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IP/IT & MEDIA
IN THIS ISSUE:New case law by the European Court of Justice regarding reputation in 1
the Community and exhaustion of trademark rights
European Court of Justice: Prohibition of linking raffles with product purchase 2 in German Act Against Unfair Competition violates European Community law
Federal Court of Justice again decides on the permissibility of advertisement 2 with price reduction
Federal Court of Justice: GEMA not competent to grant licenses for use of music 3 in advertising
‘Appropriate Remuneration’ for translators under German copyright law 3 - Federal Court of Justice decides in favor of translators
Federal Court of Justice: Transcripts of a radio contribution may be kept 4 available online even if they expressly state the names of convicted persons
Patent litigation: Procedural changes in Munich 5
News from the Practice Groups 6
NEWSLETTER – JANUARY 2010
IP/IT & MEDIa - JaNUaRY 2010 1
NEw caSE law bY THE EURoPEaN coURT of JUSTIcE REgaRDINg REPUTaTIoN IN THE coMMUNITY aND ExHaUSTIoN of TRaDEMaRk RIgHTSDR. alExaNDER R. klETT
In a decision of October 6, 2009 (file no. C-301/07), the European Court
of Justice had to decide on the interpretation of Article 9 (1) c of the
Community Trademark Regulation. This provision extends the scope
of protection of Community trademarks having a reputation in the
Community. The owner of such a Community trademark with reputation
can prevent the use of identical or similar marks even for goods or
services that are not similar to those for which the Community trademark
is registered, if such use takes unfair advantage of or is detrimental to the
distinctive character or the repute of the Community trademark.
The case to be decided by the European Court of Justice was a reference
from the Austrian Supreme Court in litigation between Pago and Tirol
Milch. Pago owns the following figurative Community trademark,
protected, among others, for fruit drinks and fruit juices:
Tirol Milch marketed a drink, among others in bottles, some of which are
similar to the one shown in the mark by Pago.
The Pago mark has a reputation only in Austria. The Austrian Supreme
Court therefore asked the European Court of Justice whether a
Community trademark that has a reputation only in Austria qualifies as a
Community trademark with a reputation in the Community for purposes of
Article 9 (1) c of the Community trademark regulation.
The European Court of Justice answered in the affirmative. In earlier case
law the court had decided that for purposes of the EU Trademark Directive
it was sufficient for a domestic Benelux trademark to have a reputation
in a substantial part of the Benelux territory—which may be a part of
one of the Benelux countries only. In the recent case the court took the
view that in order for a Community trademark to have a reputation in the
Community, it is sufficient if it is known by a significant part of the public in
a substantial part of the territory of the European Community, and that the
territory of Austria may be considered to constitute a substantial part of
the territory of the Community for these purposes.
This is good news for owners of Community trademarks making heavy
use of their marks in one or few member states only, and who still want to
benefit from the extended scope of protection afforded by Article 9 (1) c in
all 27 member states of the Community.
In another recent decision dated October 15, 2009 (file no. C-324/08),
the European Court of Justice had to decide on a referral by the Dutch
Supreme Court concerning the interpretation of Article 7 (1) of EU
Trademark Directive 89/104/EEC. In the case pending in the Netherlands,
Diesel sued Makro and other parties for selling certain products in the
Netherlands carrying the Diesel mark. Diesel had previously granted a
license for certain Diesel products for Spain, Portugal, and Andorra. The
licensee had granted an exclusive sublicense with respect to certain
goods, whereupon the sublicensee had granted a further license to another
entity concerning the manufacture of footwear, bags and belts with the
Diesel mark. The sale of these goods was not covered by any express
consent or agreement either by Diesel or its licensee. Some of these goods
were ultimately sold in the Netherlands by Makro. Makro tried to defend
itself by claiming that with respect to these goods, the trademark rights
of Diesel had been exhausted, which is why Diesel could not enjoin Makro
from selling the goods within the European Economic Area.
In this context, the Dutch Court asked the European Court of Justice
about the criteria to be applied in determining whether a sale of goods not
covered by the express consent of the trademark owner may nevertheless
have taken place with the implied consent of the owner under Article 7 (1)
of the EU Trademark Directive. The ECJ took the view that a consent of the
trademark owner with respect to marketing goods bearing the mark within
the European Economic Area by a third party may be implied if this can
be inferred from facts and circumstances prior to, simultaneous with, or
subsequent to the placing of the goods on the market within the EEA that,
as determined by the national court, would clearly show that the trademark
owner has renounced his exclusive rights.
While it is still uncertain how the case will ultimately be decided by the
Dutch Supreme Court, this case indicates the danger to trademark owners
stemming from complex multi-level distribution arrangements if the scope of
the rights of each licensee/distributor is not sufficiently specified and spelled
out in the agreement. The lesson to be learned from this case for trademark
owners, therefore, is to make absolutely sure in their license agreements
what the exact scope of rights granted to the licensee, and the possible
scope of sublicenses to be granted by the licensee, is. A lack of diligence
in this respect may ultimately lead to a de facto partial loss of enforcement
rights to the trademark owner contrary to his original intention.
IP/IT & MEDIa - JaNUaRY 2010 2
EURoPEaN coURT of JUSTIcE: PRoHIbITIoN of lINkINg RafflES wITH PRoDUcT PURcHaSE IN gERMaN acT agaINST UNfaIR coMPETITIoN vIolaTES EURoPEaN coMMUNITY lawDR. alExaNDER R. klETT / kaTHaRINa a. wEIMER
The European Court of Justice (ECJ) decided on January 14, 2010 (file
no. C-304/08) that Directive 2005/29/EC concerning unfair commercial
practices makes domestic legislation impossible according to which
business practices linking participation of consumers in a raffle to
the purchase of goods or the use of services are declared to be unfair
competition.
This decision resulted from a reference by the German Federal Court of
Justice. The German Court will have to decide on the following matter:
The supermarket chain Plus gave its customers “points” when purchasing
goods. The number of points depended on the value of the goods
purchased. From a certain number of points a customer could participate
for free in drawings of the German state-run lottery on two different
days. A German consumer protection association took action against this
because it took the view that this practice violated the provision in Sec.
4 no. 6 of the German Act Against Unfair Competition. According to this
provision, it is illegal to link participation of consumers in a raffle to the
purchase of goods or the use of services, unless the raffle by its nature is
connected to the product or service.
This provision, according to the ECJ, violates European Community
law. The rules regarding business practices vis-à-vis consumers were
completely harmonized by Directive 2005/29/EC. Under Art. 4 of the
Directive, the member states may not limit the free movement of services
and the free movement of goods for reasons relating to the areas
harmonized by the Directive. This means that member states may not
provide stricter rules regarding the relationship between companies and
consumers than does the Directive. The Directive, however, contains a
final and complete list of all practices which under any circumstances
are to be regarded as unfair without requiring an individual analysis (Art.
5 of the Directive in connection with Annex I). The prohibition on linking
participation in the raffle to the purchase of goods or the use of services
under Sec. 4 no. 6 German Act Against Unfair Competition is not mentioned
in the Directive.
Consequently, according to the ECJ, the Directive is violated by this
provision. According to the court, this analysis does not change just
because Sec. 4 no. 6 German Act Against Unfair Competition provides for
an exception for raffles which are inevitably linked to goods or services
because this wording cannot replace the necessary analysis in the
individual case as it constitutes a limited predefined exception.
This decision by the ECJ is a blow to German unfair competition law as
applied for decades. The prohibition of linking raffles to purchases is one
of the pillars of German unfair competition law and will now have to be
considered to go against European Community law. At the very least, Sec.
4 no. 6 German Act Against Unfair Competition will in the future have to
be interpreted in such a way that an individual analysis of whether unfair
competition can be found will have to be undertaken contrary to the
wording of the provision. The German Federal Court of Justice will have
to take this into account in deciding the matter. Even if the decision by
the ECJ will offer new possibilities to businesses to promote sales with
the help of raffles or draws because this linking will now be possible, the
terms and conditions of such raffles will still be scrutinized under general
provisions of unfair competition law. The German Federal Court of Justice
will now have the opportunity to define the criteria for a permitted linking.
fEDERal coURT of JUSTIcE agaIN DEcIDES oN THE PERMISSIbIlITY of aDvERTISEMENT wITH PRIcE REDUcTIoNkaTHaRINa a. wEIMER
In its judgment dating from December 10, 2009 (file no. I ZR 195/07 –
the complete judgment is not available yet), the I. Civil Court of the
German Federal Court of Justice, inter alia responsible for actions in
unfair competition, decided that advertisement with a price deduction of
19 percent constitutes unfair competition if it is not clear and unequivocal
from the advertisement itself that such price deduction will only be granted
on goods in stock in the shop.
Plaintiff and defendant are competitors in the area of trade with photo and
video cameras and respective accessories. In its brochure the defendant
advertised: “Only today, January 3, photo and video cameras without
19 percent VAT*” (“Nur heute 3. Januar Foto- und Videokameras ohne 19%
Mehrwertsteuer*”). The footnote with asterisk contained the following:
“Save a full 19 percent on the retail price” (“Sparen Sie volle 19% auf den
Verkaufspreis”). Two employees of the plaintiff visited the defendant’s
premises January 3 and received a 19 percent discount on the retail price
upon purchase of a camera. When asked whether this camera could also
be ordered, a sales representative of the defendant confirmed this but
informed the two employees that the price deduction will only be granted
on cameras in stock in the shop January 3.
The plaintiff sued the defendant for injunctive relief, determination of
obligation to pay damages, and information, and prevailed on all counts in
the lower instances. The Federal Court of Justice is of the same opinion
and dismissed the defendant’s appeal. The advertised price deduction
constitutes a sales promotion and, as such, must clearly and unequivocally
identify the conditions for its applicability already in the advertisement. The
defendant’s advertisement does not satisfy these criteria. The consumer
must be able to inform himself in advance on the conditions that the
IP/IT & MEDIa - JaNUaRY 2010 3
advertising company has set forth for claiming the price deduction in
order to be able to make an informed purchase decision. The fact that
an announced price deduction cannot be granted on goods that can be
ordered but are not (any longer) available in the shop forms part of such
decisive criteria. Such a restriction must be announced in the relevant
advertisement already in order to satisfy the transparency requirements
stipulated by the law.
The decision of the Federal Court of Justice clearly shows that companies
need to continue to apply due consideration to the design and creation of
advertising, and need to take into account that seemingly minor details
need to be mentioned to satisfy the obligation of transparency.
fEDERal coURT of JUSTIcE: gEMa NoT coMPETENT To gRaNT lIcENSES foR USE of MUSIc IN aDvERTISINgDR. alExaNDER R. klETT / kaTHaRINa a. wEIMER
The German Federal Court of Justice decided in a decision of June 10,
2009 (file no. I ZR 226/06, published with full opinion only November 30,
2009), that the German collecting society for musical rights, GEMA, is
currently not competent to license rights of its members regarding the use
of musical works in advertising.
In the case to be decided, an advertising agency wanted to use
commercials with background music for its own marketing purposes on
its Internet website. GEMA had asked for payment of license fees for this
use. The advertising agency refused to make payment and brought a
declaratory action claiming that GEMA did not have the right to request
information and/or payment of royalties from the advertising agency for the
use of musical works as part of commercials made for the customers, nor
for the use of the commercials for marketing purposes on the website of
the advertising agency. The Federal Court of Justice had to decide whether
such use for marketing purposes is covered by the exploitation rights
granted to GEMA and therefore subject to royalty payments to GEMA.
The Federal Court of Justice took the view that this is not the case, and
argued that the current version of the license agreement by which the
right-holders grant certain rights of use and exploitation to GEMA does
not include rights of the GEMA members concerning the use of their music
for advertising purposes. With the license agreements, the right-holders
grant GEMA various rights for administration that are spelled out in the
license agreement, not including, however, the right to use musical works
for advertising purposes. This right has neither been expressly granted to
GEMA, nor does it have to be regarded as included in the contractual aim
defined by both parties because, according to the Federal Court of Justice,
copyright owners are perfectly able to administer the right of use of their
works for advertising purposes themselves. In the case of use of works for
advertising purposes, the possibility to negotiate license fees individually
is in the best interest of right-holders, according to the court, which is why
subjecting such use to tariffs or distribution models of GEMA would be
contrary to such interest.
This decision came as a surprise both to GEMA and the music industry. It
does not fit with the idea of using GEMA as a “one stop shop” for obtaining
rights to use of music from GEMA members. Advertisers who would
like to use music of GEMA members are currently forced to contact the
right-holders directly, which can lead to practical difficulties and make
clearance of rights significantly more complicated. GEMA intends to get in
touch with its members in order to obtain subsequent approvals for grants
of rights made in the past, and to find a practical solution for the future
by amending the license agreement with its members to include uses in
advertising.
‘aPPRoPRIaTE REMUNERaTIoN’ foR TRaNSlaToRS UNDER gERMaN coPYRIgHT law – gERMaN fEDERal coURT of JUSTIcE DEcIDES IN favoR of TRaNSlaToRSDR. alExaNDER R. klETT
In five parallel matters decided by the German Federal Court of Justice
October 7, 2009 and published by the court recently (case nos. I ZR 38/07,
I ZR 39/07, I ZR 40/07, I ZR 41/07 and I ZR 230/06), the court further
interpreted the provisions on appropriate remuneration for licensors in
German copyright law. Since the German Copyright Act was amended in
2002, authors and creators have a legal right to appropriate and adequate
remuneration under Sec. 32 German Copyright Act. If a license fee agreed
to contractually is not found to be adequate, the author or creator can
request the consent by the licensee to amend the license agreement in
order to increase the agreed-to license fee.
While this provision may seem surprising, the legislative idea behind it
was to grant sufficient protection to authors and creators who may be
in a negotiating position that may not be sufficiently strong to be able to
obtain reasonable and adequate payment for their work. This situation,
in the opinion of the legislator, existed particularly with respect to literary
translators. It is quite fitting in a way, therefore, that the recently decided
cases all dealt with literary translators.
In the leading case among the five decided, a translator had prepared literary
translations of two novels from English into German and been paid the
contractually agreed-to fee of approximately €15 per page. She found this to
be insufficient and requested that the agreement be amended appropriately.
Interestingly, the Federal Court of Justice found that the payment of €15
per page was common in the industry at the time the agreement was
concluded. At the same time, however, the court found that such a payment
was inadequate because it did not reflect the reasonable interest of the
translator to share in all forms of economic exploitation of the translation.
IP/IT & MEDIa - JaNUaRY 2010 4
The Federal Court of Justice took the view that in order for license fees of
literary translators to be reasonable, flat fee arrangements will usually not be
sufficient if the rights granted are unlimited in time and scope. In addition,
according to the court, it will be necessary, from a certain number of copies
sold, to have the translator share in the revenue generated. The court
decided that this had to be the case above 5,000 copies of the translated
work sold. The share owed to the translator should then be 8 percent for
hard cover editions and 4 percent for paperback issues (relating to the net
retail price of the book). Additionally, according to the court, the translator
is entitled to 50 percent of the net revenue generated by the publisher by
granting third parties the right to use the translated work (relating to the
value of the translation as part of the grant).
While the Federal Court of Justice took the view that the Court of Appeals
had not finally determined whether the facts in this particular case
warranted a deviation from the general framework set by the Federal Court
of Justice, and the case has thus been remanded, the general framework
set by the Federal Court of Justice will nevertheless now have to be taken
into account in drafting license agreements under German copyright
law in the future. This applies, in particular, to publishers working with
translators. It will not apply to publishers and translators only, however.
The respective provisions in the German Copyright Act are not limited to
them. It can be taken from this recent case law by the German Federal
Court of Justice that in all cases in which license agreements relate to
long-term exploitation of works, the license fees should be structured in
such a way that a proportionate share in the revenues generated by the
author or creator is ensured. While the percentage amount set by the
Federal Court of Justice in the recent case law will not apply uniformly
to all forms of exploitation of all kinds of works, the general structure
will have to be reflected. It is therefore not advisable to continue to use
template license agreements without any proportionate share in revenue
for the licensor (author/creator) if they are to cover long-term exploitations
of certain works.
fEDERal coURT of JUSTIcE: TRaNScRIPTS of a RaDIo coNTRIbUTIoN MaY bE kEPT avaIlablE oNlINE EvEN If THEY ExPRESSlY STaTE THE NaMES of coNvIcTED PERSoNSkaTHaRINa a. wEIMER
On December 14, 2009, the German Federal Court of Justice decided (file
nos. VI ZR 227/08 and VI ZR 228/08 – the complete judgments are not
available yet) that the defendant Deutschlandradio (a German radio station)
is permitted to make non-current transcripts of broadcast contributions
that explicitly identify the names of the convicted murderers of the famous
German actor Walter Sedlmayr available in its online archive. The plaintiffs
cannot demand from the defendant Deutschlandradio to refrain from
maintaining the respective transcripts on the part of its homepage
www.dradio.de that is dedicated to archived news.
In 1993, the plaintiffs received a life sentence for murder of the actor
Walter Sedlmayr. They were released on parole in summer 2007 and
January 2008 respectively. In the category “Kalenderblatt” (calendar
sheet) of its online presence, the defendant had kept a transcript of a
contribution with the title “Walter Sedlmayr murdered 10 years ago”
(“Vor 10 Jahren Walter Sedlmayr ermordet”), dating from July 14, 2000
until at least sometime into the year 2007. This contribution truthfully
discloses the full names of the plaintiffs as convicted in the murder case
of Walter Sedlmayr.
The plaintiffs succeeded with their demands before the lower courts.
However, upon appeal by the defendant, the VI. Civil Court of the Federal
Court of Justice, responsible for the protection of personal rights, overruled
the decisions of the lower instances and dismissed the claims. In its
decision, the Federal Court weighed the personal rights of the plaintiffs
and their interest in social reintegration against the public’s interest in
information, and the freedom of opinion and of the press of the defendant.
The Federal Court decided that making the contribution containing the
plaintiffs’ full names available does indeed constitute an intrusion into
the plaintiffs’ personal rights. However, in this case the intrusion is not
unlawful because the plaintiffs’ interests, including their interest in a
successful reintegration after release on parole, has to give way to the
public’s interest in obtaining information, served by the defendant, as well
as the defendant’s freedom of opinion. According to the Federal Court,
the objected contribution is not capable of pillorying the plaintiffs or
showcasing them in a fashion that would (again) stigmatize the plaintiffs
as convicted criminals. In evaluating the facts, the Federal Court of Justice
took into consideration that the contribution contained matter-of-factly
worded and true statements regarding a capital crime against a famous
person that had caused considerable excitement in the public. The fact
that the plaintiffs had continued to seek a repeal of their conviction until far
after the year 2000 was also of importance for the legitimacy of making
the contribution available in 2000. This evaluation did not change after the
plaintiffs’ release on parole because the contribution has a limited impact
on the public because of its rather hidden location on the defendant’s
homepage, and because the public’s interest lies not only in current affairs
but also in the possibility to research events that occurred in the past. The
Federal Court explicitly mentioned the risk that the desired prohibition may
result in a deterring effect on the use of the freedom of opinion and of the
press, thereby restricting the free information and communication process:
the defendant might exclude such facts that may cause the contribution
to become illegal later on from the contribution, or it might refrain from
archiving its contributions entirely.
The decision by the Federal Court of Justice clearly shows that the public’s
interest in information in past events, and the freedom of opinion and
freedom of press of media companies, takes up a high rank and may
indeed outweigh the personal rights and interests in reintegration of the
individual.
IP/IT & MEDIa - JaNUaRY 2010 5
PaTENT lITIgaTIoN: PRocEDURal cHaNgES IN MUNIcHDR. RIcHaRD ScHlöTTER
In order to increase the attractiveness of Munich as a venue for patent
infringement cases, the Patent Chambers of the Munich District Court
recently launched a number of procedural changes. Among others, the
changes include the introduction of an early first hearing, in which the court
will give the parties a preliminary assessment of the case so that plaintiff and
defendant each receive indications for the main hearing. At the same time, in
the early first hearing, the other deadlines for submitting briefs as well as the
date for the main hearing are agreed. It is the intention of the Munich District
Court that these deadlines should be obligatory; the option of an extension
of a deadline should be exercised restrictively. Furthermore, not previously
agreed-upon additional briefs will be restricted by enforcing civil procedural
delay rules or, if necessary, by postponing the main hearing.
The introduced procedural changes should significantly expedite patent
litigation cases before the Munich District Court. The court expects a total
time frame of about six to ten months, starting from filing of the lawsuit.
The presented procedural changes appear promising. Particularly welcome is
the approach of the district court to use the early first hearing as a possibility
for determining the venue for the parties, so that the factually relevant
questions from the point of view of the court can be prepared adequately for
the main hearing. This prevents being confronted with negative surprises
during the main hearing. In conjunction with the considered streamlining of
the proceeding by the district court, this should make Munich as a venue for
patent infringement proceedings clearly more attractive.
IP/IT & MEDIa - JaNUaRY 2010 6
NEwS fRoM THE PRacTIcE gRoUPS
UPcoMINg SEMINaRS
On January 27/28, 2010, Dr. alexander R. klett will be holding a seminar
on “Legally Compliant Marketing”(Rechtssicheres Marketing) at Schloss
Montabaur at the Akademie Deutscher Genossenschaften.
Dr. Richard Schlötter will be hosting the Management Circle Seminar
“IP Rights in Insolvency Situations” (Gewerbliche Schutzrechte in der
Insolvenz) April 28 in Frankfurt, May 18 in Cologne, and June 24 in Munich.
Dr. Schlötter, Dr. alexander R. klett, and three other authorities will be
lecturing on how insolvency proceedings are executed in Germany, how
IP rights are dealt with in insolvency situations, to what extent license
agreements can be transferred, how patents are valuated, and how IP
rights can be insured.
If you would like more information, please contact Anja Oberschmidt
(aoberschmidt@reedsmith.com).
REcENT PRESENTaTIoNS & SEMINaRS
On October 26, 2009, Dr. Richard Schlötter, together with four
other speakers, held the client seminar “IP Rights in Insolvency Situations”
(Gewerbliche Schutzrechte in der Insolvenz) at the Reed Smith
Munich office.
PUblIcaTIoNS
Dr. alexander R. klett published an article in the INTA Bulletin on the
subject, “When is the Use of ® Misleading? German Federal Supreme
Court Sheds New Light” (INTA Bulletin Nov. 15, 2009, Vol. 64, No. 21, p. 9).
Dr. alexander R. klett and frederike flechsig published an article in
the German law review GRUR International entitled, “Neighboring rights in
Europe within the limits of the internal market – on the term of protection
of the rights of record companies in light of Directive 2006/116/EC”
(Europäischer Leistungsschutz in den Grenzen des Binnenmarktes - zur
Schutzdauer der Rechte des Tonträgerherstellers im Lichte der Richtlinie
2006/116/EG, GRUR Int. 11/2009, p. 895).
katharina a. weimer co-authored the article “Upcoming Changes to the
German Federal Data Protection Act,” published in the International Privacy
Guide by West (Thomson Reuters) in November 2009.
katharina a. weimer authored the article “The German Federal Data
Protection Act and its recent changes,” published by BNA International in
the World Data Protection Report in September 2009, and in the Privacy
and Security Law Report in October 2009.
ExclUSIvE IN-HoUSE SEMINaRS
We would be delighted to offer your company customized in-house
seminars and presentations on current issues and recent legal
developments. Please contact us.
PaTENT lITIgaTIoN: cURRENT lEgal DEvEloPMENTS foR PHaRMacEUTIcal aND lIfE ScIENcES coMPaNIES
On January 28, 2010, Dr. Richard Schlötter will be holding an
evening seminar on developments in patent litigation for the Life
Sciences industry (Patent Litigation: Aktuelle Entwicklungen im
Bereich Pharma/Life Sciences) at the Reed Smith Munich office.
If you are interested in attending this workshop or would like
more information, please contact Anja Oberschmidt
(aoberschmidt@reedsmith.com).
coNgRaTUlaTIoNS:
Dr. Alexander R. Klett was elected Co-Chair for the 2010-2011
term of the INTA Bulletin Committee - Policy & Practice Features
Subcommittee of the International Trademark Association.
IP/IT & MEDIa - JaNUaRY 2010 7
coNTRIbUToRS To THIS ISSUE
Dr. alexander R. klett, ll.M.
Partner
Intellectual Property
aklett@reedsmith.com
T: +49 (0)89 20304 145
Dr. Richard Schlötter
Partner
Intellectual Property
rschloetter@reedsmith.com
T: +49 (0)89 20304 172
katharina a. weimer, ll.M.
Associate
Advertising, Technology & Media
kweimer@reedsmith.com
T: +49 (0)89 20304 160
Provider of the Newsletter according to Sec. 5 German Act for Telecommunications Media Services (Telemediengesetz) and to Sec. 55 para 1 Interstate Treaty on Broadcasting (Rundfunkstaatsvertrag):
Reed Smith LLP - Fünf Höfe - Theatinerstrasse 8 80333 München
T: +49 (0)89 20304 10 F: +49 (0)89 20304 199
www.reedsmith.com
Responsible editors according to Sec. 55 para 2 Interstate Treaty on Broadcasting (Rundfunkstaatsvertrag):
Dr. Alexander R. Klett.
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