Russia: Galloping to confusion

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Russia: Galloping to confusion

Burburry is a most recognisable name. It's no less familiar checkered pattern is present on many clothes and accessories. Almost as often a galloping horseman rides across the checkered pattern. The horseman is registered as a trade mark in Russia under International Registration No 732707 in respect of goods in Class 25.

Another applicant, Hillsun International Industrial (China) filed in 2014 and obtained a registration No 575778 in respect of the same Class 25 of goods.

The patent office did not find similarity between these designations or, perhaps the examiner did not discover the earlier registered Burberry trade mark in the database. Anyway, some time later, Burberry noticed the existence of the Chinese trade mark and appealed against the registration on the basis of similarity. The owner of the appealed trade mark put forward arguments against the appeal. In particular, he noted that the outer appearance of the designations is different including that both horsemen ride in opposite directions (?). The cited trade mark shows an armed British knight while the appealed trade mark features a horseman clothed in a waving overcoat, unarmed, with a word element on the waving part of the overcoat representing the distinctive part of the company name of the trade mark owner. The heads and tails of horses are stylized differently. The cited trade mark may be associated with Britain, army, war while the appealed trade mark does not elicit such associations.

With all that, the board of the Chamber of Patent Disputes after examining the statements of the respondents concluded that the arguments of the appellant were convincing and explained its position in the way as follows:

The appealed trade mark, Registration No 575778 is a combined image which includes a stylised picture of a horseman with an overcoat on the waving part of which there is an inscription "HILLSUN", made in standard font in Latin characters. The cited trade mark according to IR 732707 is figurative designation representing a stylized picture of an armored horseman with a waving banner.

The board noted that when the images are perceived by the consumer his attention is first focused on exterior outline while small details are memorised to a lesser extent. Similarity of the compared trade marks is determined by general visual impression received by the consumer because the outlines of the horsemen figures coincide, the colour representation is the same, they have the same semantic meaning, i.e. stylized image of galloping horsemen. Besides, the techniques of stylisation are the same: both images are drafted using graphic silhouette outlines with a specific elaboration of details.

The presence of a word element "HILLSUN" in the appealed trade mark does not affect the conclusion on similarity because the inscription is made in small font and the attention of the consumer is not concentrated on it. The statement of the owner of the appealed trade mark regarding the cited trade mark, which allegedly features a British knight and elicits associations with Britain and military hostilities unlike the horseman in the appealed trade mark, does not hold water. This may be confirmed by the fact that perception of the image as a British knight is subjective because there are no distinctive features which would point to Britain.

The board also noted that both, the cited and the appealed trademarks may be associated with Middle Ages and Renaissance which enhances semantic and visual similarity of the compared designations.

As a result, registration of the appealed trade mark was cancelled. The Burberry knight continues his gallop unrestrained.

biriulin.jpg

Vladimir Biriulin

Gorodissky & Partners

Russia 129010, Moscow

B. Spasskaya Str

25, stroenie 3

Tel: +7 495 937 6116 / 6109

Fax: +7 495 937 6104 / 6123

pat@gorodissky.ru 

www.gorodissky.com

more from across site and SHARED ros bottom lb

More from across our site

Boehringer Ingelheim has instructed a team from Kirkland, while Teva is being represented by Pinsent Masons
The Delhi High Court’s latest directions offer an opportunity to move beyond remedies against bad-faith registrations and address how suspicious applications are identified in the first place, says Fatima Baig at Lexlinc
Camilla Hamrin describes how the acquisition by Acapo Onsagers will impact Bergenstråhle’s trademark practice – and reflects on changes she has seen over 30 years in IP
On a recent trip to the French capital, we learned that the UPC is squeezing domestic litigation while firms are chasing senior talent, experimenting with AI and considering new ways of organising their practices
Daniel Law says a string of lateral hires and broader expansion plans will strengthen its position to capitalise on Brazil’s burgeoning IP and patent litigation market
Jason Raeburn’s arrival will expand the firm’s London footprint in AI, copyright and tech disputes
The firm is shaping its AI strategy around partnerships with Harvey and Legora alongside internally developed tools from its legal technology company, Eltemate
A dispute Down Under shows why trademark lawyers cannot afford to wait on the sidelines when a rival brand gathers momentum
The Third Circuit’s decision in Thomson Reuters v ROSS marks the first appellate-level decision addressing AI and fair use, prompting copyright counsel to consider arguments around potential licensing markets
Injunctions for HandsFree Labs and Align Technology come as the Court of Appeal warns that busy teams must have the staffing and resources to meet UPC deadlines
Gift this article