Archive for September, 2012

Techblogger article on interim contractual remedies under Scots law

My colleague Iain Rutherford and I have an article in this month’s edition of SCL Magazine, looking some of the unique interim remedies available to parties contracting under Scots law, following a recent case at the Court of Session in Edinburgh.

The article looks at these remedies from the perspective of those involved in ICT and outsourcing contracts, and will be of particular interest to organisations that contract under Scots law, contract with a Scottish entity, or otherwise have the option of opting for Scots law jurisdiction.

For example, IT and outsourcing suppliers contracting under Scots law with Scottish organisations should be aware of the interim orders available to their customers and the tactical advantage this may give to their customers in the event of a dispute.

Similarly, organisations (whether Scottish or otherwise) that currently opt to contract under English law may wish to consider whether these remedies would provide them with more effective tools in the event of a dispute.

You can read the article by following this link.

Brodies Intellectual Property Survey Results- download now!

Recently we carried out a snapshot 60 second survey on Intellectual Property (IP) in conjunction with ADS, ScotlandIS and SCDI. We were keen to learn more about how businesses are dealing with such valuable key assets and what IP issues are of most importance to them. Responses were received from both large and small companies from a broad range of sectors.

The survey asked a number of key IP related questions such as whether audits were carried out to keep a track on the extent and value of IP, how it was used on social media platforms and whether businesses were involved in IP disputes. The results provide an interesting snapshot and insight into how businesses are dealing with IP as well as highlighting some areas where altering how IP is managed could improve the competitive advantage it gives to a business as well as maximising commercial returns.

We would like to share the results with you. They are available to download here 

Robert Buchan

A reflection on Apple v Samsung – is the jury out on jury cases?

The recent Apple v Samsung case in the US is one of the most talked about Intellectual Property (IP) decisions of the year and commentators are continuing to speculate on the impact that the decision will have on the tablet and smartphone industries.  However, from a legal perspective one of the most interesting aspects of the case  is the role that the jury played in arriving at the decision that Samsung was guilty of infringing Apple’s patents and how it calculated the damages award of around $1 billion against Samsung.

In the US, as readers will be aware, juries can be used to decide civil intellectual property cases.  However, in the UK only a judge or judges can do so.  This got me thinking about the pros and cons and of each approach and whether there is an advantage of one over the other. 

Understanding the technology
In intellectual property cases, one of the most difficult aspects is understanding the technology that forms the substance of the dispute.  This is particularly true in patent cases where the subject matter can comprise, for example, a pharmaceutical compound or a mechanical process or indeed cutting edge mobile phone technology.  In cases of a complex nature, an industry expert will usually be engaged to prepare a report to assist the lawyers and the Court understand the technology and to assist their legal arguments on the issues of validity and infringement of that patent.  Frequently, the technology will be so complex that more than one expert is engaged and each will deal with distinct parts of the patent.  The judge will spend many days listening to evidence and legal arguments on all the issues before reaching his decision. 

It may be fair to assume that the majority of jurors hearing a case will have neither a technical or a legal background.  That is not to say of course that juries cannot understand the technology or the substantive law required to arrive at a decision but it will likely mean that the lawyers (or the judge) may have to spend more time explaining complex technology or legal issues to them.  It may also mean that the legal arguments made in Court would be pitched in a different way if they were being made to a jury rather than the judge.  For example, it may be better to use less ‘legalistic’ submissions and instead use the key arguments in a context which can be more readily understood by the jurors.  Arguably, the focus becomes less on the legal aspects and more on presenting ‘key arguments/themes’ to the jurors. 

An interesting side issue to that is the impact that key jurors can have on the rest of the jury.  This is something which one would not have to consider in cases decided by a judge.  In jury cases, when a juror has experience in the particular field, they are likely to be the one who drives the discussion and influences the thinking of the other jurors.  In the Apple v Samsung case, the foreman of the jury was Velvin Hogan who is Chief Technology Officer at a company called Multicast Labs which specialises in internet video technology.  He also appears to have had some experience of the patent system in the US, having been the named inventor on a patent (see here).  In one of his post-trial interviews, it seems clear that his experience in this field was one of the key factors in helping the jury reach its verdict.  In his interview with the BBC (you can read the full transcript on the BBC website here) he said:

I asked myself the question: could I defend this patent, not in the court, could I defend this patent through that process just like I had to do my own if this were mine? ….. The answer to that question for me was yes. And so it just hit me that evening that that process I needed to explain to my fellow jurors because I was the only one that had ever gone through that process among them.

Some may argue of course that this decision making process is one of the main arguments in favour of allowing juries to decide cases such as Apple v Samsung.  Justice is being carried out by ‘the people’ because it comprises a cross section of society.  They will have different backgrounds and experiences and not everyone (perhaps even no-one) will be an ‘expert in the field’ of the technology in dispute.  Whatever their view, the jurors are bound to apply the law as it has been explained and as they understand it.  If there is one ‘expert’ amongst them then it is only natural that he or she will use their knowledge to have a major influence on the decision that is reached.

The damages calculation
In patent cases in the UK, once a finding of liability has been reached, there will usually be a separate hearing to establish the amount of damages due to the party which has had its intellectual property infringed (although often that is settled out of court). 

Under Scots law, the basic principle is that damages is calculated with a view to putting the party in the position it would have been in, had there been no infringement.  Alternatively, the victorious party can seek an account of the net profits which defender has made as a result of its infringing acts.  The victorious party usually selects whichever of these is likely to be the greater.  It is also important to note that damages in IP cases under UK law are usually not punitive.  Their purpose is not to punish the infringer for its wrongful acts (although there can be exceptions to his for example for flagrant infringement of copyright) but rather to restore the aggrieved party to the position it would have been in, but for the infringement. 

In the Apple case, there was much media criticism of the jury’s ability to reach a decision on liability and the amount of damages and in such a short period of time.  The jury was given an instruction document 109 pages long which contained around 700 individual questions.  Yet, the jury managed to assess all of this and deliver its decision in less than 2 days.  Mr Hogan, in one of his interviews claimed that there were in truth only 33 questions to answer  but that they related to 26 different Samsung devices, and in some cases the devices did not infringe the relevant patents. 

Nevertheless, this is still a remarkable feat given that, at least for the patent infringement claims, numerous items of prior art would first require to be considered to form a view on whether or not the patents were valid.  A judicial decision of this nature would certainly have taken many months to issue. 

Of course the speed of the jury’s verdict is helped greatly by the fact that they do not have to issue a written opinion setting out the reasoning for their decision or how they arrived at the amount of damages.  It would have been interesting in the Apple v Samsung case to see how they arrived at the damages amount of $1.05 billion!

So is one better than the other?
There are advantages and disadvantages to both jury and judicial decisions being issued in cases of IP infringement.  

In Scotland, there are 6 IP specialist judges who deal with the vast majority of the IP cases (the rest being dealt with by ordinary judges).  They have accumulated valuable experience in a wide variety of IP cases and many of them will also have further experience from working on cases whilst they were practising as Advocates/QC’s.  This means that the quality of the decision will most likely be very high.

Whilst I am not aware of any evidence that suggests jury decisions are appealed successfully more often than judicial decisions,  my own view is that there are likely to be less variable factors involved in a judge arriving at a decision.  This means that judicial decisions are likely to be more consistent and a body of case law can be built up and relied on.  Juries are more unpredictable in the sense that they will be made up of different people each time. 

As a lawyer, whether or not this is a benefit will depend what side of the case you are on.  It certainly worked well in Apple’s favour in this instance as the damages award is amongst the highest in American history.

Mark Cruickshank

Design rights reform – two weeks until IPO consultation closes

The IPO‘s consultation on the proposed reform of the legal framework for the protection of designs is due to close a fortnight today (2 October).

The consultation is a further step towards implementing one of the key recommendations of last year’s Hargreaves Review and follows an earlier call for evidence on design rights reform.

The proposals
Currently, designs can be protected by a mish-mash of unregistered design rights (both UK and (European) Community), registered design rights (again, both UK and Community) and, in some cases, copyright. Each lasts for differing periods of time, and covers different applications (for example, 3D objects versus aesthetic designs), and is subject to different, and complicated, rules in relation to creation of the right.

In an attempt to get round the time limited nature of registered design protection, there have even been attempts to use registered trade marks to protect product designs.

The consultation is seeking to make this clearer. In particular, the consultation is seeking views on proposals to:

  • improve the enforcement regime (including whether deliberate copying should be a criminal offence, as it is with copyright and registered trade marks) and enable people to understand more fully what rights are held by others, to help avoid disputes;
  • resolve uncertainties around the scope of protection (including the scope of protection given to unregistered designs, or whether to scrap unregistered designs altogether);
  • clarify what constitutes an infringement (including the possibility of introducing a prior use/good faith defence in relation to registered designs, and exemptions for non-commercial use); and
  • extend the period of potential deferment for publication of registered design right applications from 12 to 18 months, to reduce the risk of the product being copied or imitated prior to launch; and
  • simplify the laws surrounding the ownership of and qualification for design right

Design rights in the public eye
After many years of being considered by many outside industry and legal professions to be a fairly obscure area of intellectual property rights (as opposed to the better known patents, trade marks and copyright), design rights arguably hit the big time earlier this year in the High Court case involving Apple’s iPad and Samsung’s Galaxy Tab.

That case wasn’t about copying technical innovation, but simply about the allegedly distinctive physical shape of the iPad. As my colleagues John and Mark have blogged, that case didn’t end too well for Apple (arguably even the ringing endorsement of Apple’s products by a High Court judge will have done more for Samsung than Apple).

However, the case (along with others involving spare parts for Dyson vaccuum cleaners and replica alloy wheels) has helped bring greater attention to the design rights framework and whether it is effective in its current form in encouraging innovation.

How to respond to the consultation
What do you think? Does the current regime work for your business? You can provide your views to the IPO by following this link. If you’d like to discuss how the IPO’s proposals might impact upon your busienss, please get in touch.

Remember, the consultation closes on Tuesday 2 October 2012.

If you want to find out more about how to protect your designs, or other types of intellectual property rights, then download our free guide to protecting your intellectual property.

IPR infringement and mobile apps – why Apple provides an online reporting tool

Last week’s iOS Dev Weekly email contained an item on the online facility provided by Apple to allow you to report alleged IPR infringement issues with apps on the App Store:

…If you are having copyright or trademark issues [or in fact any other IPR] with your app Apple now have a dedicated App Store process for dealing with this. What I found interesting about the description of this is that it states that it will put you directly in contact with the provider of the disputed app. Surprising.

From Apple’s perspective, this actually makes a lot of sense. Here’s why.

Pretty much anyone can publish an app for distribution by Apple through the App Store. However, whilst Apple does do some quality control on apps that are submitted, it doesn’t have the resources (or time) to carry out an indepth analysis of whether the submitted app infringes any third party IPR. It simply isn’t cost effective for Apple to do so, given the global nature of the App Store – researching whether a particular app infringed third party copyright, patents or trade marks in various countries around the world would cost many, many, thousands of dollars.

This means that there is a very real risk that apps available for sale on the App Store might infringe a third party’s IPR – whether through deliberate infringement, unintended copying, being unaware of a pre-existing patent (whether in the same territory or abroad) or simply the sale of an app by, say, a British registered trade mark holder in a country where the trade mark in question is already owned by someone else.

The dispute process
When an IPR infringement claim does come to light, for the reasons given above it is not practical for Apple to investigate it. It just isn’t worth its while as there’s no financial benefit to Apple from doing so, and Apple is unlikely to have the information required to respond to the complaint. So, instead, it makes much more sense for Apple to provide a facility for complainers to submit a claim straight to the person or organisation that submitted the allegedly infringing app so that the two parties can sort out the dispute directly.

In the meantime, in my experience Apple will suspend (or threaten to suspend) the allegedly infringing app. This keeps Apple in the clear in terms of any alleged infringement by Apple (remember, Apple is simply an agent (or Commissionaire) – it doesn’t licence/sublicence non-Apple apps to end users) and its obligations under the DMCA, as it has taken action as soon as it became aware of the issue, and puts the onus on the recipient of the infringement claim to sort it out so that it can get its app back on the market.

Of course this approach isn’t without its problems – particularly for those on the receiving end of an infringement claim, as the online reporting tool is open to vexatious and frivolous claims, with the onus on the recipient to then demonstrate to Apple that there isn’t an issue. But for aggrieved rights holders it provides an effective way of raising IPR infringement issues directly with the alleged infringer.

Be prepared
It also emphasises the importance of thinking about your IPR before you launch your app.

Are you comfortable that your chosen brand won’t infringe that of a third party? Have you thought about who owns IPR in foreign jurisdictions before you launch an app globally? Are you sure that any third party code utilised in your app is properly licensed? Have your developers assigned across ownership of any code they create? Have you taken steps to register any regiserable IPR that you create?

To learn more about protecting your IPR, download our free guide.

PS It’s not just Apple. A quick check reveals similar facilities on Google Play for copyright infringement and trade mark infringment (although on the latter it appears that Google will actually carry out some investigation itself).

ICO imposes £250,000 fine following failure to adequately supervise service provider

The Information Commissioner (ICO) yesterday imposed his second highest fine to date, and highest outside the NHS, on a Scottish local authority following inadequacies in relation to an outsourcing contract.

Background
This case involved a local authority which outsourced the scanning of pension records to a third party, as part of a long term scanning project. The arrangement commenced in 2005, and involved the scanning of thousands of files. However, no written contract was in place between the local authority and the supplier, and it appears no supervision or monitoring of the supplier’s information security arrangements was ever carried out.

The problems came to light in September last year, when a member of public noticed that a paper recycling bank was overfilled with discarded files. Fortunately, the individual in question reported the find to the police, who in turn secured the site and alerted the local authority. Upon investigation, it turned out that almost 900 files had been disposed of by the supplier at recycling banks that day alone. Prior to the breach coming to light, the supplier a further 8,000 files having previously been disposed of by the supplier.

The records in question contained a large amount of personal data, including national insurance numbers, salary and bank account details. Some files also contained information on ill health benefits.

Data protection and outsourcing
When organisations think of outsourcing, they will usually think of high value projects involving IT or the outsourcing of entire business processes.

This case highlights that the same rules on data security apply to the performance of more routine, low value, tasks contracted out to third parties. The fact that this particular local authority had no written contract in place with the supplier, never mind robust provisions dealing with data security suggests that this appointment was likely an adhoc arrangement that did not go through the formal governance procedures.

It is also clear that supervision of the supplier’s activities fell through the cracks. Nevertheless, the local authority remains responsible under the DPA for ensuring that the data in question is adequately protected.

The case also serves as a reminder of the importance of exercising contactual rights of audit and oversight. It is not simply enough to include a data protection clause in a contract. The ICO expects data controllers to be able to demonstrate that they have carried out appropriate diligence on the adequacy of security measures put in place by their suppliers, and to continually monitor the supplier to ensure that the measures are being complied with and remain fit for purpose.

Justiciation for the penalty
As I have noted previously, when considering what security measures are appropriate, the ICO expects data controllers to take into account the sensitivity of the information involved, and likely distress that may arise from loss or unauthorised access.

In imposing such a high monetary penalty in this case, the ICO noted that serious contraventions had occurred, with breaches by the local authority of a number of other obligations under the Data Protection Act (DPA). These included failures to:

  • choose a supplier that provided sufficient guarantees in relation to information security measures;
  • take reasonable steps to ensure compliance with those measures; and
  • have in place a written contract with the supplier which obliged the supplier to act only on the local authority’s instructions and to comply with obligatisons equivalent to those imposed under the seventh data protection principle (which requires that appropriate measures are taken against unauthorised or unlawful processing of personal daya ana against acceidental loss or destruction of, or damahge to personal data).

ICO guidance
The ICO provides some guidance for organisations intending to outsource a service (or reviewing their existing contracts with service providers:

  • Always select a reputable organisation to work with;
  • Make sure the organisation has appropriate data security measures in place, including how it disposes of data
  • And make sure the organisation has appropriate security checks on staff too
  • Put a clear, enforceable contract in place
  • Make sure that contract requires the contractor to report any security breaches or other problems to you, and have procedures in place on how you will act if problems are reported
  • If you are going to transfer personal data outside of the European Economic Area, make sure you’re doing so in line with Data Protection Act 1998

For small to medium sized organisations, more detailed guidance is available on the ICO’s website.

The importance of reviewing your supply arrangements
Since the monetary penalty regime came into force, many organisations have focussed on their internal information security arrangements and staff training.

As the latest ICO fine makes clear, however, now is the time to:

  • review your supply arrangements to ensure that appropriate contracts are in place with suppliers (having regard to the activities of that supplier), that your suppliers are complying with their contractual obligations; and
  • separately review your policies on procurement, information security and the management of suppliers.

The cost of carrying out such a review is likely to be low compared to the potential fines that could be imposed by the ICO (and the reputational damage that follows) if any of those contracts are found to be deficient.

Brodies can help you to carry out such an exercise by working with your internal compliance and procurement teams to review the terms of your supplier contracts and your internal policies. To discuss this further, please contact me or your usual Brodies contact.

e-Update on ICT projects in the public sector: avoiding delays, cost overruns and service failures

Following my blog about the recent Audit Scotland report into ICT projects in the Scottish public sector, we have this morning issued an e-update to clients and contacts summarising the key issues and recommendations.

The e-update also emphasises the importance of early stage legal input to ensure that the procurement runs to track and initial procurement documentation doesn’t cause problems further down the line (to continue the train analogy).

You can read the e-update by following this link.

If you would like to sign-up to receive future e-updates, please follow this link to register. If you’d like to discuss any of the issues covered in the update please get in touch.

iHard: Bruce Willis and ownership of downloaded content

It seems that last week’s widely-repeated story that Bruce Willis was preparing to sue Apple for ownership of songs downloaded from iTunes was unverified and probably untrue.

Journalists can be forgiven for hedging their bets however, as resale of digital assets a complex subject. In fact, you could say it is pretty “iHard” to understand.

A licence to use
When you buy a music download you are actually paying for a contractual right – a licence – to permit you to do something with that copyright work that would otherwise be contrary to the author’s copyright. (For further discussion of the bundle of rights which protect songs, read this Tech Blog from last September.) 

The licence will set out what you can do with the copyright work, e.g. listen to it in private, burn it to CD/download it to other devices up to a set number of times etc. If what you are doing is not expressly permitted under the licence then you are probably infringing copyright.

In this respect the rights obtained by a purchaser of a music download from iTunes are no different to the rights acquired by a purchaser of a CD from a high street store. If you buy a CD you own the physical CD, but you don’t own the songs on it.

The practical differences are that:

  1. the licensed products are embodied in a physical CD, permitting easy transfer; and
  2. the first-sale doctrine applies to CDs.

The first-sale doctrine provides that once copyright products embodied in a physical object are introduced in the market in a given territory, the right holder loses control of them, and they can be freely resold, lent, or given away by the purchaser. In other words, the purchaser of a CD containing songs has the right to resell, lend or give away their copy of the songs (although not copies of their copy – which is an important distinction.)

The first-sale doctrine
There are various historical justifications for the first-sale doctrine (market failure; the free movement of goods; the impossibility of controlling the uses of a purchased copyright work; enhancing the circulation of culture), and a very similar concept called “exhaustion of rights” exists in the EU.

The catch is that the World Intellectual Property Organization Copyright Treaty (the international treaty on copyright law adopted by the member states of the World Intellectual Property Organization, including the US and, through the Council of the European Union, the EU) limits application of the first-sale doctrine to “fixed copies that can be put into circulation as tangible objects- not intangible content distributed over the internet”.

This means that if the licence for a digital copyright work prevents making copies of it, or prevents transfer of the licence, then reselling, lending or giving away that work is forbidden. (The degrees to which major players such as Amazon and Apple explicitly forbid such transfer is a matter of licence interpretation, and tends to be debated amongst lawyers and academics.)

Posited potential “workarounds”, particularly in the case of death of the owner, include: creating a legal trust (though this seems far-fetched – you can’t change a licence through a trust); burning your media onto a device and bequeathing that device in your will; or writing down the password. As noted above, the legality of these methods will depend on interpretation of particular licence terms.

The distinction between physical and digital content appears increasingly untenable
The European Court of Justice recently ruled that, in relation to a computer program, the rights of the copyright owner Oracle in relation to a copy of is software had been exhausted – even though the software had been downloaded from the internet. 

The judgment addressed the distinction between tangible or intangible forms of the computer program, concluding (via a rather circuitous route that deeemed the Computer Program Directive to be a lex specialis of the Copyright Directive):

it must be considered that the exhaustion of the distribution right under [the Computer Program Directive] concerns both tangible and intangible copies of a computer program”

In theory therefore, although the judgment’s treatment of the tangible/intangible issue is far from the most robust reasoning you will ever read, this suggests that in certain circumstances exhaustion of rights in “used” digital content may be possible.  (If resale of software is an issue of particular interest to you, please read my colleague Martin Sloan’s in-depth summary of the judgement and his key points.)

Similarly, there is forthcoming litigation in the US regarding the legality of reselling of “used” digital songs. Capitol Records is suing ReDigi, a Massachusetts start-up which runs an online marketplace where individulas can resell music files. The legality of ReDigi’s business model will probably turn on whether it is making a copy of the song when it moves the “used” files it to its cloud servers. Capitol has insisted in its filing that copies are being made, claiming: 

While ReDigi touts its service as the equivalent of a used record store, that analogy is inapplicable: used record stores do not make copies to fill up their shelves”

As discussed above, making copies of copies isn’t protected by the first-sale doctrine, so ReDigi will have to prove that only a single copy of a song is being used throughout its entire sales process (as well as finding its own way around the tangible/intangible goods issue).

Hudson Hawk
In the meantime, I appreciate you may have been lured to this blog post on the promise of Bruce Willis, and been subjected to law instead.  So, in a wonderful scene from the unfairly maligned Hudson Hawk, let’s round things off by enjoying Swinging on a Star.

A deep fried Mars a day…… TechBlogger quoted in BBC News story

Scotland is famous for many culinary delights, including haggis, Irn Bru and of course the deep fried Mars bar. 

According to press reports a few months ago, the Carron Fish Bar in Stonehaven (which claims to have created the latter deep fried delicacy) was considering applying for Protected Geoographical Indication status (on which my colleague John McGonagle has blogged previously). 

The deep fried Mars bar story has caused quite a stir in the media, following news earlier this week that Mars, manufacturer of the Mars bar (and owner of various trade marks, including “Mars” and “Mars bar”) had written to the owners of the Carron to ask them to post a disclaimer on their menu, distancing the confectionary company from any endorsement of the a snack not in-keeping with Mars’ “commitment to promoting healthy, active lifestyles”.

The story raises a number of interesting intellectual property law issues, and I appeared on BBC Radio Scotland’s Newsdrive Programme on Wednesday 5 September 2012 to discuss these.

To find out more, you can listen to the broadcast here (it starts at 21.30 minutes). My comments were also picked up and quoted in a BBC News online article here.

The story is a good lesson in the importance of understanding what intellectual property a business owns or uses. In this case, the Carron has got some good publicity out of the PGI application, but has also now attracted the attention of Mars’ lawyers.

To find out more about intellectual property rights, download our free guide to protecting your IP, or come along to our forthcoming seminars, where we’ll be discussing what businesses can do to maximise the value of and return from their investment in IP.

Mark Cruickshank

Commission plans shakeup of key State Aid laws in relation to R&D funding

The European Commission is undertaking a review of the current state aid framework which is due to expire at the end of 2013. 

As part of that review, the Commission has recently launched a public consultation into the current General Block Exemption Regulation (“GBER”) which exempts certain categories of state aid, such as support for SMEs and funding for R&D projects, from the normal requirement of notifying state aid measures to the Commission. 

In addition to the current GBER consultation, separate reviews have been conducted for specific types of aid such as research, development and innovation (“R&D&I”), the questionnaire for which was published at the end of 2011 with the deadline for submissions in early 2012.  The Commission has identified R&D&I policy as an essential component of its strategy for growth and jobs. 

The mid-term review of the R&D&I framework, published prior to the questionnaire, indicated that there is a clear need to improve the conditions for private R&D in the EU.  It was reported that at that time the R&D spending in Europe was below 2%, compared to 2.6% in the US and 3.4% in Japan, mainly as a result of lower levels of private investment.  The questionnaire asked public authorities whether there were particular factors preventing them from granting a larger proportion of R&D&I aid through block exempted measures and whether the current level of notification thresholds for R&D&I measures were appropriate.

The proposed reforms are important because GBER has been responsible for cutting the administrative burden both on the Commission and on national public authorities who would otherwise have been obliged to notify their state aid plans to Brussels. 

The review is therefore a significant one for both public authorities and organisations seeking to benefit (or who currently benefit) from financial assistance in relation to R&D.  If your organisation benefits under the current scheme (or your R&D activities are hindered by the current rules), then you may wish to contribute to the consultation and explain how the Commission can better support R&D and innnovation in your sector. 

The consultation responses will form a key part of the Commission’s proposals for a revised Regulation which is due for publication next year. The Commission is seeking responses to the current consultation by 12 September 2012 at the latest.  If you are considering responding to the consultation and need assistance please do not hesitate to get in touch.

Laura is a blogger on Brodies PublicLaw Blog, specialising in state aid and competition law.


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