DHL Corporation and Subsidiaries - Page 165

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          contracts entered into by DHL and DHLI were still enforceable, as           
          between them.                                                               
               Petitioners take a different tack from respondent’s approach           
          by arguing that the arrangement between DHL and DHLI would not              
          meet the applicable section 482 regulations so as to require                
          reallocation as to that intangible asset.  Petitioners also argue           
          that, as a matter of law, trademark rights exist separately in              
          each country of registration and DHLI acquired the rights by                
          registration and use.  If we decide that DHL owned the worldwide            
          rights to the trademark, petitioners argue that they should be              
          allowed a setoff equal to the value of assistance or cost borne             
          by DHLI in developing the trademark rights outside the United               
          States.  The parties provided four well-qualified experts on                
          trademark law.                                                              
               Respondent’s expert on trademark ownership is a practicing             
          lawyer with 30 years’ experience, including litigation, in                  
          intellectual property law, specializing in trademarks and unfair            
          competition.  He concluded that, with the possible exception of             
          certain Central American countries, the agreements between DHL              
          and DHLI established DHL as the owner of the trademark rights.              
          His interpretation of the 1974 MOA and related agreements is that           
          they give DHL the ownership in the trade name and trademark, in             
          particular because DHLI could not assign the foreign                        
          registrations without DHL’s consent and because of DHLI’s                   
          obligation to cease use everywhere for 5 years upon termination             




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