HomeTrade MarksInfringement

What Is Passing Off?

The common law action that protects the goodwill in an unregistered mark, name or get-up. You must prove reputation, a misrepresentation, and damage — and the Trade Marks Act limits damages against a defendant who is himself a registered proprietor.

The trade marks series, no. 37 · Infringement and enforcement · 6 min read

Not every valuable brand is registered. Passing off is the action that protects the rest — a common law cause of action applying in Papua New Guinea as part of the underlying law under Schedule 2 of the Constitution.

The classic trinity

A plaintiff must establish

1. Reputation or goodwill attaching to the goods or services in the mind of the purchasing public, by association with the mark, name, get-up or other identifying feature.

2. A misrepresentation by the defendant — whether or not intentional — leading or likely to lead the public to believe that the goods or services offered are those of the plaintiff.

3. Damage, or the likelihood of damage, resulting from the erroneous belief.

Proving each element of passing off
ElementWhat proves it
ReputationDuration and continuity of trading; sales volumes by year and province; advertising spend and samples; signage and packaging; media coverage; statements from distributors, retailers and trade bodies
MisrepresentationSamples of the defendant’s goods and packaging; side-by-side comparison; evidence of actual confusion — misdirected orders, complaints, returns, mistaken enquiries
DamageLost sales and margin; diverted custom; loss of licensing opportunity; damage to reputation where the defendant’s goods are inferior
Reputation is local, and it is the hard part

The goodwill must exist in Papua New Guinea, among the purchasing public here. A brand famous elsewhere but unknown in this market has nothing to protect. And reputation is proved by evidence, gathered and paid for — which is why a registration, which requires none of it, is so much cheaper to enforce.

Passing off and statutory infringement compared

Passing off compared with section 53 infringement
Infringement (s 53)Passing off
Requires registrationYesNo
Requires reputationNoYes
Requires damageNoYes, or its likelihood
What is protectedThe mark, for the registered goodsThe goodwill of the business, however identified — name, get-up, packaging, slogan, shop layout
Scope of goodsConfined to the specificationWhatever the reputation and the risk of confusion extend to
Geographic scopeThe whole country, subject to limitations on the registrationOnly where the reputation exists
Proof of titleCertified extract (s 10)Evidence of trading, built case by case
RemediesInjunction; damages or account, at the plaintiff’s option (s 56)Injunction; damages or an account, at general law
Where passing off does more

Because it protects goodwill rather than a registered sign, passing off can reach things a registration cannot: get-up and packaging as a whole, a trading name, a slogan, the look of a shop, and use on goods outside the registered specification. It is the natural companion claim in most infringement proceedings, and the only claim available where the mark was never registered or the registration has been removed.

Section 59 — the registered defendant’s shield

Section 59

In an action for passing off arising out of the use by the defendant of a registered trade mark of which he is the registered proprietor or a registered user, being a mark substantially identical with, or deceptively similar to, the plaintiff’s trade mark, damages shall not be awarded against the defendant if he satisfies the court:

(a) that at the time he commenced to use the mark he was unaware, and had no reasonable means of ascertaining, that the plaintiff’s mark was in use; and

(b) that when he became aware of the existence and nature of the plaintiff’s mark he immediately ceased to use his mark on goods in relation to which the plaintiff used it.

Note the four limits on the shield
  1. It applies only where the defendant is himself the registered proprietor or a registered user of the mark he used.
  2. It bars damages only — an injunction and the other relief remain available.
  3. Both conditions must be satisfied, and the burden is on the defendant.
  4. Condition (b) requires the defendant to have immediately ceased. A defendant who kept trading after learning of the plaintiff’s mark loses the protection entirely.

The practical lesson for a defendant is to search before adopting, and to stop at once if a prior user emerges. For a plaintiff, it is to give notice early and clearly — from the date the defendant becomes aware, continued use is unprotected.

Before writing a letter of demand

Section 90 applies to threats of proceedings for infringement of a mark that is registered, or alleged by the threatener to be registered. A person threatened may seek a declaration that the threats are unjustifiable, an injunction, and damages, unless the threatener shows the mark is registered and the acts would constitute infringement.

So a demand that asserts registration where there is none is exposed. Where your rights rest on reputation alone, say so — assert passing off, not infringement. Section 90(3) also confirms that the section does not render a lawyer liable for an act done in a professional capacity on behalf of a client.

The strongest position combines them: a registration for the statutory monopoly, copyright in the artwork, and the reputation to support passing off for everything the registration does not cover. For advice, see the law firms directory.

Check the section yourself

Before relying on anything here, read the current text of the Trade Marks Act (Chapter 385) and check for later amendments. If a decision matters to you, get advice — start with the Office of the Public Solicitor, or find a firm in the law firms directory.

Disclaimer: This article provides general information about Papua New Guinea law and does not constitute legal advice. Laws may change, and their application depends on individual circumstances. You should obtain professional legal advice for your specific situation. Read the full disclaimer.