09.24.2025
Cross-Border Chaos: Defining “Genuine Use” in Taiwan to Defend Your Trademark Across Borders
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Introduction: In the present globalized economy, multinational enterprises frequently establish operations across multiple jurisdictions, leveraging vast resources to influence international markets. With the increasing prominence of cross-border commerce, trademarks registered by these global businesses are not only tools of brand identification but also key assets that accumulate international recognition and market value. However, despite the international reach of a brand, trademark protection remains territorial.
Under Taiwan’s registration-based trademark system, a trademark may be registered without prior use; however, a registered trademark without use in commerce can be subject to revocation. Multinational companies that primarily conduct business online or from abroad and seek to maintain trademark rights in Taiwan without a physical presence often face challenges.
This article distills critical insights from four rulings by courts in Taiwan that clarify the threshold for “genuine use” of trademarks in a cross-border setting. These cases illuminate how courts weigh the realities of international e-commerce, marketing strategies, and local consumer engagement in order to determine whether trademark use can substantiate protection in Taiwan.
By examining these cases in depth, multinational enterprises should be equipped with practical guidance to not only elevate their trademarks on the global stage but also effectively demonstrate use, overcome legal challenges, and secure trademark protection within Taiwan’s unique legal framework.
Relevant Regulations in TaiwanArticle 5 of the Trademark Act stipulates,
I. “Use of a trademark” means any of the following act, in the course of trade, where such trademark is capable of being recognized by relevant consumers as a trademark:
(1) To apply a trademark to goods or packaging or containers thereof;
(2) To possess, display, sell, export, or import the goods referred to in the preceding subparagraph;
(3) To apply a trademark to articles relating to the provision of services; or
(4) To apply a trademark to commercial documents or advertisements relating to goods or services.
II. The preceding paragraph shall also apply to acts performed by digital audio-visual means, through electronic media, on the Internet, or through other media.(2) To possess, display, sell, export, or import the goods referred to in the preceding subparagraph;
(3) To apply a trademark to articles relating to the provision of services; or
(4) To apply a trademark to commercial documents or advertisements relating to goods or services.
Articles 57-III and 67-III of the Trademark Act respectively stipulate,
“The proof of use furnished pursuant to the preceding paragraph shall be capable of establishing the genuine use of the trademark in accordance with general commercial practices.”
“Paragraph 3 of Article 57 shall apply mutatis mutandis to the circumstance that a proprietor of a revoked trademark furnishes proof of use pursuant to Paragraph 2 of Article 65.”
“Paragraph 3 of Article 57 shall apply mutatis mutandis to the circumstance that a proprietor of a revoked trademark furnishes proof of use pursuant to Paragraph 2 of Article 65.”
Article 63-I-2 of the Trademark Act stipulates,
“The Registrar Office shall, ex officio or upon an application, revoke the registration of a trademark if such trademark has not yet been put to use or such use has been suspended for a continuous period of not less than three years without proper reasons for non-use, unless the trademark has been put to use by a licensee.”
JudgmentsI. Polipol Polstermoebel GmbH & Co. KG v. Taiwan Intellectual Property Office (Judgment 2021 Xin Shang Su Zi No. 94 of the Intellectual Property and Commercial Court) [1]
(1) Background
Target Brand, Inc. (hereafter referred to as “the Intervener”) filed an application for the trademark “
” designated for use on services “provision of convenience stores, superstores, supermarkets, shopping centers, and department stores; online shopping (electronic commerce)” in Class 35 on May 20, 2005. The trademark application was subsequently approved by the Taiwan Intellectual Property Office (TIPO) and registered under Trademark Registration No. 01198911 (hereafter referred to as “the disputed mark”).
On March 9, 2020, Polipol Polstermoebel GmbH & Co. KG (hereafter referred to as “the Plaintiff”) filed a non-use revocation action against the disputed mark, arguing that the registration of the disputed mark was in violation of Article 63-I-2 of the Trademark Act due to non-use of the mark.
In the Rebuttal, the Intervener argued that it was a globally recognized retail enterprise providing retail services to consumers worldwide. It has offered electronic commerce services through its official website, enabling consumers across the globe, including those in Taiwan, to place online orders. International shipping, including to Taiwan, has been facilitated via its logistics partner, Borderfree. To support the claim of genuine use of the disputed mark, in addition to the official website screenshots bearing the disputed mark along with archived webpages from its official website, the Intervener submitted order confirmation emails between its cooperating partner, Borderfree, and consumers in Taiwan, receipts detailing purchases made by consumers in Taiwan on the Intervener’s website, customer account lists, and online shopping records. According to the submitted account lists and online shopping records, the Intervener completed over 1,000 transactions with consumers in Taiwan between April 19, 2018, and February 29, 2020. The receipts also contained the disputed mark and indicate billing and shipping addresses located in Taiwan. Furthermore, the transaction amounts shown in the confirmation emails between Borderfree and consumers in Taiwan were denominated in New Taiwan dollars. Accordingly, the Intervener contended that its mark has been used in connection with “online shopping (electronic commerce)” services and, by extension, such use should be considered as covering similar services, including those provided by convenience stores, superstores, supermarkets, shopping centers, and department stores. Therefore, the disputed mark should not fall within the scope of Article 63-I-2 of the Trademark Act.
In response, the Plaintiff not only challenged the authenticity of the evidence submitted by the Intervener but also emphasized that the Intervener’s website was entirely in English, listed prices in U.S. dollars, and failed to explicitly indicate that shipping services extended to Taiwan. Accordingly, the Plaintiff argued that there was no clear indication of the Intervener’s intent to offer services to the Taiwanese market through its website.
In the Revocation Decision [2], the TIPO concluded that the Intervener’s mark was in use. This case has been brought to the Petitions and Appeals Committee and subsequently to the Intellectual Property and Commercial Court (IPCC). Both the Petitions and Appeals Committee and the IPCC upheld the same opinion regarding the use of the disputed mark.
” designated for use on services “provision of convenience stores, superstores, supermarkets, shopping centers, and department stores; online shopping (electronic commerce)” in Class 35 on May 20, 2005. The trademark application was subsequently approved by the Taiwan Intellectual Property Office (TIPO) and registered under Trademark Registration No. 01198911 (hereafter referred to as “the disputed mark”).On March 9, 2020, Polipol Polstermoebel GmbH & Co. KG (hereafter referred to as “the Plaintiff”) filed a non-use revocation action against the disputed mark, arguing that the registration of the disputed mark was in violation of Article 63-I-2 of the Trademark Act due to non-use of the mark.
In the Rebuttal, the Intervener argued that it was a globally recognized retail enterprise providing retail services to consumers worldwide. It has offered electronic commerce services through its official website, enabling consumers across the globe, including those in Taiwan, to place online orders. International shipping, including to Taiwan, has been facilitated via its logistics partner, Borderfree. To support the claim of genuine use of the disputed mark, in addition to the official website screenshots bearing the disputed mark along with archived webpages from its official website, the Intervener submitted order confirmation emails between its cooperating partner, Borderfree, and consumers in Taiwan, receipts detailing purchases made by consumers in Taiwan on the Intervener’s website, customer account lists, and online shopping records. According to the submitted account lists and online shopping records, the Intervener completed over 1,000 transactions with consumers in Taiwan between April 19, 2018, and February 29, 2020. The receipts also contained the disputed mark and indicate billing and shipping addresses located in Taiwan. Furthermore, the transaction amounts shown in the confirmation emails between Borderfree and consumers in Taiwan were denominated in New Taiwan dollars. Accordingly, the Intervener contended that its mark has been used in connection with “online shopping (electronic commerce)” services and, by extension, such use should be considered as covering similar services, including those provided by convenience stores, superstores, supermarkets, shopping centers, and department stores. Therefore, the disputed mark should not fall within the scope of Article 63-I-2 of the Trademark Act.
In response, the Plaintiff not only challenged the authenticity of the evidence submitted by the Intervener but also emphasized that the Intervener’s website was entirely in English, listed prices in U.S. dollars, and failed to explicitly indicate that shipping services extended to Taiwan. Accordingly, the Plaintiff argued that there was no clear indication of the Intervener’s intent to offer services to the Taiwanese market through its website.
In the Revocation Decision [2], the TIPO concluded that the Intervener’s mark was in use. This case has been brought to the Petitions and Appeals Committee and subsequently to the Intellectual Property and Commercial Court (IPCC). Both the Petitions and Appeals Committee and the IPCC upheld the same opinion regarding the use of the disputed mark.
(2) The IPCC’s opinion
1. Based on the evidential materials submitted by the Intervener, it can be concluded that between 2015 and 2017, the Intervener collaborated with Borderfree to offer international online shopping services for a wide range of retail goods, using the disputed mark in its marketing. Furthermore, the order and shipping confirmation emails issued by Borderfree featured the disputed mark, included explanatory notes in Traditional Chinese (commonly used in Taiwan), listed prices in New Taiwan Dollars, and specified shipping addresses located in various cities across Taiwan. The order dates, order numbers, and tracking numbers shown in the order confirmations, shipping confirmations, and customs documents can be cross-referenced and verified. Collectively, this evidence sufficiently supports the Intervener’s claim that, between April 10 and October 7, 2017, consumers in Taiwan placed orders and received goods through the Intervener’s online shopping platform, as described on its official website.
2. In today’s era of rapidly developing internet media and international trade, most companies operate official websites primarily in English. Potential customers and relevant consumers from all over the world, including Taiwan, can access these websites via the internet to learn about the goods or services offered and engage in transactions. Accordingly, although the Intervener’s shopping website is based in the United States, consumers located in Taiwan are still able to access and browse the website online. Moreover, as the Intervener did provide services for consumers in Taiwan to place orders and have goods delivered through its shopping website, the Intervener’s use of the mark reflected an intent to market its services to the Taiwanese market, and objectively, commercial transactions did take place. Thus, the Intervener indeed used its mark, and the Plaintiff’s argument in this regard is without merit.
2. In today’s era of rapidly developing internet media and international trade, most companies operate official websites primarily in English. Potential customers and relevant consumers from all over the world, including Taiwan, can access these websites via the internet to learn about the goods or services offered and engage in transactions. Accordingly, although the Intervener’s shopping website is based in the United States, consumers located in Taiwan are still able to access and browse the website online. Moreover, as the Intervener did provide services for consumers in Taiwan to place orders and have goods delivered through its shopping website, the Intervener’s use of the mark reflected an intent to market its services to the Taiwanese market, and objectively, commercial transactions did take place. Thus, the Intervener indeed used its mark, and the Plaintiff’s argument in this regard is without merit.
II. USA PRO IP LIMITED v. Taiwan Intellectual Property Office (Judgment 2023 Xin Shang Su Zi No. 18 of Intellectual Property and Commercial Court) [3]
(1) Background
USA PRO IP LIMITED (hereinafter referred to as “the Plaintiff”) filed an application for the trademark “ 
” designated for use on goods in Classes 18, 25, 27, and 28, on February 6, 2017. The application was subsequently approved by the TIPO and registered under Trademark Registration No. 01888275 (hereafter referred to as “the disputed mark”), with the registration being valid from December 16, 2017 to December 15, 2027.
On January 12, 2021, Montfort Services Sdn. Bhd. (hereinafter referred to as “the Intervener”) filed a non-use revocation action against the disputed mark, alleging that the registration of the disputed mark contravened Article 63_I-2 of the Trademark Act.
In the revocation decision [4], the TIPO concluded that the entire registration of the disputed mark should be revoked due to non-use. The case was subsequently appealed to the Petitions and Appeals Committee. In the appeal decision, the Committee revoked the original decision insofar as it pertained to the cancellation of the partial registration of the disputed mark for the designated goods “sportswear; clothing; shirts; pants; shorts; skirts; t-shirts; gilets; yoga pants; underwear; bras; sports bras; leggings; tights; vests; athletic tops for running, yoga, exercise and sport; sweatshirts; sweat pants; hoodies; jackets” in Class 25. The remainder of the revocation decision was upheld.
The Plaintiff subsequently filed an administrative suit before the IPCC. In its decision, the Court revoked the appeal decision and original decision insofar as they pertained to the cancellation of the partial registration of the disputed mark for the designated goods “gymnastic shoes; leisure shoes; sports shoes; esparto shoes or sandals” in Class25, “exercise mats; yoga mats” in Class 27 and “appliances for gymnastics; body-building apparatus; weight-bearing exercise equipment; dumb-bells; kettle bells; weight disc; bar-bells; pull-up bars for training arms; exercise weight bags; bags containing weights for attachment to the ankles, legs, or wrists for exercise; medicine balls; yoga and gym balls; gym bars; flexible exercise bands; foam blocks for use in yoga; jump ropes; resistance cables used for exercise; abdominal rollers; exercise hoops; head band [sports articles]; sport bands for wearing on the wrist to absorb sweat” in Class 28. The remainder of the Plaintiff’s pleadings were rejected.
” designated for use on goods in Classes 18, 25, 27, and 28, on February 6, 2017. The application was subsequently approved by the TIPO and registered under Trademark Registration No. 01888275 (hereafter referred to as “the disputed mark”), with the registration being valid from December 16, 2017 to December 15, 2027.On January 12, 2021, Montfort Services Sdn. Bhd. (hereinafter referred to as “the Intervener”) filed a non-use revocation action against the disputed mark, alleging that the registration of the disputed mark contravened Article 63_I-2 of the Trademark Act.
In the revocation decision [4], the TIPO concluded that the entire registration of the disputed mark should be revoked due to non-use. The case was subsequently appealed to the Petitions and Appeals Committee. In the appeal decision, the Committee revoked the original decision insofar as it pertained to the cancellation of the partial registration of the disputed mark for the designated goods “sportswear; clothing; shirts; pants; shorts; skirts; t-shirts; gilets; yoga pants; underwear; bras; sports bras; leggings; tights; vests; athletic tops for running, yoga, exercise and sport; sweatshirts; sweat pants; hoodies; jackets” in Class 25. The remainder of the revocation decision was upheld.
The Plaintiff subsequently filed an administrative suit before the IPCC. In its decision, the Court revoked the appeal decision and original decision insofar as they pertained to the cancellation of the partial registration of the disputed mark for the designated goods “gymnastic shoes; leisure shoes; sports shoes; esparto shoes or sandals” in Class25, “exercise mats; yoga mats” in Class 27 and “appliances for gymnastics; body-building apparatus; weight-bearing exercise equipment; dumb-bells; kettle bells; weight disc; bar-bells; pull-up bars for training arms; exercise weight bags; bags containing weights for attachment to the ankles, legs, or wrists for exercise; medicine balls; yoga and gym balls; gym bars; flexible exercise bands; foam blocks for use in yoga; jump ropes; resistance cables used for exercise; abdominal rollers; exercise hoops; head band [sports articles]; sport bands for wearing on the wrist to absorb sweat” in Class 28. The remainder of the Plaintiff’s pleadings were rejected.
(2) The IPCC’s opinion
1. Based on the sales statistics, product photographs, and invoices submitted by the Plaintiff, the Court confirmed that, between March 2018 and August 2020, consumers in Taiwan purchased sportswear, sports bras, leggings, and T-shirts bearing the disputed mark through the authorized distributors’ websites, namely, Sports Direct and House of Fraser.
In addition, the screenshots of product purchase history pages from these distributors demonstrate that other products bearing the disputed mark were also made available for purchase, including sports shoes, dumbbells, yoga mats, foam blocks for use in yoga, bags containing weights for attachment to the ankles or wrists for exercise, and flexible exercise bands. Considering that these websites featured such goods bearing the disputed mark during March and May 2018, and May 2020, time periods that overlap with the timeframe in which consumers in Taiwan purchased related apparel (i.e., sportswear, sports bras, leggings, and T-shirts), it can reasonably be concluded that consumers browsing the Plaintiff’s distributor websites had a high likelihood of encountering and potentially purchasing both categories of goods. Given that both sets of products constitute essential clothing and equipment for yoga or fitness activities, there exists a close association between them. It may be determined that the Plaintiff used the disputed mark on goods such as sports shoes, dumbbells, yoga mats, flexible exercise bands, foam blocks for use in yoga, and bags containing weights for attachment to the ankles or wrists for exercise with the intent to market those products. Moreover, such use enabled relevant consumers in Taiwan to recognize the source of the goods and distinguish them accordingly. This conclusion remains unaffected even if consumers did not ultimately purchase these items despite viewing them on the same websites. Accordingly, the Court held that the Plaintiff had genuinely used the disputed mark within the relevant three-year period on the following goods: “sports shoes” in Class 25, “yoga mats” in Class 27, and “weight-bearing exercise equipment; dumbbells; exercise weight bags; bags containing weights for attachment to the ankles, legs, or wrists for exercise; flexible exercise bands; foam blocks for use in yoga; resistance cables used for exercise” in Class 28.
In addition, when determining use of an “identical” trademark, the assessment must be based on how the trademark is actually used in commerce, specifically whether the goods or services in question are identical in terms of content, purpose, function, etc., and whether the general public would commonly perceive them as the same goods or services in commercial practice. In this case, the disputed mark was used on “sports shoes” in Class 25. This item shares overlapping or identical purposes and functions with other goods such as “gymnastic shoes; leisure shoes; esparto shoes or sandals” in Class25. Likewise, “yoga mats” and “exercise mats” in Class 27 were treated as conceptually overlapping. As for the goods “weight-bearing exercise equipment; dumbbells; exercise weight bags; bags containing weights for attachment to the ankles, legs, or wrists for exercise; flexible exercise bands; foam blocks for use in yoga; resistance cables used for exercise” in Class 28, they were considered functionally and commercially related to other fitness products such as “appliances for gymnastics; body-building apparatus; kettle bells; weight disc; bar-bells; pull-up bars for training arms; medicine balls; yoga and gym balls; gym bars; jump ropes; abdominal rollers; exercise hoops; head band [sports articles]; sport bands for wearing on the wrist to absorb sweat” in Class 28. These products generally share the same manufacturers, distribution channels, and consumer base in commercial practice. Therefore, they are considered to be goods of identical nature, and the use of the disputed trademark on such goods should be recognized as valid use.
On the other hand, the goods “panty hose; ankle socks; socks; winter gloves; ski gloves; gloves [clothing]; sports caps; swim caps; hats; baseball caps” in Class 25 and “games and toys; trampolines; sports balls; sports nets; exercise machines; wrist supports for sports; hand supports [sports articles]; waist supports for sports; men’s athletic supporters [sports articles]; protective mask for sports; protective paddings [parts of sports suits]; ornaments for Christmas trees; playing cards; roller skates and skateboards; bags for sports equipment; fishing tackle; sit-up benches; stationary exercise bicycles; stationary bicycles; elliptical machines; running machines; weightlifting chairs; weightlifting benches; trampolines; gloves for weight lifting; weight benches; gloves for mixed martial arts; gloves for sports” in Class 28 were not considered functionally or conceptually related to yoga and fitness products mentioned before and thus cannot be deemed goods of identical nature. As such, the Plaintiff has not sufficiently demonstrated that the disputed trademark was used on those goods.
2. Although the Plaintiff submitted screenshots of its official shopping website from March to September 2020, showing that products such as backpacks, tote bags, small travel cases, women’s ankle socks, and hats bearing the disputed trademark were visible to consumers browsing the site, the Court noted that the Plaintiff’s official website is a foreign site, with a top-level domain “.uk” rather than “.tw”. The website content is entirely in English, with no option for Traditional Chinese, and prices are not displayed in New Taiwan Dollars. Furthermore, no transaction records were provided to demonstrate that consumers in Taiwan actually placed orders for the aforementioned products via this website. Therefore, the Court finds it difficult to conclude that the Plaintiff’s official website targets consumers in Taiwan as part of its marketing strategy. As a result, it cannot be established that the disputed mark, as used on the aforementioned goods, is recognized by relevant consumers in Taiwan as a source identifier for them. Consequently, the use does not satisfy the requirements for trademark use to maintain rights. Accordingly, the Court finds no merit in the Plaintiff’s assertion that the disputed trademark was used on the goods in Class 18 and the goods such as “panty hose; ankle socks; socks; sports caps; swim caps; hats; baseball caps” in Class 25.
3. The Plaintiff further argues that its official website fulfills the requirement of marketing to the Taiwanese market by offering international shipping to Taiwan. However, the Court maintains that, since the website is entirely in English, provides no Chinese language options, and does not display prices in New Taiwan Dollars, the intended marketing audience appears to be English-speaking consumers abroad, rather than consumers in Taiwan. Even though Taiwan is listed among the destinations for international shipping, this may merely reflect an accommodation for overseas consumers who wish to have products delivered to Taiwan, rather than evidence of marketing efforts directed to the Taiwanese market. The Plaintiff failed to provide any evidence of actual transactions made by consumers in Taiwan through its official website, nor did it present any concrete evidence of marketing activities targeting Taiwan. Thus, the Court found it difficult to conclude that any actual commercial activity took place within Taiwan nor genuine use of the trademark.
In addition, the screenshots of product purchase history pages from these distributors demonstrate that other products bearing the disputed mark were also made available for purchase, including sports shoes, dumbbells, yoga mats, foam blocks for use in yoga, bags containing weights for attachment to the ankles or wrists for exercise, and flexible exercise bands. Considering that these websites featured such goods bearing the disputed mark during March and May 2018, and May 2020, time periods that overlap with the timeframe in which consumers in Taiwan purchased related apparel (i.e., sportswear, sports bras, leggings, and T-shirts), it can reasonably be concluded that consumers browsing the Plaintiff’s distributor websites had a high likelihood of encountering and potentially purchasing both categories of goods. Given that both sets of products constitute essential clothing and equipment for yoga or fitness activities, there exists a close association between them. It may be determined that the Plaintiff used the disputed mark on goods such as sports shoes, dumbbells, yoga mats, flexible exercise bands, foam blocks for use in yoga, and bags containing weights for attachment to the ankles or wrists for exercise with the intent to market those products. Moreover, such use enabled relevant consumers in Taiwan to recognize the source of the goods and distinguish them accordingly. This conclusion remains unaffected even if consumers did not ultimately purchase these items despite viewing them on the same websites. Accordingly, the Court held that the Plaintiff had genuinely used the disputed mark within the relevant three-year period on the following goods: “sports shoes” in Class 25, “yoga mats” in Class 27, and “weight-bearing exercise equipment; dumbbells; exercise weight bags; bags containing weights for attachment to the ankles, legs, or wrists for exercise; flexible exercise bands; foam blocks for use in yoga; resistance cables used for exercise” in Class 28.
In addition, when determining use of an “identical” trademark, the assessment must be based on how the trademark is actually used in commerce, specifically whether the goods or services in question are identical in terms of content, purpose, function, etc., and whether the general public would commonly perceive them as the same goods or services in commercial practice. In this case, the disputed mark was used on “sports shoes” in Class 25. This item shares overlapping or identical purposes and functions with other goods such as “gymnastic shoes; leisure shoes; esparto shoes or sandals” in Class25. Likewise, “yoga mats” and “exercise mats” in Class 27 were treated as conceptually overlapping. As for the goods “weight-bearing exercise equipment; dumbbells; exercise weight bags; bags containing weights for attachment to the ankles, legs, or wrists for exercise; flexible exercise bands; foam blocks for use in yoga; resistance cables used for exercise” in Class 28, they were considered functionally and commercially related to other fitness products such as “appliances for gymnastics; body-building apparatus; kettle bells; weight disc; bar-bells; pull-up bars for training arms; medicine balls; yoga and gym balls; gym bars; jump ropes; abdominal rollers; exercise hoops; head band [sports articles]; sport bands for wearing on the wrist to absorb sweat” in Class 28. These products generally share the same manufacturers, distribution channels, and consumer base in commercial practice. Therefore, they are considered to be goods of identical nature, and the use of the disputed trademark on such goods should be recognized as valid use.
On the other hand, the goods “panty hose; ankle socks; socks; winter gloves; ski gloves; gloves [clothing]; sports caps; swim caps; hats; baseball caps” in Class 25 and “games and toys; trampolines; sports balls; sports nets; exercise machines; wrist supports for sports; hand supports [sports articles]; waist supports for sports; men’s athletic supporters [sports articles]; protective mask for sports; protective paddings [parts of sports suits]; ornaments for Christmas trees; playing cards; roller skates and skateboards; bags for sports equipment; fishing tackle; sit-up benches; stationary exercise bicycles; stationary bicycles; elliptical machines; running machines; weightlifting chairs; weightlifting benches; trampolines; gloves for weight lifting; weight benches; gloves for mixed martial arts; gloves for sports” in Class 28 were not considered functionally or conceptually related to yoga and fitness products mentioned before and thus cannot be deemed goods of identical nature. As such, the Plaintiff has not sufficiently demonstrated that the disputed trademark was used on those goods.
2. Although the Plaintiff submitted screenshots of its official shopping website from March to September 2020, showing that products such as backpacks, tote bags, small travel cases, women’s ankle socks, and hats bearing the disputed trademark were visible to consumers browsing the site, the Court noted that the Plaintiff’s official website is a foreign site, with a top-level domain “.uk” rather than “.tw”. The website content is entirely in English, with no option for Traditional Chinese, and prices are not displayed in New Taiwan Dollars. Furthermore, no transaction records were provided to demonstrate that consumers in Taiwan actually placed orders for the aforementioned products via this website. Therefore, the Court finds it difficult to conclude that the Plaintiff’s official website targets consumers in Taiwan as part of its marketing strategy. As a result, it cannot be established that the disputed mark, as used on the aforementioned goods, is recognized by relevant consumers in Taiwan as a source identifier for them. Consequently, the use does not satisfy the requirements for trademark use to maintain rights. Accordingly, the Court finds no merit in the Plaintiff’s assertion that the disputed trademark was used on the goods in Class 18 and the goods such as “panty hose; ankle socks; socks; sports caps; swim caps; hats; baseball caps” in Class 25.
3. The Plaintiff further argues that its official website fulfills the requirement of marketing to the Taiwanese market by offering international shipping to Taiwan. However, the Court maintains that, since the website is entirely in English, provides no Chinese language options, and does not display prices in New Taiwan Dollars, the intended marketing audience appears to be English-speaking consumers abroad, rather than consumers in Taiwan. Even though Taiwan is listed among the destinations for international shipping, this may merely reflect an accommodation for overseas consumers who wish to have products delivered to Taiwan, rather than evidence of marketing efforts directed to the Taiwanese market. The Plaintiff failed to provide any evidence of actual transactions made by consumers in Taiwan through its official website, nor did it present any concrete evidence of marketing activities targeting Taiwan. Thus, the Court found it difficult to conclude that any actual commercial activity took place within Taiwan nor genuine use of the trademark.
III. Tokyu Corporation v. Taiwan Intellectual Property Office (Judgment 2020 Xin Shang Su Zi No. 104 of the Intellectual Property Court) [5]
(1) Background
Tokyu Corporation (hereafter referred to as “the Plaintiff”) filed an application for the trademark “ .png)
” designated for use on services in Classes 35, 36, 39, 41, 43 and 44 on February 6, 2014 under Application No. 103006470. Later on January 7, 2015, said trademark application was divided into two. The divisional application No. 103880452 covering the designated services “advertising; department stores; supermarkets; mail order; online shopping; retail and wholesale of livestock products; retail and wholesale of aquatic products; retail and wholesale of food products; retail and wholesale of cosmetics; retail and wholesale of beverages” in Class 35, “real estate rental and sales; brokerage of real estate sales and leasing” in Class 36, and “restaurants; hotels; cafés; snack bars” in Class 43 was approved and registered as Trademark Registration No. 01768451 (hereinafter referred to as “the disputed mark”), with the registration being valid from May 1, 2016 to April 30, 2026.
On June 26, 2019, Dong Ji Wu Industrial Co., Ltd. (translation from 東急屋實業有限公司, hereafter referred to as “the Intervener”) filed a non-use revocation action against the disputed mark, arguing that partial registration of the disputed mark for use on the services in Class 35 was in violation of Article 63-I-2 of the Trademark Act due to non-use of the mark.
In the revocation decision [6], the TIPO concluded that the registration of the disputed mark for use on the services “advertising; supermarkets; mail order; online shopping; retail and wholesale of livestock products; retail and wholesale of aquatic products; retail and wholesale of food products; retail and wholesale of cosmetics; retail and wholesale of beverages” in Class 35 should be revoked due to non-use. However, the TIPO decided to sustain the registration for the remaining service “department stores” in Class 35.
Dissatisfied with the unfavorable portion of the decision, the Intervener filed an administrative appeal. In the appeal decision, the Petitions and Appeals Committee revoked the part of the original decision that sustained registration for the remaining services “department stores” in Class 35, and ordered the TIPO to render a new decision within a specified period. Believing that the appeal decision was unlawful, the Plaintiff subsequently filed an administrative suit. The Intellectual Property Court (IPC), however, overruled the Plaintiff’s pleading.
” designated for use on services in Classes 35, 36, 39, 41, 43 and 44 on February 6, 2014 under Application No. 103006470. Later on January 7, 2015, said trademark application was divided into two. The divisional application No. 103880452 covering the designated services “advertising; department stores; supermarkets; mail order; online shopping; retail and wholesale of livestock products; retail and wholesale of aquatic products; retail and wholesale of food products; retail and wholesale of cosmetics; retail and wholesale of beverages” in Class 35, “real estate rental and sales; brokerage of real estate sales and leasing” in Class 36, and “restaurants; hotels; cafés; snack bars” in Class 43 was approved and registered as Trademark Registration No. 01768451 (hereinafter referred to as “the disputed mark”), with the registration being valid from May 1, 2016 to April 30, 2026.On June 26, 2019, Dong Ji Wu Industrial Co., Ltd. (translation from 東急屋實業有限公司, hereafter referred to as “the Intervener”) filed a non-use revocation action against the disputed mark, arguing that partial registration of the disputed mark for use on the services in Class 35 was in violation of Article 63-I-2 of the Trademark Act due to non-use of the mark.
In the revocation decision [6], the TIPO concluded that the registration of the disputed mark for use on the services “advertising; supermarkets; mail order; online shopping; retail and wholesale of livestock products; retail and wholesale of aquatic products; retail and wholesale of food products; retail and wholesale of cosmetics; retail and wholesale of beverages” in Class 35 should be revoked due to non-use. However, the TIPO decided to sustain the registration for the remaining service “department stores” in Class 35.
Dissatisfied with the unfavorable portion of the decision, the Intervener filed an administrative appeal. In the appeal decision, the Petitions and Appeals Committee revoked the part of the original decision that sustained registration for the remaining services “department stores” in Class 35, and ordered the TIPO to render a new decision within a specified period. Believing that the appeal decision was unlawful, the Plaintiff subsequently filed an administrative suit. The Intellectual Property Court (IPC), however, overruled the Plaintiff’s pleading.
(2) The IPC’s opinion
1. The evidential materials submitted by the Plaintiff are sufficient to establish that, within the three years prior to the filing date of the non-use revocation action (June 26, 2019), the Plaintiff promoted and marketed the services of the “Tokyu Department Store” operated in Japan through participation in international tourism exhibitions held in Taiwan.
2. According to the territorial principle of trademark law, use of a trademark must be for the purpose of commercial transactions within the domestic market, namely, the sale of goods or provision of services in Taiwan with relevant commercial activity, to be deemed use for “marketing purposes.” In other words, “marketing purposes” does not merely refer to making the trademark known to consumers; rather, it must involve association with the goods or services designated under the trademark registration, such that there is an actual possibility for consumers in Taiwan to purchase those goods or services in the local market. Only under such circumstances can the legislative purposes of the Trademark Act, namely, “protecting domestic consumers from confusion or deception” and “maintaining fair competition in the domestic market,” be fulfilled.
3. Furthermore, the use of a trademark establishes an association between the mark and the designated goods or services. Since trademark rights are premised on genuine use, and given that Taiwan follows a registration-based system where prior use is not a prerequisite for registration, continued use of a registered trademark is required to preserve those rights. To qualify as such use, it must not only fulfill the aforementioned “marketing purposes” but also constitute regular and economically meaningful use capable of creating or sustaining a market for the goods or services within the territory in which the trademark right exists. Mere promotion of the trademark in Taiwan, without any actual transaction (in whole or in part) occurring within Taiwan, fails to meet this threshold. If consumers in Taiwan are unable to purchase the goods or services represented by the trademark within Taiwan, the use lacks economic significance in terms of establishing a market in Taiwan, and therefore fails to serve the essential function of a trademark. Such use does not constitute genuine use for the purpose of maintaining trademark rights. For instance, if a food and beverage operator registers a trademark for restaurant services and then displays the mark on menus, price lists, business cards, or advertises via television or newspapers in Taiwan, yet does not operate any restaurant within Taiwan but merely promotes services provided by its overseas restaurants, then the designated restaurant services do not have any economic value in Taiwan. Such use cannot be considered genuine use sufficient to maintain the trademark rights.
4. Although the evidential materials submitted by the Plaintiff did show the disputed mark alongside references to a “department store,” the Plaintiff did not actually operate any department store within Taiwan. The shopping vouchers and promotional leaflets distributed by the Plaintiff at tourism exhibitions in Taiwan constituted mere advertising and promotional activities. Consumers in Taiwan must still visit the Plaintiff’s department stores located in Japan in order to redeem such vouchers and access the related services. The department store services were provided entirely in Japan, and both the place of service provision and the entire transaction process took place outside of Taiwan. There has been no economic activity related to the department store services taking place within Taiwan. Such use does not meet the standard of genuine use under Trademark Act in Taiwan. It therefore cannot be recognized that the Plaintiff used the disputed mark in connection with the designated “department store” services within Taiwan.
5. Further, although the Plaintiff argued that the inclusion of a Tokyu Department Store 5% discount coupon in the “Tokyu One-Day Pass Package” purchased by consumers constituted a form of reservation or pre-booking of department store services, and that part of the transaction therefore took place in Taiwan, thus amounting to genuine use of the trademark, this argument is unpersuasive.
The package sold at the travel exhibition was titled the “Tokyu Railway One-Day Pass Package,” offered at a promotional price of NTD350. The package included a Tokyu Railway one-day pass, a pouch, an iPASS card, a Tokyu Department Store 5% discount coupon, a TOKYU PLAZA ¥500 discount voucher, and a TOKYU HANDS 5% discount coupon. It is evident that the primary purpose of the NTD350 payment was to purchase the Tokyu Railway one-day pass, while the other items were merely complimentary gifts.
Consumers who received the Tokyu Department Store discount coupon were not necessarily expected to visit or make purchases at the department store. Therefore, it cannot be concluded that, by purchasing the “Tokyu Railway One-Day Pass Package,” consumers in Taiwan entered into any form of reservation or pre-arranged agreement for department store services. The Plaintiff’s claim that part of the transaction for department store services took place in Taiwan is thus insufficient and unconvincing.
2. According to the territorial principle of trademark law, use of a trademark must be for the purpose of commercial transactions within the domestic market, namely, the sale of goods or provision of services in Taiwan with relevant commercial activity, to be deemed use for “marketing purposes.” In other words, “marketing purposes” does not merely refer to making the trademark known to consumers; rather, it must involve association with the goods or services designated under the trademark registration, such that there is an actual possibility for consumers in Taiwan to purchase those goods or services in the local market. Only under such circumstances can the legislative purposes of the Trademark Act, namely, “protecting domestic consumers from confusion or deception” and “maintaining fair competition in the domestic market,” be fulfilled.
3. Furthermore, the use of a trademark establishes an association between the mark and the designated goods or services. Since trademark rights are premised on genuine use, and given that Taiwan follows a registration-based system where prior use is not a prerequisite for registration, continued use of a registered trademark is required to preserve those rights. To qualify as such use, it must not only fulfill the aforementioned “marketing purposes” but also constitute regular and economically meaningful use capable of creating or sustaining a market for the goods or services within the territory in which the trademark right exists. Mere promotion of the trademark in Taiwan, without any actual transaction (in whole or in part) occurring within Taiwan, fails to meet this threshold. If consumers in Taiwan are unable to purchase the goods or services represented by the trademark within Taiwan, the use lacks economic significance in terms of establishing a market in Taiwan, and therefore fails to serve the essential function of a trademark. Such use does not constitute genuine use for the purpose of maintaining trademark rights. For instance, if a food and beverage operator registers a trademark for restaurant services and then displays the mark on menus, price lists, business cards, or advertises via television or newspapers in Taiwan, yet does not operate any restaurant within Taiwan but merely promotes services provided by its overseas restaurants, then the designated restaurant services do not have any economic value in Taiwan. Such use cannot be considered genuine use sufficient to maintain the trademark rights.
4. Although the evidential materials submitted by the Plaintiff did show the disputed mark alongside references to a “department store,” the Plaintiff did not actually operate any department store within Taiwan. The shopping vouchers and promotional leaflets distributed by the Plaintiff at tourism exhibitions in Taiwan constituted mere advertising and promotional activities. Consumers in Taiwan must still visit the Plaintiff’s department stores located in Japan in order to redeem such vouchers and access the related services. The department store services were provided entirely in Japan, and both the place of service provision and the entire transaction process took place outside of Taiwan. There has been no economic activity related to the department store services taking place within Taiwan. Such use does not meet the standard of genuine use under Trademark Act in Taiwan. It therefore cannot be recognized that the Plaintiff used the disputed mark in connection with the designated “department store” services within Taiwan.
5. Further, although the Plaintiff argued that the inclusion of a Tokyu Department Store 5% discount coupon in the “Tokyu One-Day Pass Package” purchased by consumers constituted a form of reservation or pre-booking of department store services, and that part of the transaction therefore took place in Taiwan, thus amounting to genuine use of the trademark, this argument is unpersuasive.
The package sold at the travel exhibition was titled the “Tokyu Railway One-Day Pass Package,” offered at a promotional price of NTD350. The package included a Tokyu Railway one-day pass, a pouch, an iPASS card, a Tokyu Department Store 5% discount coupon, a TOKYU PLAZA ¥500 discount voucher, and a TOKYU HANDS 5% discount coupon. It is evident that the primary purpose of the NTD350 payment was to purchase the Tokyu Railway one-day pass, while the other items were merely complimentary gifts.
Consumers who received the Tokyu Department Store discount coupon were not necessarily expected to visit or make purchases at the department store. Therefore, it cannot be concluded that, by purchasing the “Tokyu Railway One-Day Pass Package,” consumers in Taiwan entered into any form of reservation or pre-arranged agreement for department store services. The Plaintiff’s claim that part of the transaction for department store services took place in Taiwan is thus insufficient and unconvincing.
IV. Wang, Guan-Xiong (transliteration from 王冠雄) v. Taiwan Intellectual Property Office (Judgment 2023 Xin Shang Su Zi No. 14 of the Intellectual Property and Commercial Court) [7]
(1) Background
Crown Melbourne Limited (hereafter referred to as “the Intervener”) filed an application for the trademark “CROWN” designated for use on services “hotels; restaurants; café; hot and cold beverage store s; beer houses; bars” in previous local class 42 on September 20, 1997. The trademark application was subsequently approved by the TIPO and registered under Trademark Registration No. 00104570 (hereafter referred to as “the disputed mark”).
On April 20, 2020, Wang, Guan-Xiong (hereafter referred to as “the Plaintiff”) filed a non-use revocation action against the disputed mark, arguing that the registration of the disputed mark was in violation of Article 63-I-2 of the Trademark Act due to non-use of the mark.
In the revocation decision [8], the TIPO concluded that the disputed mark should be revoked due to non-use. Dissatisfied with the revocation decision, the Intervener filed an administrative appeal. In the appeal decision, the Petitions and Appeals Committee revoked the original decision and ordered the TIPO to render a new lawful decision within a specified period. Believing that the appeal decision was unlawful, the Plaintiff subsequently filed an administrative suit. The IPCC, however, overruled the Plaintiff’s pleading.
On April 20, 2020, Wang, Guan-Xiong (hereafter referred to as “the Plaintiff”) filed a non-use revocation action against the disputed mark, arguing that the registration of the disputed mark was in violation of Article 63-I-2 of the Trademark Act due to non-use of the mark.
In the revocation decision [8], the TIPO concluded that the disputed mark should be revoked due to non-use. Dissatisfied with the revocation decision, the Intervener filed an administrative appeal. In the appeal decision, the Petitions and Appeals Committee revoked the original decision and ordered the TIPO to render a new lawful decision within a specified period. Believing that the appeal decision was unlawful, the Plaintiff subsequently filed an administrative suit. The IPCC, however, overruled the Plaintiff’s pleading.
(2) The IPCC’s opinion
1. According to the submitted evidence, Lion Travel Agency is an affiliate of Lion Travel Co. in Taiwan. Through this affiliation, Lion Travel Co., via Lion Travel Agency, entered into cooperation agreements with the Intervener for the provision of hotel accommodations and related services to Taiwanese tourists traveling to Australia. Moreover, promotional materials on the Lion Travel website for Australian tour packages include descriptions such as: “Special buffet meal at CROWN PLAZA or JUPITER hotel to satisfy your taste buds!” This indicates that the Intervener marketed its hotel services in Australia to consumers in Taiwan through its collaboration with Lion Travel Group.
2. Additional evidence further shows that, in 2017 and 2018, consumers in Taiwan booked accommodation and stayed at Crown Towers Melbourne through domestic travel websites such as “Tripadvisor” and “ezTravel,” and posted reviews afterward. This confirms that the Intervener actively promoted its hotel services in Australia to Taiwanese consumers through local booking platforms during the relevant period.
3. The foregoing evidence demonstrates that the Intervener promoted its “CROWN” branded hotel services located in Australia to consumers in Taiwan via local travel agencies and booking websites, thereby encouraging them to travel abroad and utilize those services. Although the Intervener did not operate a physical service location or directly provide hotel services within Taiwan, consumers in Taiwan were able to complete booking transactions domestically. As such, part of the commercial transaction process occurred within Taiwan. Given that Taiwanese consumers could engage in transactions for the services identified by the disputed mark within Taiwan, the trademark use bears economic significance in terms of establishing or expanding a market presence or distribution channel within the territory.
4. Accordingly, the use of the disputed trademark on hotel services satisfies the territorial principle of trademark law, and constitutes genuine use under the Trademark Act in Taiwan.
2. Additional evidence further shows that, in 2017 and 2018, consumers in Taiwan booked accommodation and stayed at Crown Towers Melbourne through domestic travel websites such as “Tripadvisor” and “ezTravel,” and posted reviews afterward. This confirms that the Intervener actively promoted its hotel services in Australia to Taiwanese consumers through local booking platforms during the relevant period.
3. The foregoing evidence demonstrates that the Intervener promoted its “CROWN” branded hotel services located in Australia to consumers in Taiwan via local travel agencies and booking websites, thereby encouraging them to travel abroad and utilize those services. Although the Intervener did not operate a physical service location or directly provide hotel services within Taiwan, consumers in Taiwan were able to complete booking transactions domestically. As such, part of the commercial transaction process occurred within Taiwan. Given that Taiwanese consumers could engage in transactions for the services identified by the disputed mark within Taiwan, the trademark use bears economic significance in terms of establishing or expanding a market presence or distribution channel within the territory.
4. Accordingly, the use of the disputed trademark on hotel services satisfies the territorial principle of trademark law, and constitutes genuine use under the Trademark Act in Taiwan.
ConclusionIn Case I (Target case), the court took a pragmatic and forward-looking approach by recognizing that cross-border e-commerce, even without physical presence or full localization, may constitute genuine trademark use in Taiwan if supported by concrete, verifiable evidence. Although the Intervener’s website was primarily in English and lacked explicit Taiwan-targeted design, the court was persuaded by the transactional records showing payments in New Taiwan Dollars, Traditional Chinese communications, and confirmed shipping addresses across Taiwan. These elements demonstrated not only the accessibility of the services to Taiwanese consumers but also real commercial engagement within the local market. This decision underscores the court’s adaptability to evolving trade realities, where digital platforms blur territorial lines and online transactions can establish sufficient market presence for trademark protection.
In contrast, Case II (USA PRO case) illustrates the court’s more rigorous standards when evaluating trademark use with limited ties to Taiwan. Although the court recognized certain sales through authorized distributors as genuine use, due to clear accessibility by consumers in Taiwan, it rejected claims based solely on a foreign, English-only website that lacked Taiwan-specific localization, evidence of domestic transactions, or interaction with local consumers. The judgment made clear that mere online accessibility or the availability of international shipping does not suffice. Instead, the court emphasized the necessity of demonstrable intent to target the Taiwanese market, backed by traceable commercial activity within Taiwan.
Turning to Cases III and IV, which focus on services provided outside Taiwan’s territory but marketed to Taiwanese consumers, the courts drew a clear line between promotional activities and genuine commercial transactions. In Case III (Tokyu case), the court ruled that marketing efforts within Taiwan, such as distributing vouchers and attending travel fairs, did not amount to genuine use since the service was rendered abroad and no part of the transaction occurred within Taiwan. This approach highlights the court’s strict interpretation that genuine use requires economically meaningful activities within the territory, not just brand awareness or advertising.
In contrast, Case IV (Crown case) set an important precedent by recognizing genuine use where Taiwanese consumers could complete part of the transactional process domestically, booking and paying for hotel services through local agencies, before consuming the service abroad. This partial transaction within Taiwan was sufficient to establish a tangible market presence, in line with the territorial principle of trademark law.
Author’s comments and suggestionsThe answer to the question whether cross-border use alone can support trademark protection in Taiwan, even without a physical presence, is a qualified but confident “Yes, but only with solid, jurisdiction-specific evidence.”
Recent rulings make clear that courts in Taiwan are willing to recognize changing commercial realities such as e-commerce and cross-border services, but not at the expense of the territorial nature of trademark rights. Genuine use must be proven through concrete, traceable activity tied to the Taiwanese market. Mere online visibility, international shipping options, or brand recognition without demonstrable engagement is not enough. What the courts consistently require is actual commercial interaction, i.e., “economic substance, not symbolic presence.”
To that end, multinational enterprises must strategically approach their trademark use in Taiwan. It is not necessary to have a local office or full business operations in Taiwan, but it is essential to make the mark functionally accessible and commercially relevant to consumers in Taiwan.
First, there must be a realistic possibility of transactions occurring within Taiwan. Ideally, this includes enabling direct purchases or bookings by consumers in Taiwan. At minimum, a part of the transactional process, such as order placement, should occur within Taiwan’s jurisdiction.
Second, an online presence that clearly targets Taiwan market must be established. If no dedicated “.tw” domain is launched, businesses should at least implement Traditional Chinese language options, list prices in New Taiwan Dollars, and offer shipping or service availability to Taiwan. These features should not be superficial and must be backed by actual consumer activities, such as access logs from Taiwan IP addresses, purchase records, and communications with customers in Taiwan.
Third, complete records that demonstrate genuine use. Transactional data, marketing analytics, distributor agreements, and evidence of consumer engagement specific to Taiwan are included. For service marks in particular, businesses must ensure that some portion of the transaction, whether it be booking, payment, or ordering, takes place within Taiwan. Courts have drawn a clear line: promotional activities like advertising or participating in trade fairs are not enough unless they are tied to a service that can be accessed or paid for from within Taiwan.
This reasoning becomes particularly relevant when being applied to service marks that involve department store operations, as illustrated by the Tokyu case. In the Tokyu case, the trademark owner operated a department store in Japan and attempted to establish use in Taiwan based on the distribution of brochures and discount coupons at travel fairs. However, the court held that such promotional activities, without any objective evidence of commercial transactions occurring within Taiwan, were insufficient to constitute genuine use. The court also noted the inherent challenge in delivering department store services across borders, as such services typically involve in-person consumer interactions.
However, the Target case offers a framework to potentially bridge this gap. The trademark owner operated a global online shopping platform and was able to substantiate genuine use in Taiwan through concrete evidence such as local orders, shipping confirmations, customs documentation, and customer testimonials. The court found that this demonstrated functional and commercially relevant use of the mark within Taiwan.
Drawing from Target case, a modified model may be feasible even for department store services. For instance, if a department store brand can enable consumers in Taiwan to place online orders and later pick up goods at an overseas retail location, such a “click-and-collect” mechanism, could possibly help satisfy the genuine use requirement under Taiwan’s territorial framework. While such hybrid service models are not yet standard, they should offer a possible path for asserting trademark use across borders, particularly for service marks traditionally tied to in-person experiences.
Finally, early registration should be followed by intentional, evidence-backed use. In Taiwan, the Trademark Law operates under a “use-it-or-lose-it” principle. Businesses that register marks without meaningful follow-through risk losing protection through cancellation actions.
These cases collectively reflect a practical, evolving judicial stance: courts in Taiwan are not rigid, but they do require evidence. They are open to cross-border and digital commerce, but only if the operation translates into tangible economic engagement with the local market. Trademark rights are preserved not by brand potential alone but by verifiable market relevance within Taiwan.
By adopting a localized strategy aligned with legal standards in Taiwan, multinational enterprises can more effectively manage trademark use and maintain brand protection in Taiwan.
References:
[1] Judgment 2021 Xin Shang Su Zi No. 94 of the Intellectual Property and Commercial Court (智慧財產及商業法院110年度行商訴字第94號行政判決).
[2] Revocation Decision Zhong Tai Fei Zi No. L01090103 issued by the Taiwan Intellectual Property Office (智慧財產局中台廢字第L01090103號廢止審定).
[3] Judgment 2023 Xin Shang Su Zi No. 18 of the Intellectual Property and Commercial Court (智慧財產及商業法院112年度行商訴字第18號行政判決).
[4] Revocation Decision Zhong Tai Fei Zi No. L01100021 issued by the Taiwan Intellectual Property Office (智慧財產局中台廢字第L01100021號廢止審定).
[5] Judgment 2020 Xin Shang Su Zi No. 104 of the Intellectual Property Court (智慧財產法院109年度行商訴字第104號行政判決).
[6] Revocation Decision Zhong Tai Fei Zi No. L01080263 issued by the Taiwan Intellectual Property Office (智慧財產局中台廢字第L01080263號廢止審定).
[7] Judgment 2023 Xin Shang Su Zi No. 14 of the Intellectual Property and Commercial Court (智慧財產及商業法院112年度行商訴字第14號行政判決).
[8] Revocation Decision Zhong Tai Fei Zi No. L01090197 issued by the Taiwan Intellectual Property Office (智慧財產局中台廢字第L01090197號廢止審定).
