The text below represents commentary, not legal advice.

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Published in the Intellectual Property Law Newsletter, vol. 18 (no. 4) (Summer 2000), p. 7, by the Section of Intellectual Property Law of the American Bar Association. Copyright © Paul Edward Geller 2000.  Note that the Brussels Convention referenced below has been superseded, in most E.U. member states, by Council Regulation (EC) No. 44/2001.

Mastering Conflicts of Laws in
Intellectual Property Litigation

 

Paul Edward Geller

          Conflicts of laws arise more frequently in the field of intellectual property as works, trademarks, and inventions are increasingly exploited across borders. This article will sketch out a framework of analysis for dealing with the ambivalent conflicts rulings that have been arising in cross-border cases. This framework is only intended to sharpen issues and to suggest useful analyses for reaching some solutions.
 

Jurisdictional versus Conflicts Issues
 

          In cross-border cases, claimants shop for forums. The law of the court which a claimant addresses, that is, forum law, will determine its jurisdiction, its approach to conflicts of laws, and its remedies. Jurisdictional and conflicts issues often overlap in that the law applicable to a case upon the resolution of a conflict may form a ground of jurisdiction. For example, there is pressure to plead infringement of federal rights inside the United States because, if a federal law of intellectual property applies to a case, then a federal district court will have jurisdiction.(1)

          In a cross-border case, there might be infringement in other countries, subject to treaties and foreign laws. For example, a claimant from one country might have to invoke the Berne or Paris Convention, or the TRIPs Agreement, to justify a claim under the copyright, trademark, or patent law of another country. Note that, in most countries outside the British and Scandinavian traditions, the provisions of an intellectual property treaty may be largely self-executing and form the basis for a foreigner's claim as if the provisions were part and parcel of domestic law. U.S. federal courts have, however, been reluctant to take jurisdiction over a case just because such a treaty is invoked, even though federal jurisdiction lies for a case arising under a U.S. treaty, in which the federal courts do have special expertise and concerns.(2)

          Analytically speaking, pleading foreign law before a U.S. court need not undermine federal jurisdiction. There may be a self-standing basis for federal jurisdiction: for example, on the basis of diversity, a U.S. federal court may consider claims of infringement taking place abroad and arising under foreign laws.(3) Similarly, where a composer alleged infringement by a recording of his song exploited in interrelated transactions worldwide, his claim of infringement taking place in the United States provided a basis for federal jurisdiction, "potentially allowing the Court to exercise pendent jurisdiction over claims arising under foreign law."(4) That said, some U.S. courts might find a pretext in the doctrine of forum non conveniens for clearing their calendars of cases largely based on foreign laws.(5)

          In some cross-border cases, it may be appropriate to consider suing in a foreign court, for example, to strike more quickly with an injunction on the spot where infringement occurs abroad. However, jurisdictional and conflicts analyses may differ abroad: most notably, the Brussels or Lugano Convention will apply in most European cases. These conventions may affect the availability of injunctions enforceable in the forum country or across European borders,(6) as well as jurisdiction to award damages arising in the forum country or in other European countries.(7)
 

The Basic Conflicts Rule
 

          To focus on conflicts exclusively, assume that a U.S. federal district court takes jurisdiction over an entire cross-border case. How should it resolve conflicts of laws that typically arise in such cases? The Second Restatement of Conflict of Laws provides a framework from which to start analysis in most states.(8) In its basic provision, it gives "the needs of the interstate and international systems" as the first criterion to consider in resolving conflicts where no statutory directive dictates a solution.(9) Here lies the key to resolving conflicts in the field of intellectual property, where the critical "international system" is that established by the Berne and Paris Conventions and now integrated into the TRIPs Agreement.

          In this international system, the basic principle is national treatment.(10) The default position of national claimants is simple: domestic law governs their claims against infringement at home. National treatment then requires applying such domestic laws to foreigners' claims as apply in the countries where protection is sought, that is, where infringement takes place. The Second Circuit, in Itar-Tass, has equivocated on this reasoning in opining that "Russian law determines the ownership and essential nature of the copyrights alleged to have been infringed" in the United States.(11) Following this misleading dictum in Itar-Tass, the Southern District of New York, in Bridgeman, ruled one way and then another, but ultimately granted national treatment in applying U.S. law to determine whether copyright existed and was infringed in a British work in the United States.(12) Thus, whatever vacillation the courts may display, the basic principle normally results in resolving infringement issues by applying the law of the country on whose territory infringement takes place.(13)

          Courts have a pair of ways, however, to shrink or to stretch territoriality itself. First, courts may localize infringement by referring to definitions of infringing acts that intellectual property statutes set out but that can prove to be elastic. For example, U.S. courts have construed infringement narrowly in finding it in so-called completed acts that consummate transactions in single countries or broadly in finding it in acts that stretch across transactions crossing borders.(14) Second, courts sometimes step outside the bounds of statutory and treaty provisions by creating exceptions that allow them to apply domestic laws extraterritorially to clearly foreign acts. As we shall see, U.S. courts sometimes justify such exceptions by invoking policies that do not obviously meet the Restatement criterion of "the needs of the interstate and international systems."(15)

          To sort out the cases and policies, it will prove useful to distinguish between incoming and outgoing transactions relative to any given country. This might be only one country, often the forum country, although it need not be; indeed, infringement may sometimes be colorably alleged as taking place in a number of countries at once, and this distinction may be applied to each country. In an incoming transaction, preparatory or contributory acts take place abroad in a foreign source country or countries and the ultimate exploiting acts occur in the marketplace of the country in question. For example, authorization is given abroad, infringing copies or products are made abroad, or infringing signals transmitted from abroad, but the infringing materials are marketed or used in the country in question. In an outgoing transaction, such preparatory or contributory acts take place in the country in question and marketing or use occurs abroad.(16)

          There is some worldwide consensus that, in the case of an incoming transaction, the court should apply the law of the country whose market is targeted by the infringement at issue.(17) For example, in Subafilms, the Ninth Circuit en banc considered a two-million dollar award, about half attributable to foreign marketing, and half to domestic marketing, of the Beatles' Yellow Submarine.(18) Invoking "the international regime for protecting intellectual property," the Ninth Circuit held that U.S. copyright law could not support the award relative to marketing abroad just by virtue of authorization at home.(19)

          This approach leaves open a gut issue in cross-border cases: Should this basic rule be expanded? Will an outgoing transaction also support applying domestic law? Should it suffice for infringing materials to be made in a given country, or infringing signals sent out from there, for its domestic law to apply? It will first be argued that the basic rule should not generally be expanded, or exceptions made to it, for purposes of imposing compensatory monetary liability. Then arguable exceptions will be considered, largely at the level of injunctions.
 

When the Basic Rule Generally Applies
 

          Consider, for example, the facts in the L.A. News case:(20) First, in Los Angeles, the L.A. News Service took videos of the riots of 1992. Second, there, the L.A. News Service licensed N.B.C. to televise these videos, but with a restriction to the United States. Third, N.B.C. transmitted its show with the video footage to Reuters-related parties in New York. Fourth, some of these parties in New York made hard copies of that footage. Fifth, it was retransmitted via cable or satellite across the Atlantic. Sixth, it was televised abroad, notably in Europe.(21)

          The infringing transaction here was outgoing relative to the United States insofar as it targeted the European market. Hence the issue: To what extent should the transaction suffice to support applying U.S. law? Or would only European laws apply to it? Regarding monetary awards, the lower and higher courts differed. The district court finally awarded statutory damages under U.S. law for unconsented copying in New York City.(22) But it seemed to follow Subafilms when it refused to make any further monetary award for foreign reception, stating that plaintiff "can seek a remedy for this infringement under the applicable foreign law."(23) On appeal, the Ninth Circuit reversed the refusal by the trial court in L.A. News to grant any further monetary relief and rather applied the old Sheldon line of precedents based on equitable considerations.(24) Sheldon had applied U.S. law to impose a constructive trust on money earned from foreign exploitation of copies made at home.(25)

          The Sheldon precedents are not consistent with the Restatement criterion, "the needs of the interstate and international systems." Given the same set of facts of cross-border infringement, these precedents invite a court on one side of a given border to apply its own law, not only to exploitation at home, but as the basis for compensating claims for exploitation abroad, even though a court on the other side of the border may well apply its law to just such claims as arise in its own jurisdiction. For example, in the case of an infringing book published in Canada but sold in the United States, a Canadian court, applying only Canadian copyright law and rejecting U.S. law on various issues, awarded profit shares deriving, not only from Canadian sales, but from U.S. sales as well.(26) By contrast, on these facts, a U.S. court could have applied U.S. law, at least to U.S. sales, possibly reaching a different result with regard to compensatory liability for these sales. Precedents extending copyright laws, each made for a domestic market, to serve as bases for compensating losses in other markets, thus risk aggravating tensions with other laws. As a result, such case law tends to undercut the international system.(27)

          Furthermore, the consensus for applying the law of the country with the targeted market corresponds to business practice. Attributing monetary liability under that law, at least to impose compensatory damages, best corresponds to the foreseeable risks of marketing in that country, since enterprises normally consult that country's law before entering its market. In addition, if such monetary liability were imposed under the laws of source countries for infringing materials, rather than laws of countries with the targeted markets, then enterprises would seek to operate from countries with the lowest levels of protection, effectively from pirate havens.

          This argument might not always hold for statutory or treble damages. The TRIPs Agreement generally contemplates such "remedies which constitute a deterrent to further infringements."(28) Given the global vocation of the TRIPs Agreement, its provisions would inform the Restatement criterion of "the needs of the interstate and international systems," including the rationale of fighting cross-border piracy. On that premise, purely deterrent relief under forum law, statutory or treble damages in appropriate U.S. cases,(29) could arguably apply to outgoing transactions that target markets abroad.
 

Exceptions at the Level of Injunctions
 

          Vary the facts of L.A. News. Suppose that the claimant discovered that its videos had just found their way into the hands of another party whose business it was to market works in Europe. What law or laws would have provided bases for enjoining that party's exploitation in Europe? There is authority for enjoining acts that, in one country, prepare or contribute to exploitation in another country, but only on the basis of the law of the country of ultimate exploitation. For example, if infringing copies or products are made abroad, say, in some pirate haven, U.S. law may support enjoining marketing in the United States.(30) On that basis, European laws would have to be applied to enjoin transmission of L.A. News footage from the United States to Europe.(31) How many of such laws should suffice as the basis for enjoining the transaction? Could the U.S. court, for which this was an outgoing transaction, apply U.S. law to enjoin it?

          Before answering, consider a more complex case. This was a domain-name case, in which infringement was potentially as worldwide as the web. In the 1980s, Playboy had the Italian magazine Playmen enjoined from infringing its trademark by using the title Playmen in the United States.(32) In the 1990s, after registering this title as a trademark in Italy, the Italian publisher set up a Playmen website in Italy, which marketed graphic materials competitive with Playboy's in the United States. Upon a hearing to enforce the prior judgment, the Southern District of New York issued the following order in the alternative: either stop access to U.S. end-users or shut the website down worldwide.(33) Under the facts, although not the law of the case, the transactions were incoming, not only relative to the United States, but to other countries where Playboy had succeeded in asserting its mark against Playmen, notably England, France, and Germany. Arguably, the threat of unlicensed reception in other large markets would support an injunction beyond U.S. territory, at least in these markets if not more broadly. However, the basic rule would still require pleading laws reigning in foreign markets. But how many laws?

          Go back to our hypothetical based on L.A. News. Suppose the claimant knew that the videos were to be transmitted abroad but did not know where they were headed. Under the basic rule, the claimant would have to plead the laws of a multiplicity of possibly receiving countries. The claimant might try to lighten its burden by citing the Restatement criterion, "the needs of the interstate and international systems," which would buttress any argument for an injunction. One such need is to nip piracy in the bud before it spreads to other countries: for example, the TRIPs Agreement provides for seizing infringing goods at borders on the basis of domestic law irrespective of where the goods are going.(34) Thus, invoking the need to fight piracy globally, the claimant could appeal to the court's equitable discretion in pleading, as a basis for an injunction, impending infringement under the laws of a few countries with major markets, such as were targeted in Playmen. Effectively, the claimant would be arguing that, to obtain a preliminary injunction rapidly with global impact, it should suffice for it to make its case relative to infringement in the lion's share of the global marketplace that the laws of a few countries cover. A much more daring argument would invoke the need to fight global piracy as the policy grounds for applying forum law alone as a sufficient basis for enjoining a global pattern of infringement originating in the forum jurisdiction.(35)
 

Further Anomalies
 

          Trademark case law, however, does not fall neatly within this framework. If a foreign transaction, say, in Mexico or Canada, has requisite effects in the United States, U.S. courts may apply our trademark law to find the transaction infringing, although the circuits apply the "effects" test somewhat differently.(36) This case law deviates from the territorial approach followed in other fields of intellectual property: for example, in one case, U.S. trademark law was applied to sales of sport shoes in Canada because of tenuous effects in the United States, but U.S. design patents were not applicable to the same transactions.(37)

          In a seminal case, the claimant had a combination patent on a shrimp-cleaning device. At issue was a kit of pieces that, once assembled, constituted the device, but the kit made in the United States was only marketed abroad. The U.S. Supreme Court precluded liability under U.S. patent law for lack of a completed act of infringement in the United States, but the U.S. Patent Act was then amended to overrule this decision.(38) A comparable case arose in Germany, where it was held infringing to offer such almost-ready, German-patented devices for sale in Germany, even if only for export.(39) Now, the TRIPs amendments have put such "offering" language into the U.S. Patent Act, but case law is only beginning to crystallize on point.(40)
 

Conclusion
 

          Clearly, the case law is ambivalent. In copyright, Subafilms precludes applying U.S. law as a basis for monetary liability for exploitation abroad, but L.A. News relies on a questionable judge-made exception. More dramatically, U.S. trademarks are applied extraterritorially, albeit in case law far from consistent from circuit to circuit, while patents are applied with strict territoriality, save for a few statutory exceptions. For now, it seems advisable to consider pleading both U.S. and foreign laws, sometimes in the alternative, in many cross-border cases. Such pleading has to be appropriate and artful for various reasons, most notably to assure jurisdiction and to forestall any motion to dismiss for forum non conveniens. In any event, the Restatement criterion of "the needs of the interstate and international systems" may best guide conflicts analysis.(41)
 

1. 28 U.S.C. § 1338 (2000).

2. 28 U.S.C. § 1331 (2000). See, e.g., Peter Starr Production Co. v. Twin Continental Films, 783 F.2d 1440, 1443 n.3 (9th Cir. 1986) (mooting attempt to base jurisdiction over the case as arising under U.C.C.); De Bardossy v. Puski, 763 F. Supp. 1239, 1245-46 (S.D.N.Y. 1991) (rejecting such an attempt upon failure to argue federal concerns).

3. 28 U.S.C. § 1332 (2000). See, e.g., London Film Productions Ltd. v. Intercontinental Communications, Inc., 580 F. Supp. 47, 50 (S.D.N.Y. 1984) (exercising diversity jurisdiction over claims for acts of infringement that were alleged to have taken place only in Latin America).

4. Armstrong v. Virgin Records, Ltd., 91 F. Supp. 2d 628, 630-31, 635-38 (S.D.N.Y. 2000) (holding that foreign parties may be held contributorily or vicariously liable for direct infringement in the U.S., predicating pendent jurisdiction over infringement abroad on such infringement at home, and noting diversity as among the parties in any event).

5. Compare Boosey & Hawkes Music Publ., Ltd., v. Walt Disney Co., 145 F.3d 481, 492 (2d Cir. 1998) ("While reluctance to apply foreign law is a valid factor favoring dismissal . . . . District courts must weigh this factor along with the other relevant considerations."), with World Film Services, Inc. v. RAI Radiotelevisione Italiana S.p.A., 50 U.S.P.Q.2d 1187 (S.D.N.Y. 1999) (refusing to dismiss claims that "arise under both U.S. and Italian intellectual property law," while noting that "[t]here is no reason to believe that this Court will be unable to apply Italian copyright law as necessary").

6. See generally Christopher Wadlow, Enforcement of Intellectual Property in European and International Law 14-44, 141-49 (1998) (analyzing conditions on which Brussels Convention, in article 24, allows for provisional, cross-border injunctions).

7. See, e.g., Shevill v. Presse Alliance S.A., E.C. Court of Justice, March 7, 1995, Case C-68/93, [1995] All E.R. (EC) 289 (holding that, in action for defamation by a French newspaper distributed in several countries, French court would have jurisdiction to award damages incurred in all these countries, while each court in each of these other countries would have jurisdiction only relative to damages in the country where it sits); Wegman c. Sté. Elsevier Science, Cass. Civ. I (Supreme Court, France), July 16, 1997, 176 Rev. Int'le du Droit d'Auteur 403 (1998) (holding that, where U.K. defendant starts publication, Brussels Convention allows for jurisdiction in France over infringement only to the extent of damages in France).

8. See generally Klaxon Co. v. Stentor Electric Manufacturing Co. of North America, 313 U.S. 487 (1941) (applying, in diversity case, conflicts law of forum state).

9. 1 American Law Institute, Restatement (Second) of Conflict of Laws, § 6(2)(a) (1971).

10. See Berne Convention for the Protection of Literary and Artistic Works, Sept. 9, 1886, as last revised at Paris, July 24, 1971, art. 5, 828 U.N.T.S. 221; Paris Convention for the Protection of Industrial Property, March 20, 1883, as last revised at Stockholm, July 14, 1967, arts. 2-3, 21 U.S.T. 1583, 828 U.N.T.S. 305; Agreement on Trade-Related Aspects of Intellectual Property Rights, including Trade in Counterfeit Goods, April 15, 1994, art. 3, in Marrakesh Agreement Establishing the World Trade Organization, Annex 1C, Legal Instruments-Results of the Uruguay Round vol. 31, 33 I.L.M. 81 (1994) [hereinafter TRIPs Agreement].

11. Itar-Tass Russian News Agency v. Russian Kurier, Inc., 153 F.3d 82, 84 (2d Cir. 1998). The quoted assertion was dictum here in that it was not necessary to resolve the critical issue of standing. This writer further questions whether, as the Second Circuit seemed to think, standing necessarily turns on ownership and the law of the country of origin should necessarily determine ownership. For these considerations, somewhat tangential to the present analysis, see Paul Edward Geller, International Copyright: An Introduction, §§ 6[2]-6[3] [hereinafter Geller, Introduction], in 1 International Copyright Law and Practice, INT-221 to INT-253 passim (Paul Edward Geller & Melville B. Nimmer eds., 2001).

12. See Bridgeman Art Library, Ltd., v. Corel Corp., 25 F. Supp. 2d 421, reconsidered, 36 F. Supp. 2d 191 (S.D.N.Y. 1999). Both the Itar-Tass and Bridgeman courts erred in invoking section 104(c) of the U.S. Copyright Act, which purports to preclude Berne self-execution. As the Bridgeman Court finally seems to have realized (id. at 195-196), that provision simply compels applying U.S. copyright law, that is, national treatment, to Berne works within the United States.

13. See, e.g., Shaw v. Rizzoli Int'l Pubs., Inc., 51 U.S.P.Q.2d 1097 (S.D.N.Y. 1999) (citing Itar-Tass, disentangling ownership from infringement issues, and applying U.S. law to alleged U.S. infringement).

14. Compare Allarcom Pay Television Ltd. v. General Instrument Corp., 69 F.3d 381, 387 (9th Cir. 1995) (holding that U.S. law copyright does not apply to the unauthorized unscrambling of satellite transmissions only received in Canada), with National Football League v. Primetime 24 Joint Venture, 50 U.S.P.Q.2d 1461 (S.D.N.Y. 1999) (localizing capture and retransmission of signals in the U.S. as infringing acts, even though reception only takes place in Canada). Cf. Quantitative Financial Software, Ltd. v. Infinity Financial Technology, Inc., 47 U.S.P.Q.2d 1764 (S.D.N.Y. 1998) (refusing to localize infringement in the U.S. where a foreign software module "will control huge volumes of trades" in New York City).

15. See infra text accompanying notes 24-27 and 36-37.

16. Of course, a court may resort to its own notions of contributory or vicarious liability in analyzing a cross-border transaction. See, e.g., Metzke v. May Dep't Stores Co., 878 F. Supp. 756, 760-62 (W.D. Pa. 1995) (raising issue whether a party is contributorily liable under U.S. law for having had infringing copies made in Taiwan with scienter that such copies might be sold in the U.S.). However, at the threshold of inquiry, where the court is merely localizing infringing acts prior to resolving conflicts, the law or laws applicable to liability issues as such are not yet determined.

17. See generally Geller, Introduction, supra note 11, § 3[1][b], at INT-47 to INT-61 passim (elaborating frame of analysis).

18. Subafilms, Ltd. v. MGM-Pathe Communications Co., 24 F.3d 1088 (9th Cir. 1994), cert. denied, 513 U.S. 1001 (1994).

19. Id., 24 F.3d at 1097-99.

20. Los Angeles News Service v. Reuters Television Int'l, 942 F. Supp. 1265, concl., 942 F. Supp. 1275 (C.D. Cal. 1996), rev'd, 149 F.3d 987 (9th Cir. 1998), cert. denied, 119 S. Ct. 1032 (1999).

21. There was a companion case, in which the L.A. News Service sued a Canadian broadcaster for spill-over into the United States: Los Angeles News Service v. Conus Communications Co., 969 F. Supp. 579 (C.D. Cal. 1996).

22. Los Angeles News Service v. Reuters, 942 F. Supp. at 1282-83.

23. Id., 942 F. Supp. at 1269.

24. Id., 149 F.3d at 991-93.

25. See Sheldon v. Metro-Goldwyn Pictures Corp., 106 F.2d 45, 52 (2d Cir. 1939); also Update Art v. Modiin Publ., 843 F.2d 67, 73 (2d Cir. 1988) (following Sheldon).

26. Hager v. ECW Press Ltd., 85 C.P.R. (3d) 289 (1998).

27. It is therefore at best ingenuous to justify reliance on the Sheldon precedents by stating: "Were it otherwise in a global marketplace, our [emphasis added] copyright laws would be pointless." Richard Feiner & Co. v. Turner Entertainment Co., 47 U.S.P.Q.2d 1539 (S.D.N.Y. 1998). There are other copyright laws elsewhere, not to mention the international treaties.

28. TRIPs Agreement, supra note 10, art. 41(1).

29. See, e.g., 17 U.S.C. § 504(c)(2) (2000) (copyright); 15 U.S.C. § 1117(b), (c)(2) (2000) (trademark); 35 U.S.C. § 284 (2000) (patent).

30. See, e.g., Spindelfabrik Suessen-Schurr v. Schubert & Salzer, 903 F.2d 1568, 1577-78 (Fed. Cir. 1990) (enjoining preparatory acts in Germany "for use" that would infringe patent in U.S.); The Doors case, Feb. 18, 1993, BGH (Federal Court, Germany), 1993 GRUR Int. 699, excerpts translated in 26 Int'l Rev. Indus. Prop. & Copyright L. [I.I.C.] 305 (1995) (confirming application of German law as basis of injunction against the importation of sound recordings legally fabricated abroad).

31. Note that this analysis may change in the E.C. See, e.g., Council Directive 93/83/EEC of 27 September 1993 on the coordination of certain rules concerning copyright and rights related to copyright applicable to satellite broadcasting and cable retransmission, recitals 9-15 and art. 1.2, 1993 O.J. (L 248/15) 15, 16, 18 (localizing satellite-relayed broadcasts in E.C. countries from which uplinking takes place, but conditioning this approach with safeguard rules).

32. Playboy Enterprises, Inc. v. Chuckleberry Publ. Inc., 687 F.2d 563 (2d Cir. 1982).

33. Id., 939 F. Supp. 1032 (S.D.N.Y. 1996).

34. TRIPs Agreement, supra note 10, arts. 51-60.

35. Cf. Mike Curb v. MCA Records, Inc., 898 F. Supp. 586, 593-96 (M.D. Tenn. 1995) (refusing to ignore acts in the U.S. initiating infringement abroad because of the need to control cross-border infringement, but reserving judgment on choice of laws); also 17 U.S.C. § 512(j)(1)(B)(ii) (2000) (empowering U.S. courts to block access from off-shore, but without expressly predicating any showing that U.S. audiences access the materials at issue).

36. Compare Sterling Drug, Inc. v. Bayer, 14 F.3d 733, 744-48 (2d Cir., 1994) (applying narrow test to guide tailoring an injunction of trademark use outside the U.S.), with Reebok Int'l, Ltd. v. Marnatech Enter., Inc., 970 F.2d 552, 553-57 (9th Cir. 1992) (applying broad test to effects of Mexican transactions and applying U.S. trademark law). See generally Curtis A. Bradley, Territorial Intellectual Property Rights in an Age of Globalism, 37 Va. J. Int'l L. 505 (1997) (reviewing and critiquing application of U.S. trademark law to foreign transactions).

37. Aerogroup Int'l, Inc. v. Marlboro Footworks, Ltd., 955 F. Supp. 220, 229-32 (S.D.N.Y. 1997), aff'd per curiam, 1998 U.S. App. LEXIS 7733 (2d Cir. Apr. 13, 1998) (Gajarsa, J., dissenting with regard to the extraterritorial application of trademark law in the case), cert. denied, 525 U.S. 948 (1998).

38. Deepsouth Packing Co., Inc. v. Laitrem Corp., 406 U.S. 518 (1972). See 35 U.S.C. § 271(f) (2000). Cf. Johns Hopkins Univ. v. CellPro, Inc., 152 F.3d 1342, 1367 (Fed. Cir. 1998) (citing Deepsouth while vacating portions of order to repatriate exported substances absent showing that the substances abroad would contribute to patent infringement in the U.S.).

39. Cross-Seamed Sacks case, BGH, March 29, 1960, 1960 GRUR 423, commented and partially translated by Dieter Stauder, Patent Infringement in Export Trade, 3 I.I.C. 491 (1972).

40. 35 U.S.C. § 271(a) (2000). Compare 3D Systems, Inc. v. Aarotech Laboratories, Inc., 160 F.3d 1373, 1378-79 (Fed. Cir. 1998) (finding offer in the sending of price quotes to California residents), with Rotec Industries, Inc. v. Mitsubishi Corp., 36 F. Supp. 2d 810, 815-18 (C.D. Ill. 1998), aff'd, 2000 U.S. App. LEXIS 13563 (Fed. Cir. June 13, 2000) (distinguishing 3D Systems because offer at issue was completed abroad). Cf. Halmar Robicon Group v. Toshiba Int'l Corp., 53 U.S.P.Q.2d 1501 (W.D. Pa. 1999) (distinguishing some offers as taking inside, and some outside, the U.S.).

41. For the theoretical basis of the foregoing analysis, see Paul Edward Geller, International Intellectual Property, Conflicts of Laws, and Internet Remedies, 22 Euro. Intell. Prop. Rev. 125 (2000).