DETROIT -- International automotive companies should prepare for tricky legal issues -- especially on trademarks and trade treaties -- as the United Kingdom exits the EU.
That’s the advice from Jeff Sadowski, a suburban Detroit patent attorney for Howard and Howard.
“There aren’t many patent issues” because the U.K. isn’t exiting the international group that oversees those, Sadowski said today in an interview.
“But trademarks could be vulnerable,” he said, because U.K. local laws differ from the pan-European ones that have prevailed in the EU so trademarks set up under EU rules eventually will need to be re-registered in the U.K.
“British trademark laws aren’t on a first-to-use basis, but first-to-file,” he said.
In the immediate aftermath of Brexit with a lengthy decoupling process ahead, it’s unclear when trademarks must be locally registered, “but I’m advising my clients to do it immediately,” Sadowski said. “It could be a real mess.”
There are also long-term potential issues on copyrights, trade treaties and data protection, though those aren’t as urgent.
“Talking with my contacts in England about future workload,” he added, “patent attorneys aren’t very excited, but trade treaty and data protection attorneys are excited and trademark attorneys are ecstatic.”