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If it is an obscure TM and the Respondent is located outside the UK, it could be argued that the Registrant had no prior knowledge of your clients rights (if any) at the time of registration. You must prove that the current Registrant was aware of your clients TM prior to registration.
In effect two parts to a DRS - Your clients rights and the Registrants bad faith. You have to prove both aspects to ensure success.
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