Trade Marks PDF

Corporate & Commercial Practice Intellectual Property Trade Marks Intellectual Property Office of Singapore Trade Mark Basics Legislation  Trade Marks Act 1998 (“TMA”)  Trade Marks Rules  Trade Marks (International Registration) Rules (non-examin...

Corporate & Commercial Practice Intellectual Property Trade Marks Intellectual Property Office of Singapore Trade Mark Basics Legislation  Trade Marks Act 1998 (“TMA”)  Trade Marks Rules  Trade Marks (International Registration) Rules (non-examinable) Trade marks Word Mark Others e.g. Sound Mark (non-examinable) Device Mark Composite Mark Why trade marks?  Guarantee of origin / quality  Serves as “short cut” for the consumer  Saves search time and costs  Just desserts theory  Trader deserves protection in return for its investment to build up public recognition of its trade mark  Attractive power of a trade mark  Well known marks and concept of dilution (non-examinable) Symbols TM  indicates that the mark is being used by a party as a trade mark  does not denote that the mark is registered or protected under the trade mark law. ®  indicates that a mark is registered  not a statutory requirement to use the ® with a registered trade mark, and any omission to use the ® does not affect the registration of the mark  an offence to use the ® symbol together with a trade mark that is yet to be registered: Section 51(1) TMA What is a trade mark  Interpretation in Section 2(1) TMA  “trade mark” means any sign capable of being represented graphically* and which is capable of distinguishing goods or services dealt with or provided in the course of trade by a person from goods or services so dealt with or provided by any other person;  “sign” includes any letter, word, name, signature, numeral, device, brand, heading, label, ticket, shape, colour, aspect of packaging or any combination thereof;  *Requirement of graphical representation  The register must enable the public / authorities to know the exact parameters of the scope of protection Benefits of registration  Not compulsory to register a trade mark in order to use it  Unregistered trade marks may still be protected by the law of passing off (non-examinable)  So why register?  Adds value to a business Benefits of registration  Statutory property right  A registered trade mark is a property right obtained by the registration of the trade mark under this Act and the proprietor of a registered trade mark has the rights and remedies provided by this Act: Section 4(1)  Register is prima facie evidence of anything contained in it e.g. ownership: Section 101(a)  The owner of the registered trade mark is granted a statutory monopoly over the mark and has the right to control the use of the trade mark Benefits of registration  Right to control the use of a trade mark  restrict other parties from using the registered trade mark in Singapore without the owner’s consent (infringement action)  prevent a later trade mark, which is similar or identical to an earlier registered trade mark, from being registered in Singapore in relation to the same or similar goods or services (opposition)  prevent a later trade mark, which is similar or identical to an earlier registered trade mark, from remaining registered in Singapore in relation to the same or similar goods or services (invalidation) Practical considerations before registration 1. Budget  Mark variations  Classes of goods and services  Countries (jurisdictions) 2. Mark  Earlier Identical / similar marks  Registers in countries (jurisdictions) of interest 3. Goods and services  Nice classification  Current goods and services  Future expansion Practical considerations before registration 4. Use of mark  By self or licensees  Records  Beware revocation for non-use 5. Countries to register in  Current markets  Future expansion Registration overview Trade mark application filed Formalities Examination  If not compliant, examiner informs applicant of objections Substantive Examination on Absolute and  Objections may be Relative Grounds overcome and the application eventually accepted If accepted, application is published in Trade Marks Journal If no opposition filed, or opposition is decided in applicant’s favour, mark is registered Opposition overview  Recap: After a TM application is accepted, it is published in the TM Journal, a public document  During the opposition period, anyone can object to the registration of the TM by starting an opposition  The grounds of opposition overlap with the registrability criteria used during examination  There are absolute and relative grounds for refusal, relevant in both examination and opposition  If the grounds of opposition are established, the TM application is refused  If the grounds of opposition are not established, the TM application progresses to registration Intellectual Property Trade Marks Registrability Criteria: Absolute Grounds Section 7(1) and (2)  Absolute grounds for refusal of registration  7.—(1) The following shall not be registered… (b) trade marks which are devoid of any distinctive character; (c) trade marks which consist exclusively of signs or indications which may serve, in trade, to designate the kind, quality, quantity, intended purpose, value, geographical origin, the time of production of goods or of rendering of services, or other characteristics of goods or services… (2) A trade mark shall not be refused registration by virtue of subsection (1)(b), (c)…if, before the date of application for registration, it has in fact acquired a distinctive character as a result of the use made of it. Types of Marks  Han’s (F & B) Pte Ltd v Gusttimo World Pte Ltd 2 SLR 825 (“Hans”)  Some trade marks carry a high level of inherent distinctiveness (see - )  understood by the public as bearing a trade mark meaning  even if they have not yet been used or promoted to the public  Invented words are classic examples of such trade marks.  Words whose meaning has little bearing on the product to which it is to be applied.  Other marks, may have low levels of inherent distinctiveness  mark includes a word or symbol or device that is at least partially descriptive of the goods or service.  the word chosen has a laudatory meaning or some meaning that captures a mood or image of some relevance to the product or service in question  Sign possesses a capability to distinguish but is regarded as not possessing distinctiveness, at the time when chosen and first used  members of the public may over a period of time be taught, through advertising and brand promotion exercises, to recognise the trade mark as performing a trade mark function  In this way, the trade mark has acquired distinctiveness through use Love & Co Pte Ltd v The Carat Club Pte Ltd 1 SLR(R) 561 (“Love”)  An invalidation case where applicant for invalidation sought to have the registration of “LOVE” declared invalid  Each absolute ground for registration in s 7(1) operates independently though the grounds may overlap (at 45])  A failure to overcome any ground of objection is sufficient to deny registration (or the render a registration invalid)  Section 7(1)(b) on being “devoid of any distinctive character” is a catch all objection (at )  Includes descriptive marks  Converse may not be true Love  Summary of outcome  The “LOVE” trade mark is devoid of distinctive character: s 7(1)(b)  strikingly unimaginative design  widespread use of the word “love” within the jewellery trade  need to educate the public that the “LOVE” trade mark was being used by the defendant as its trade mark  The “LOVE” mark designated the intended purpose of jewellery: s 7(1)(c)  intended purpose of jewellery to serve as an expression of love In the Matter of a Trade Mark Application by Marvelous AQL Inc SGIPOS 3 (“Marvelous”)  Essential principles (at )  Section 7(1)(c) is in the public interest, to ensure that descriptive terms may be freely used by all  The signs and indications referred to in s 7(1)(c) are those which may serve in normal usage from a consumer’s point of view designate, either directly or by reference to one of their essential characteristics, goods or services which registration is sought  The situations specifically covered by s 7(1)(c) are those in which the sign is capable of designating a “characteristic” of the goods or services referred to in the application  Non-exhaustive list  The provision extends to any characteristic of goods or services, irrespective of how significant the characteristic may be commercially  The property [or characteristic] in question must be easily recognisable by the relevant class of persons Marvelous  Essential principles (at )  It is not necessary that such descriptive terms are actually in use, it is sufficient that such signs and indications could be used to designate a characteristic of the goods or services  A sign must be refused under s 7(1)(c) if at least one of its possible meanings designates a characteristic of the goods or services concerned  It is irrelevant if there are other, more usual signs or indications for designating a particular characteristic of the goods or services  As a general rule, a mere combination of elements, each of which is descriptive of characteristics of the goods or services, itself remains descriptive  However, the combination may not be descriptive if there is a perceptible difference between the resultant combination and the mere sum of its parts  The existence of a specific defence [Section 28(1)(b)] does not limit the scope of Section 7(1)(c)  The term “exclusively” requires a purposive approach Conclusion: Types of Marks Type Example Goods / Fanciful Kodak Any  (no meaning in common language) Arbitrary Apple Computers  Suggestive Jaguar Cars  Descriptive Fresh & Crunchy Apples  Generic Apple Apples  Intellectual Property Trade Marks Registrability Criteria: Relative Grounds Overview  Relative grounds vs absolute grounds  What is an earlier trade mark  Section 2(1)  Section 8  Section 8(2)  Section 8(2)(b) (most common objection)  Section 8(4) well known mark (non-examinable)  Section 8(7)(a) passing off (non-examinable) Section 2  Interpretation 2.—(1) In this Act, unless the context otherwise requires —  “earlier trade mark” means — (a) a registered trade mark or an international trade mark (Singapore), the application for registration of which was made earlier than the trade mark in question, taking account (where appropriate) of the priorities claimed in respect of the trade marks; or (b) a trade mark which, at the date of application for registration of the trade mark in question or (where appropriate) of the priority claimed in respect of the application, was a well known trade mark, and includes a trade mark in respect of which an application for registration has been made and which, if registered, would be an earlier trade mark by virtue of paragraph (a) subject to its being so registered; Section 8(2)  Relative grounds for refusal of registration  8(2) A trade mark shall not be registered if because — (a) it is identical with an earlier trade mark and is to be registered for goods or services similar to those for which the earlier trade mark is protected; or (b) it is similar to an earlier trade mark and is to be registered for goods or services identical with or similar to those for which the earlier trade mark is protected, there exists a likelihood of confusion on the part of the public. Staywell Hospitality Group Pty Ltd v Starwood Hotels & Resorts Worldwide, Inc and another and another appeal 1 SLR 911 (“Staywell”)  3-step test Application Mark Opponent’s Earlier Mark 3-Step test  Step 1  Identify the marks for comparison  Earlier mark v later mark  Compare the marks  Step 2  Identify the goods / services for comparison  Earlier goods / services v later goods / services  Compare the goods / services  Step 3  Assess likelihood of confusion  Mark-similarity factors  Goods-similarity factors 3-Step test  Once the two threshold requirements in Steps 1 and 2 have been met, the issue of the likelihood of confusion arises in Step 3 for consideration:  how similar the marks are  how similar the goods / services are, and given this,  how likely the relevant segment of the public will be confused (Staywell at )  If marks not similar under Step 1 or goods / services not identical / similar under Step 2, threshold requirements not met, no necessity to proceed to Step 3 Step 1  Identify the marks for comparison  What is the earlier mark?  Is it an earlier registered / applied for mark? Check date  Compare the marks  Assess marks-similarity  Comparison is mark-for-mark without consideration of any external matter (at )  The three aspects of similarity (i.e. visual, aural and conceptual similarities) are meant to guide the inquiry  Trade-offs can occur among the three aspects of similarity (at ) Step 1  Inherent technical distinctiveness is an integral factor in the marks- similarity inquiry.  A mark which has greater technical distinctiveness enjoys a high threshold before a competing sign will be considered dissimilar to it (at )  E.g. “Nutella” has high technical distinctiveness, “Nutello” is more readily considered similar Step 1  While the components of a mark may be inherently technically distinctive, ultimately the ability of the mark to function as a strong badge of origin must be assessed by looking at the mark as a whole.  Conversely, the components of a mark may not be inherently distinctive, but the sum of its parts may have sufficient technical distinctiveness (at )  When speaking of the assessment of a mark as a whole, the visual, aural or conceptual similarity of the marks in question must be based on the overall impression given by the marks, bearing in mind, in particular, their distinctive and dominant components (at )  The similarity of marks is ultimately and inevitably a matter of impression rather than one that can be resolved as a quantitative or mechanistic exercise.  The court must ultimately conclude whether the marks, when observed in their totality, are more similar than dissimilar (at ) Step 1  Whose perspective?  Hai Tong Co (Pte) Ltd v Ventree Singapore Pte Ltd and another and another appeal 2 SLR 941 (“Hai Tong”)  The relevant viewpoint is that of the average consumer who would exercise some care and a measure of good sense in making his or her purchases, not that of an unthinking person in a hurry (at )  It is assumed that the average consumer has “imperfect recollection” such that the two contesting marks are not to be compared or assessed side by side (and examined in detail). Instead, the court will consider the general impression that will likely be left by the essential or dominant features of the marks on the average consumer (at ) Step 1  Visual similarity  For word marks, consider  length of the marks (how many letters)  structure of the marks (e.g. how many words)  overlap in the letters of the marks  size of the elements in common relative to the rest of the marks  For composite marks, consider  whether the textual element or the device is more dominant  size of textual element versus device  prominence of placement of textual element versus device  distinctiveness of textual element versus device (e.g. is device perceived as descriptive of the goods / services, or decorative, rather than indicative of trade origin?) Step 1  Aural similarity  2 approaches  Qualitative  Consider the dominant and distinctive component (Staywell at )  Quantitative  Consider whether the competing marks have more syllables in common than not (Staywell at ) Step 1  Conceptual similarity  The conceptual analysis seeks to uncover the ideas that lie behind and inform the understanding of the mark as a whole  greater care is therefore needed in considering what the conceptually dominant component of a composite mark is because the idea connoted by each component might be very different from the sum of its parts (Staywell at )  e.g. concepts of “St Regis” and “Park Regis” different from idea connoted by “Regis” alone (Staywell at ) Step 1: Summary  Identify the marks for comparison  Compare the marks  mark-for-mark comparison  3 aspects / trade-offs can occur  inherent technical distinctiveness  mark considered as a whole, taking into account the dominant and distinctive components  overall impression, more similar than dissimilar  perspective of an average consumer who would exercise some care and a measure of good sense  average consumer has imperfect recollection; marks not compared side by side in detail  principles for visual, aural and conceptual comparison  Conclude whether the marks are similar or not Step 2  Identify the goods / services for comparison  Look at specifications  Compare the goods / services  Assess goods / services-similarity  British Sugar factors  Relevance of class numbers Step 2  Compare the goods / services  Assess goods / services-similarity  If same specification, already identical goods / services, 2nd element of s 8(2)(b) established (Staywell at [40-41])  If not identical, continue to assess whether goods / services similar Step 2  Compare the goods / services  Relevance of class numbers  International Classification of Goods and Services (Nice Classification)  Goods Classes (1- 34) and Services Classes (35 – 45)  E.g. Class 25 “Clothing, footwear, headwear”  E.g. Class 36 “Financial, monetary and banking services; insurance services; real estate services”  Goods / services which fall under the same class might be similar, but the class number itself is not determinative (e.g. Class 9 covers a wide variety of goods, which may not be similar to each other)  One should still consider the actual specifications of goods / services Step 2 Compare the goods / services  How goods / services in issue are regarded in trade  British Sugar factors from British Sugar plc v James Robertson & Sons Ltd RPC 281 (a) The respective uses of the respective goods or services (b) The respective users of the respective goods or services (c) The physical nature of the goods or acts of service (d) The respective trade channels through which the goods or services reach the market (e) In the case of self-serve consumer items, where in practice they are respectively found or likely to be found in supermarkets and in particular whether they are, or are likely to be, found on the same or different shelves (f) The extent to which the respective goods or services are competitive. This inquiry may take into account how those in trade classify goods Step 3  Assess likelihood of confusion  Opposition: compare actual and notional fair uses (look at both parties’ specifications) (at )  Infringement: compare defendant’s actual use and claimant’s actual and notional fair uses (look at claimant’s specification) (at )  Confusion must be the kind that arises from similarity of marks and identity / similarity of goods / services  Permissible extraneous factors Step 3  Once marks-similarity and goods- / services-similarity have been established, consider the impact of these similarities on the relevant consumers’ ability to understand where those goods / services originate from (at )  The only relevant confusion is that which results from the similarity between marks and goods or services  The establishment of similarity of marks and goods or services does not make a finding of confusion automatic Step 3  Assess likelihood of confusion  Permissible extraneous factors  Extraneous factors may be considered to the extent that they inform the court as to how the similarity of marks and goods will likely affect the consumer’s perception as to the source of the goods (at )  : (a) intrinsic to the very nature of the goods and/or (b) affect the impact that the similarity of marks and goods has on the consumer.  The impermissible factors are those differences between the competing marks and goods which are created by a trader’s differentiating steps e.g. pricing differentials, packaging and superficial marketing choices made by the trader (at ) Step 3  Assess likelihood of confusion  [96(a)]  Permissible extraneous factors relating to the impact of marks- similarity on consumer perception  Non-exhaustive list:  degree of similarity of the marks  reputation of the marks  a strong reputation does not necessarily equate to a higher likelihood of confusion, and could in fact have the contrary effect  impression given by the marks  possibility of imperfect recollection of the marks. Step 3  Assess likelihood of confusion  [96(b)]  Permissible extraneous factors relating to the impact of goods- similarity on consumer perception  Excludes steps taken by trader to differentiate the goods  Non-exhaustive list:  Normal way in, or the circumstances under, which consumers would purchase goods of that type  Whether the goods are expensive or inexpensive  Whether the goods would tend to command a greater or lesser degree of fastidiousness and attention on the part of prospective purchasers  Likely characteristics of the relevant consumers and whether they would or would not tend to apply care or have specialist knowledge in making the purchase. Intellectual Property Trade Marks Registration and Renewal Registration  A trade mark is registered for 10 years from the date of registration: Section 18(1)  A trade mark when registered is registered as of the date of the application for registration, and that date is deemed to be the date of registration: Section 15(2)  Example:  TM application filed on 2 February 2024  Accepted and published on 8 August 2024; no opposition up till 8 October 2024  Registered for 10 years from 2 February 2024  2 February 2034 Renewal  A trade mark registration may be renewed for further periods of 10 years each: Section 18(2)  Cost vs benefit  If mark no longer of interest, can allow registration to expire without renewal  If mark has been licensed to licensee, make sure it is renewed if it expires during the term of the licence Intellectual Property Trade Marks Exclusive Rights Exclusive rights 26.—(1) The proprietor of a registered trade mark has the exclusive rights — (a) to use the trade mark; and (b) to authorise other persons to use the trade mark, in relation to the goods or services for which the trade mark is registered. … (4) The rights shall accrue to the proprietor as from the date of registration of the trade mark, except that — (a) no infringement proceedings may be begun before the date on which the trade mark is in fact registered; … (5) If the trade mark is registered subject to any disclaimer or limitation, the rights of the proprietor are restricted by the disclaimer or limitation. Disclaimer or limitation 30.—(1) An applicant for registration of a trade mark, or the proprietor of a registered trade mark, may — (a) disclaim any right to the exclusive use of any specified element of the trade mark; or (b) agree that the rights conferred by the registration shall be subject to a specified territorial or other limitation. (2) Where the registration of a trade mark is subject to a disclaimer or limitation, the rights conferred by section 26 are restricted accordingly.  Example: A composite mark containing a distinctive word and a non- distinctive device is registered with a disclaimer to the non-distinctive device as such Nature of registered trade mark  A registered trade mark is personal property: Section 36  Therefore, it is possible to assign or license a registered trade mark: Section 38(1)  Assignment may be full or partial: Section 38(2)  Assignment must be in writing and signed by or on behalf of the assignor: Section 38(3)  Licence may be full or limited: Section 42(1), (2)  Licence must be in writing and signed by or on behalf of the grantor: Section 42(3) Registration (recordal) of assignments and licences  Why register and put the main details of the transaction on public record (on the register of trade marks)?  Unless an application to register the transaction, it is ineffective as against a person acquiring a conflicting interest in the trade mark, in ignorance of the transaction: Section 39(3)  A person who becomes the proprietor of a registered trade mark is not entitled to monetary remedies in respect of infringement occurring after the date of the transaction and before the date of the application to register the transaction: Section 39(4) Intellectual Property Trade Marks Post-registration Challenges Post-registration challenges  Pre-registration, an application to register a trade mark may be opposed  Post-registration, a registered trade mark may still be challenged  Focus: invalidation and revocation  Can be brought in the High Court or before the Registrar of TM  Why may a registered mark be challenged?  The challenged mark has been cited under section 8 against the challenger’s later TM application during examination  The applicant for invalidation missed the deadline to oppose the challenged mark before it was registered  As a counterclaim to an action for infringement by the owner of the registered mark Invalidation  Section 23, read with sections 7 and 8  On grounds that disqualify a mark from being registrable  Recall absolute and relative grounds for refusal of registration  Effect of successful application for declaration of invalidity is that the registration of the mark is deemed never to have been made, but this shall not affect transactions past and closed: section 23(10)  Invalidation can be full or partial: section 23(9) Revocation  Focus: section 22(1)(a) and (b)  On grounds that the mark has not been used for 5 years consecutively  Burden of proof of use on mark owner: section 105  Effect of successful application for revocation is that the registration of the mark is revoked from the date of the application for revocation, or an earlier date when the grounds for revocation existed: section 22(7)  Revocation can be full or partial: section 22(6) Revocation  If use takes place after the 5-year period and more than 3 months before the application for revocation, the registered mark shall not be revoked: section 22(3), (4)  If use takes place within 3 months before the application for revocation, but preparations for it began before the proprietor became aware that the application might be made, the registered mark shall not be revoked: section 22(4)  The relevant “use” includes use in a form differing in elements which do not alter the distinctive character of the mark in the form in which it was registered: section 22(2) Revocation Example involving dates  Registered mark allegedly not used between 1 Jan 2018 and 31 Dec 2023  Application for revocation filed on 5 May 2024  Registered mark resumed use on 4 April 2024 and the preparations only started after proprietor was aware that the application for revocation might be made  Such use is disregarded: section 22(4)  Proprietor cannot prove use other than the above  Registered mark is revoked, effectively from 1 Jan 2024 (the 1st day after the end of the 5-year period of non-use): section 22(7)(b) Intellectual Property Trade Marks Infringement Infringement 27.—(1) A person infringes a registered trade mark if, without the consent of the proprietor of the trade mark, the person uses in the course of trade a sign which is identical with the trade mark in relation to goods or services which are identical with those for which it is registered. (2) A person infringes a registered trade mark if, without the consent of the proprietor of the trade mark, the person uses in the course of trade a sign where because — (a) the sign is identical with the trade mark and is used in relation to goods or services similar to those for which the trade mark is registered; or (b) the sign is similar to the trade mark and is used in relation to goods or services identical with or similar to those for which the trade mark is registered, there exists a likelihood of confusion on the part of the public. Infringement (4) For the purposes of this section and sections 28, 29 and 31, a person uses a sign if, in particular, the person — (a) applies it to goods or the packaging thereof; (b) offers or exposes goods for sale, puts them on the market or stocks them for those purposes under the sign, or offers or supplies services under the sign; (c) imports or exports goods under the sign; (d) uses the sign on an invoice, wine list, catalogue, business letter, business paper, price list or other commercial document, including any such document in any medium; or (e) uses the sign in advertising. Infringement (5) Despite subsection (4), a person who — (a) applies a sign to any material used or intended to be used for labelling or packaging goods; or (b) uses a sign on any document described in subsection (4)(d) or in advertising, is deemed not to use the sign if, at the time of such application or use, the person does not know nor have reason to believe that the proprietor or a licensee of the registered trade mark did not consent to such application or use of the sign. Infringement Recall Staywell Hospitality Group Pty Ltd v Starwood Hotels & Resorts Worldwide, Inc and another and another appeal 1 SLR 911 (“Staywell”) : the 3-step Staywell test applies to infringement cases to : for infringement, compare the range of notional fair uses of the claimant’s mark against the actual use of the defendant’s sign to : permissible and non-permissible extraneous factors at 3rd step of Staywell test Intellectual Property Trade Marks Defences Defences 28.—(1) Despite section 27, a person does not infringe a registered trade mark when — (a) the person uses — (i) the person’s name or the name of the person’s place of business; or (ii) the name of the person’s predecessor in business or the name of the person’s predecessor’s place of business; (b) the person uses a sign to indicate — (i) the kind, quality, quantity, intended purpose, value, geographical origin or other characteristic of goods or services; or (ii) the time of production of goods or of the rendering of services; or (c) the person uses the trade mark to indicate the intended purpose of goods (in particular as accessories or spare parts) or services, and such use is in accordance with honest practices in industrial or commercial matters. Defences 28(2) Despite section 27, a person does not infringe a registered trade mark by using an unregistered trade mark that is identical with or similar to the registered trade mark in relation to goods or services identical with or similar to those for which the trade mark is registered if the person, or the person and the person’s predecessor in title, have continuously used in the course of trade the unregistered trade mark in relation to those goods or services from a time before — (a) the date of registration of the registered trade mark; or (b) the date the proprietor of the registered trade mark, or a predecessor in title, or a person who was a registered user of the trade mark under the repealed Act, first used the trade mark, whichever is the earlier. Defences 28(3) Despite section 27, a registered trade mark is not infringed by the use of another registered trade mark in relation to goods or services for which the latter is registered. 28(4) Despite section 27, a person who uses a registered trade mark does not infringe the trade mark if such use — (a) constitutes fair use in comparative commercial advertising or promotion; (b) is for a non-commercial purpose; or (c) is for the purpose of news reporting or news commentary. Summary Defences Section 28(1)(a) use of own name or place of business Section 28(1)(b) / (c) descriptive use Section 28(2) earlier use Section 28(3) registered mark Section 28(4)(a) fair use in comparative commercial advertising or promotion Section 28(4)(b) non-commercial use Section 28(4)(c) news reporting or news commentary Notice Copyright © 2024, Singapore Institute of Legal Education. 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