An action for unfair competition in the Philippines has two essential elements as stated by the Supreme Court in a number of cases: (1) confusing similarity in the general appearance of the goods, and (2) intent to deceive the public and deceive a competitor. On the issue of confusion, two types have been noted. These are confusion of goods and confusion of business or source of origin. In the case of Asia Pacific Resources International Holdings, Ltd. v PAPERONE, INC. (G.R. Nos. 213365-66, December 10 2018), the Supreme Court found Paperone guilty of unfair competition.