving a permanent transfer. A reference, however, to the heading of 9973 makes it clear that it is not so.  The heading of 9973 reads as  “Leasing / rental services with or without operator”. The heading of 9973 therefore makes clear that the scope of the heading is limited only to the particular services mentioned in the heading. Notwithstanding the broad language of the contents of heading 9973, its scope does not cover services other than those mentioned in the heading.  It is this author’s opinion accordingly that except only for leasing and rental services, all other services entail only a temporary transfer and that even leasing and rental services may on its factual circumstances entail only a temporary transfer.  Goods, on the other hand, always entail a permanent transfer. It would appear therefore that apart from the specific exception,  temporary transfer or licensing is considered as supply of service and permanent transfer of intellectual property as supply of goods. In my opinion therefore, the position of law remains largely unchanged by the introduction of the GST regime.

Conclusion

Over the years, with changing laws, and developing case law, the doctrinal position of law remains the same. A more specific contextual inquiry is called for, though, in relation to leasing and rental services. Permanent transfer of intellectual property law is not considered as supply of service.  Even though the applicable tax on both permanent and temporary transfer of intellectual property rights happen presently to be at the same rate, by the introduction of the GST law, it has been endorsed that it is only permanent transfer of intellectual property rights that is considered as supply of goods and taxed accordingly.  

End Notes:

[1] C.B.E. & C. Circular F. No. B2/8/2004-TRU. http://centralexcisetrichy.gov.in/newcentral/tradenotice/st/yr0405/tn12.pdf 

[2] https://cbic-gst.gov.in/gst-goods-services-rates.html 

[3] https://cbic-gst.gov.in/gst-goods-services-rates.html 

[4] AGS Entertainment Pvt. Ltd. vs. Union of India. https://indiankanoon.org/doc/123738864/  

[5] SKOL Breweries Ltd. Vs C.C.E & C.S.T. (CESTAT Bangalore). https://taxguru.in/wp-content/uploads/2020/12/SKOL-Breweries-Ltd.-Vs-C.C.E-C.S.T.-CESTAT-Bangalore.pdf 

Disclaimer: Views, opinions, interpretations are solely those of the author, not of the firm (ALG India Law Offices LLP) nor reflective thereof. Author submissions are not checked for plagiarism or any other aspect before being posted.

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Article: Whether Graphical User Interface (GUI) is Protected Under the Designs Act, 2000?

Introduction

Graphical User Interface (hereinafter referred to as “GUI”) is a visual interface that allows interaction with all kinds of electronic devices through graphical elements like icons and menus. The classification of designs under the Designs Act, 2000 (“Act”) does seem to recognize the protection of GUIs but the framework lacks clarity, and its application has been to the contrary.  Currently, GUIs are extended some protection under the Copyright Act, 1957.  Outside India, GUIs are mostly protected under Design Laws. For instance, in the European Union protection to GUIs is accorded under Designs law by virtue of the Community Design Regulation (Council Regulation No. 6/2002/EC).  [1] The absence of unambiguous statutory provisions and clear, consistent precedents makes the topic worthy of judicial scrutiny.

Background 

According to Section 2(a) of the Act, ‘article means any article of manufacture… includes any part of an article capable of being made and sold separately.’

Section 2(d) of the Act states that ‘design means only the features of shape, configuration, pattern, ornament or composition of lines or colors applied to any article whether in two dimensional or three dimensional or in both forms by any industrial process or means… which in the finished article appeal to and are judged solely by the eye.’ 

From a plain interpretation of the above, it is evident that an app or a software can be treated as an article  only if the word ‘manufacture’ includes programming and the writing of the software code. Assuming such an expansive interpretation of the word ‘manufacture’, for the GUI part of the software to be also considered an article, the GUI should be capable  of being made and sold separately. In theory, even if rarely in practice, the GUI code can be written separately from the writing of the code of the subsuming software. Even with this further assumption, for GUI to be an article it would need to be capable of being sold separately as well. GUI, however, is never sold separately from the software subsuming it. It would be dubious to assert that it is capable of being sold separately. Only for the purpose of argument if it is assumed otherwise, and GUI is treated as an article, does it feature a design applied to it by an industrial process? Or could it be that GUI itself is a design applied by an industrial process to the subsuming software?

Answering these two questions turns on an interpretation of the word ‘industrial’.  If the word ‘industrial’ is accorded an expansive interpretation on the same lines as the expansive interpretation of the word ‘manufacture’ (supra) to include the activity of software code writing and programming, GUI can be associated with the concept of a design in the statutory sense. It will still remain unclear, though, whether GUI itself is the design or whether it is the article embodying the design. 

Copyright Protection instead of Design Protection? 

In 2014, on an application filed by Amazon Technologies Inc. [Design Application No. 240305 (2014)] [2] for registration of its GUI for ‘providing supplemental information of a digital work to a display screen’, the Designs Office denied protection. The reasoning given by the Controller of Designs was that a GUI does not meet the requisites under Sections 2(a) and 2(d) of the Designs Act and hence cannot be registered. 

Under the Copyright regime, the issue first arose in relation to copyright protection over computer programs in 2016 in the case of Maraekat Infotech Ltd. v. Naylesh V. Kothari  [2016 SCC Bom 2369]   [3] before a single judge [Gupte S.C., J] of the High Court of Bombay.  The Plaintiff in this case had approached the Court alleging infringement of copyright in its software. The Plaintiff contended that the Defendants were the former employees of the Plaintiff and alleged that they had copied the software developed by the Plaintiff. The Court held that in cases of copyright infringement in computer programs and software, besides comparing the literal similarity between the two software, the overall similarity in features of design and program structure also need to be thoroughly examined. The Court in this case extended the copyright protection available to computer programs and software to their ‘structure, sequence, and organization’. The meaning of the phrase ‘structure, sequence and organization’ can perhaps be understood to cover GUI as well.                

GUIs therefore are currently afforded some protection under the Copyright Act under ‘computer programs and software’ but denied protection under the implementation of the Designs Act.  

It would be useful to discover the Government’s thinking on this dichotomy. 

MeitY’s position on GUI under Copyright Act, 1957 

Grant of protection to GUIs under the Copyright Act also seems to have the backing from Ministry of Electronics and Information Technology (“MeitY”)- 

GUI is an element of the program through which users can interact with various other features of the computer programme. Copyright protects form of expression and can be used to protect source code and the object code of a computer programme. Furthermore, computer programmes are protected as a literary works by the Indian Copyright Act and hence, the look and feel of Graphical User Interface (GUI) can be protected under the Copyrights.” [4].

Conclusion

The development of novel technology and enhancement of existing ones requires evolution of the legal regime. A strict literal interpretation of the existing provisions of the Indian Designs Act renders it near impossible to confer protection to GUIs under the Designs Act. Consequently, the Courts have been bound by the restrictive approach taken by the legislature. Evolving times and international harmonisation arguably require an amendment in the Designs Act, 2000, to widen the definition of ‘article’ and/or ‘design’ to bring GUI under the ambit of design  protection.

  Endnotes

1.https://euipo.europa.eu/tunnelweb/secure/webdav/guest/document_library/contentPdfs/law_and_practice/cdr_legal_basis/62002_cv_en.pdf

2. Design Application No. 240305 (2014). https://ipindiaservices.gov.in/DesignApplicationStatus 

3.    Maraekat Infotech Ltd. v. Naylesh V. Kothari  [2016 SCC Bom 2369] https://www.casemine.com/judgement/in/58117eda2713e179478c4db1

4.  https://www.meity.gov.in/content/copyright

Disclaimer: Views, opinions, interpretations are solely those of the author, not of the firm (ALG India Law Offices LLP) nor reflective thereof. Author submissions are not checked for plagiarism or any other aspect before being posted.

Copyright: ALG India Law Offices LLP

Article: Whether the Test of Similarity is Altered for Abbreviation Marks?

Introduction

Abbreviation basically means a shortened form of a word or phrase. Use of abbreviations as a trademark has become a common practice nowadays for better brand recognition and retention in the minds of a modern consumer. The Trade Marks Act, 1999 (“Act”) under section 2(1)(m) provides that “‘mark’ includes a…word, letter, numeral,… or any combination thereof”. Therefore, abbreviations can be considered as marks under the Act. However, the test of similarity for abbreviation marks would need to be adapted as even change in a single letter can have a huge effect on the likelihood of confusion between the marks.

Test of Deceptive Similarity

Section 2(1)(h) of the Act provides that a mark shall be deemed to be “‘deceptively similar’. – A mark shall be deemed to be deceptively similar to another mark if it so nearly resembles that other mark as to be likely to deceive or cause confusion”. In order to come to the conclusion whether one mark is deceptively similar to another under Section 29 of the Act, it has been held that the broad and essential features of the two are to be considered and an overall similarity leading to the likelihood of confusion is enough. [Parle Products Pvt. Ltd. v. J.P. and Co., (1972) 1 SCC 618] [1].

Abbreviation Marks and Deceptive Similarity

The concept of deceptive similarity as envisioned under Section 2(1)(h) of the Act provides a broad criterion and courts need to interpret the scope of the provision according to the nature of the mark involved so as to appropriately determine the likelihood of confusion. The Courts in India have on several instances dealt with the test of deceptive similarity for abbreviation marks and have enunciated the law on the point. In International Student Identity Card Association v. Abhishek Tiwari [2017 (71) PTC 554 (Del)] [2], it was held that while analyzing deceptive similarity for abbreviation marks under section 2(1)(h) of the Act, there should be a test of phonetic similarly between the two acronyms along with uniqueness or distinctiveness in the abbreviation forming the generic description of the product.

The Supreme Court in Mahendra & Mahendra Paper Mills Ltd. v. Mahindra & Mahindra Ltd. [AIR 2002 SC 117] [3] had elucidated further on the test of deceptive similarity as provided under Section 2(1)(h) of the Act that the question whether there is any likelihood or deception or confusion must be considered in the context of various factors including nature of the market itself, the class of customers, the extent of reputation, the trade channels, the existence of any connection in course of trade, and others. For example, while considering whether MRF would be similar to TRF in identical goods/services, it has to be seen not only in context of the difference in the syllables but also in light of the other surrounding factors like class of consumers, goodwill, etc.

An Altered Approach

The overall similarity approach as used generally for the test of similarity could lead to catastrophic results if other surrounding circumstances as discussed above are not meaningfully taken into consideration. With the same aspect in mind, the High Court of Delhi in the case of CFA Institute v. Brickwork Finance Academy [2020 (84) PTC 12 (Del)] [4] applied the test of deceptive similarity for marks CFA and BFA with an altered approach. The Court, while pondering upon the question of whether there was a likelihood of confusion or deception arising from similarity of marks, came to the conclusion that since the first syllable/alphabet is different/dissimilar, the marks are visually and phonetically dissimilar. The Court then moved on to consider the aspect of the class of purchasers, the mode of purchase and other surrounding circumstances and held that the class of customers who are likely to avail or pursue the courses of either the plaintiff or the defendant will be capable of differentiating between the two programs before enrolling for their preferred course. In this case, while considering the similarity between the marks, the court appropriately concluded, that that there is no likelihood of the two marks being confused as such, by taking into consideration not only the difference in syllable/alphabet but also other factors which are of utmost significance in abbreviation marks.

Conclusion

The test of difference in syllable/alphabet making the marks different/dissimilar as applied by Courts establishes that the test of similarity although overall quite similar but nevertheless should be approached with a slightly altered sense in case of abbreviation marks. The conclusion that can be derived is that with regard to abbreviation trade marks, even a different first letter can make the trademark as such dissimilar, however, the same shall also be dependent on several other factors as provided in the various judicial pronouncements on the subject. The author believes that there must be extra vigilance with regard to abbreviation marks as likelihood of confusion could vary tremendously even with minor modifications.

Endnotes

[1] Parle Products Pvt. Ltd. v. J.P. and Co., (1972) 1 SCC 618. https://main.sci.gov.in/jonew/judis/6909.pdf 

[2] International Student Identity Card Association v. Abhishek Tiwari, 2017 (71) PTC 554 (Del). http://164.100.69.66/jupload/dhc/VIB/judgement/06-03-2017/VIB27022017SC1132016.pdf 

[3] Mahendra & Mahendra Paper Mills Ltd. v. Mahindra & Mahindra Ltd., AIR 2002 SC 117. https://indiankanoon.org/doc/1555192/ 

[4] CFA Institute v. Brickwork Finance Academy, 2020 (84) PTC 12 (Del)

Disclaimer: Views, opinions, interpretations are solely those of the author, not of the firm (ALG India Law Offices LLP) nor reflective thereof. Author submissions are not checked for plagiarism or any other aspect before being posted.

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Article: Are Motion Trade Marks Protected?

Introduction

In today’s fast-paced world, brands are not only represented by conventional forms of trademarks but are also increasingly using unconventional forms of trademarks. In India, the registration of unconventional trademarks is not new. However, it has been mainly restricted to certain kinds of unconventional trademarks such as colour marks and sound marks. The law is still catching up with newer types of trademarks. One such unconventional mark is a motion mark. This article aims to analyse whether a motion mark is registrable under the current scheme of the Trade Marks Act, 1999 (“the Act”).

Motion Marks under the TM Act

The Act does not exclusively define a motion mark. The draft Manual of Trade Marks is also silent on the issue. Generally, a motion mark can be understood as a mark which consists of a movement or change in the position of the elements of a mark. It can be a short clip combining both moving pictures and sound.

The Act under section 2(1)(zb) defines a trade mark as “…a mark capable of being represented graphically and which is capable of distinguishing the goods or services of one person from those of others and may include shape of goods, their packaging and combination of colours…” Further, section 2(1)(m) of the Act states that a “…mark includes a device, brand, heading, label, ticket, name, signature, word, letter, numeral, shape of goods, packaging or combination of colours or any combination thereof…”.

From the above provisions, the following two main issues arise:

1.      Whether the above two provisions are broad enough to include a motion mark?; and

2.      Whether a motion mark can be represented graphically?

Inclusive Definition of Trademark

With regards to the first issue, a Single Judge Bench [Soumen Sen, J.] of the High Court of Calcutta in Assam Roofing Ltd. and Ors. v.  JSB Cement LLP and Ors. [AIR 2016 Cal 41] [1] held that “…Section 2(m) of the Act gives an inclusive definition of ‘mark’.”. Though motion marks were not the subject matter of these judgements, the interpretation by the Court provides reasonable grounds for the inclusion of a motion mark as a mark under the Act.

Graphical Representation of Motion Trademark

With regards to the second issue, the Trade Marks Rules, 2017 under Rule 2(1)(k) define graphical representation as “…the representation of a trademark for goods or services represented or capable of being represented in paper form and includes representation in digitised form…”. Thereby, for registering a motion mark, all the moving elements in the mark must be capable of being represented in a paper form. Graphical representation is also required so that the mark can be published in the Trademark Journal.

However, this requirement makes the registration of a motion mark difficult. Since the correct representation of a motion mark includes the movement of the elements of the mark along with the sound, the same cannot be represented on paper entirely.

Motion Mark as Device Trademark

In India, the first motion mark to be filed was Nokia’s ‘CONNECTING HANDS’ mark under Registration No. 1246341 [2]. However, the Registry records show that the mark has been registered as a device mark rather than a motion mark. Probably owing to this reason, India did not see any applications for motion marks until recently.

Change in TM Registry’s View 

In a recent instance, the Trade Marks Registry, Delhi, initially objected to an application by the Toshiba Corporation for its motion mark for ‘TOSHIBA’ (Application No. 4093005) [3] by stating that “…motion marks are not accepted in India”. However, the Registry subsequently changed its position and the mark was accepted and has since been registered as a motion mark.

In other instances as well, the Trade Mark Registry has registered some motion marks (e.g. Registration No. 4192672 [4] and 4192678 [5]).

The Moving Elements of a Motion Mark

On a perusal of the above registrations, it can be seen that the marks that have been registered only include the graphical representation of the moving elements of the motion mark and not the motion mark in the true sense. The limited ability of graphical representation significantly restricts the protection of a motion mark.

Conclusion

The above discussion shows that despite the initial hesitancy in accepting motion marks, the Trademark Registry has now started to accept and register motion marks. Till the time a motion mark is capable of being represented graphically, it is eligible to be registered provided that the mark satisfies the other requirements of the Act. However, it can be seen that only a handful of motion marks are currently registered. The way forward should include the possibility of representation of such marks in multimedia formats such as MP4 files so as to remove the dependency of graphical representation alone. In the digital age, this will enable the better protection of a more comprehensive array of trademarks. 

Endnotes

[1] Assam Roofing Ltd. and Ors. v.  JSB Cement LLP and Ors. [AIR 2016 Cal 41], pg. 2, available at https://www.calcuttahighcourt.gov.in/Order-Judgment-PDF/O/CS_106_2015_09122015_J_217.pdf.

[2] Registration Certificate available at https://ipindiaonline.gov.in/eregister/showdocument.aspx?document_no=WFlaW1xdMCwvLCorKFhZWltcXQ==.

[3] Registration Certificate available at https://ipindiaonline.gov.in/eregister/showdocument.aspx?document_no=WFlaW1xdKS0wMCssLSpYWVpbXF0=.

[4] Registration Certificate available at https://ipindiaonline.gov.in/eregister/showdocument.aspx?document_no=WFlaW1xdKSsqKSgpKidYWVpbXF0=.

[5] Registration Certificate available at https://ipindiaonline.gov.in/eregister/showdocument.aspx?document_no=WFlaW1xdKSsqKTArJypYWVpbXF0=.

Disclaimer: Views, opinions, interpretations are solely those of the author, not of the firm (ALG India Law Offices LLP) nor reflective thereof. Author submissions are not checked for plagiarism or any other aspect before being posted.

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Review: “Digital Swadeshi and 3D Printing Intellectual Property in India: The Multi-level Perspective, Causal Layered Analysis and Backcasting” by Thomas Birtchnella, Angela Dalyb and Luke Heemsbergenc

Citation: Birtchnella, Thomas; Dalyb, Angela; and Heemsbergenc, Luke, “Digital swadeshi and 3D printing intellectual property in India: The multi-level perspective, causal layered analysis and backcasting”, Futures, ISSN: 0016-3287, Volume 122 (September 2020) < https://doi.org/10.1016/j.futures.2020.102596>

Introduction 

The subject research paper proposes the use of 3D printing technology in India as a potential tool to democratize production and resultant Intellectual Property (IP) creation. The research paper borrows its context of the Swadeshi movement and the coinage of Digital Swadeshi from a newspaper column authored by Mr. Sudheendra Kulkarni on the subject. It bases its foresight and analysis on data collected from the United Kingdom IP Office’s global workshop series on ‘3D printing and IP futures’, the Indian leg for which was held in Indian Institute of Technology, Roorkee in 2018. The research paper  primarily discusses the method and context for data collection and its foresight and the past trends of IP Regulation in relation to the potential for 3D printing innovation in India.

‘Make in India’ and Digital Democratization

This section of the research paper  provides context to the researchers’ view of India as a potential market for 3D printing innovation, based primarily on India’s acceptance and support of open-source technologies and freedom of innovation. It then references ‘Digital Democratization’, i.e. the democratization of production and making of objects by individuals themselves that 3D printing could enable. Aware of the limitation of scale associated with 3D printing technology, the researchers argue that this makes the technology ideal for individual, customized use and a potential boost to “peer-production”. The researchers view this ‘Digital Democratization’ and the power of individuals to join an eco-system of co-creators with other individuals and organizations alike as being consistent with the goals of the Make in India initiative. To support this, the researchers also draw parallels with the Swadeshi movement from the early 1900s, which saw a promotion in self-sufficiency over reliance on imperial mass-produced goods.

The parallels drawn between the potential democratization through widespread adoption of 3D printing technology and the swadeshi movement are interesting. The researchers’ reliance on successful historical movement with aid from the current eco-system establishes a strong case for a potential 3D printing technology market in India. However, it does not appear to factor in certain socio-economic limitations that would make adoption of the technology at the scale it roots for, challenging. In specific, it does not appear to have touched upon the issue of awareness or accessibility of a sizable portion of the Indian population to technology (potentially 3D printing technology in the future), limiting the assumption and impact of democratization to an exclusive part of the population.

3D Printing and IP in India

Having somewhat established a context for its foresight, the next section discusses the role of the IP regime in promoting growth of the technology in India. It first establishes that 3D printing involves IP in two aspects- creation and infringement. While democratized use of technology could enable more individuals to be IP creators, the availability of Computer Aided Design (CAD) files online has been stated as a potential concern for increase in infringement. In light of this, the research paper further examines the copyright framework and judicial trends in India. This section discusses provisions of the Copyright Act, 1957 and the limitation of protection it accords against making of a three-dimensional object from a two-dimensional artistic work for the purposes of industrial application of any purely functional part of a useful device. It also cites judicial trends in upholding refusal of grant of patents in certain spheres, and the liberal invocation of public interest rights over those of foreign organizations, including in copyright matters. Based on the above, the researchers argue that while 3D printing technology may be well adopted and the related IP protected in certain areas, its use in areas viewed as ‘domestic priority’ such as healthcare, education and agriculture, may serve to limit rights of certain foreign IP holders.

In its analysis of the law and judicial trends, the research paper draws a noticeable contrast between priority of localised interests as a boon in promoting the technology in India and the same priority as also indicative of a potentially challenging environment for foreign IP holders in India. This section is also apt in recognizing that regulations surrounding 3D printing remain at a theoretical stage across various jurisdictions, and are evolving to suit growth of the technology and industry.

Conclusion

The research paper, through its basis in history and the visions of the Make in India, makes a strong case in favour of the growth of 3D printing technology in India, and its significant role in catalyzing more creation, including that of Intellectual Property. Its exploration through the IP regime to highlight an existent channel for promotion of innovation, including that of policies in support of self-sustenance and local growth, further aids its case in favour of growth and innovation in the technology in India. In doing so, the paper also sufficiently brings out the IP challenges in 3D printing, the addressal of which remains to be seen.

Disclaimer: Views, opinions, interpretations are solely those of the author, not of the firm (ALG India Law Offices LLP) nor reflective thereof. Author submissions are not checked for plagiarism or any other aspect before being posted.

Copyright: ALG India Law Offices LLP

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