Judgments

Decision Information

Decision Content

T-5250-80
British American Bank Note Company Limited (Appellant)
v.
Bank of America National Trust and Saving Asso ciation, B A Cheque Corporation and B.A. Finan cial Services Limited' (Respondents)
Trial Division, Cattanach J. Ottawa, May 19,
June 2, 3, 4, 1982; March 2, 1983.
Trade marks Appeal from Registrar's decision refusing
registration of trade mark used in connection with highly specialized printing services — Registrar deciding mark undistinctive and confusing, given previous use by respondents of similar marks and names — First respondent's Canadian business mostly marketing travellers cheques — Whether appellant's mark confusing with mark or name previously used or made known in Canada by respondents — Applicant having unshifting onus of establishing right to registration and that confusion unlikely — Opponent alleging prior use must show trade reputation linked to potentially confusing mark — Opponent's responsibility may shift and therefore burden of proof — Trader cannot appropriate general words describing business for trade name — General words indicate objects but made distinctive by adding distinguishing feature — Appellant disclaiming all words in mark, leaving only letters Nonetheless must consider trade mark as whole re possibility
of confusion Opposition of second and third respondents negated because appellant's date of first use preceding com mencement of second's Canadian operations and incorporation of third — S. 29 requiring only simple statement regarding date of first use — Whether appellant's mark likely to pro duce inference appellant's services provided by same person supplying travellers cheques bearing first respondent's mark — "Weak mark" if consists only of letters — Should be given less protection — Small variations will prevent confusion — First respondent's allegedly confusing mark attenuated by subordination to other mark used concurrently — Cheques marketed among travelling public while appellant's highly specialized services supplied to certain groups who know appellant Appeal allowed Trade mark must be used for services of owner alone, even if another closely related - "Single organization" concept referred to by Angers J. in Good Humor case rejected, unless partnership — Trade Marks Act, R.S.C. 1970, c. T-10, ss. 2, 6, 16, 29, 37(2) (b), (c), (d), (9) (as am. by S.C. 1976-77, c. 28, s. 44), 49 — Trade Marks Regulations, C.R.C., c. 1559, Schedule II, Form 1.
' The foregoing spelling of the corporate names of the respondents has been adopted as being the most consistent usage but there are variations throughout the material.
Judicial review — Statutory appeals — Appeal from Regis trar's decision refusing registration of trade mark because undistinctive and confusing, given previous use by respondents of similar marks and names — Notwithstanding Act, Supreme Court in Rowntree establishing Federal Court may overturn Registrar's discretionary decision only if proceeded on wrong principle or unjudicially — Registrar's assessment of likeli hood of confusion adjudication on facts, not exercise of discre tion — Court therefore having authority to overrule — Appeal allowed — Trade Marks Act, R.S.C. 1970, c. T-10, ss. 2, 6, 16, 37(2)(b),(c),(d).
This was an appeal from the decision of the Registrar of Trade Marks, who rejected the appellant's application for registration of the trade mark THE B A BANK NOTE GROUP. The appellant was engaged in the business of printing highly specialized documents by a steel-engraving method. It was one of seven companies that constituted The B A Bank Note Group (the Group). Over the years, the appellant had marked the material which it had printed with several variants of its corporate name. There had been no real consistency in its use of these inscriptions; nonetheless, since January 1, 1973, it had used the mark in question as a trade mark, in connection with its printing services. The three respondents opposed the application for registration. The first of them, Bank of America National Trust and Saving Association (BANTSA), had been incorporated in the United States. It was the registered owner of a U.S. trade mark composed of the letters "BA" and of those letters in a stylized form, which trade mark appeared, together with other marks, on "Bankamerica" travellers cheques. The marketing of those cheques comprised the bulk, and perhaps the whole, of BANTSA's business in Canada, even though it described its objects as being those of a "full service national bank". The second respondent, B A Cheque Corporation (BACC), also incorporated in the United States, concerned itself with the "marketing, distributing and servicing" of the travellers cheques issued by BANTSA, but it did not engage in these activities in Canada until well into 1973. B.A. Financial Services Limited (BAFSL) was in the business of loaning money. It was incorporated in Quebec in 1974, and like BANTSA, it was a subsidiary of Bank American Corporation. The Registrar upheld the opposition on both of the grounds advanced by the respondents: namely, that the trade mark in question was not distinctive of the appellant's wares or services, given the respondents' previous use in Canada of similar, though unregistered, trade marks and trade names; and that the appellant was not the person entitled to registration, because the mark in question was confusing with the marks and names previously used by the respondents.
Held, the appeal should be allowed.
The key issue is whether the trade mark in question is confusing with a trade mark or trade name previously used or made known in Canada by the respondents. The appellant has asserted that when the opposition to an application for registra tion is based upon the previous use of a mark or name with which the applicant's mark is allegedly confusing, the opponent bears the onus of establishing a reputation in the trade in association with a mark that is of the same character as the applicant's mark. This view, however, is too simple. The appli cant incurs the responsibility of establishing his right to regis tration, and thus of showing that confusion is unlikely. This responsibility never shifts from the applicant; therefore, it is an onus. In contrast, the opponent who objects on the ground of prior use has only a burden of proof: he does have to establish a reputation linked to a potentially confusing mark, but this obligation may shift. The applicant may rebut the proof sub mitted by the opponent.
In choosing a corporate or trade name, no trader may appropriate for its exclusive use general words descriptive of the business in which it is involved. Words of that kind do serve to indicate the trader's purposes and objects; nevertheless, distinctiveness should be imparted to the name by supplement ing the general words with some distinguishing feature.
At the direction of the Registrar, the appellant disclaimed the words THE, BANK, NOTE and GROUP, because such words are in the public domain and are available to all traders. This leaves only the letters "B" and "A"; however, it is still the trade mark as a whole which must be considered in determining whether confusion with other trade marks might result.
In light of the date on which the appellant began to use its trade mark, the opposition of BACC and BAFSL cannot be maintained. BACC commenced its Canadian operations, and BAFSL was incorporated, only after that date. Consequently, their use in Canada of the trade names "B.A. Financial Ser vices Limited" and "B A Cheque Corporation" could not have occurred prior to the appellant's date of first use. The same would be true in regard to BACC's or BAFSL's use or making known of any trade mark incorporating the letters "B A". The officer who heard the application did raise a question as to the appellant's compliance with the section 29 requirements concerning date of first use; nonetheless, section 29 obliges an applicant to make only a simple statement in this regard, no verifying affidavit being necessary, and the appellant has pro vided the requisite statement.
With respect to the opposition of BANTSA, the issue in this case reduces to whether the appellant's trade mark, used in connection with its highly specialized printing services, is likely to produce the inference that those services are provided by the same person who supplies travellers cheques bearing the letters `BA".
A trade mark which consists only of letters of the alphabet, without the accompaniment of any distinguishing indicia, lacks inherent distinctiveness. It is a "weak mark", and should not be given protection as broad as that accorded a unique mark. Comparatively small variations from this weak mark will suf fice to prevent confusion, and the public may be expected to exercise a greater degree of discrimination with regard to such a mark.
On BANTSA's travellers cheques, the letters "BA", printed in pale yellow against a darker yellow, form part of a subdued background. They also appear in the borders and corners of the cheques, but in very small type. Other words dominate: "Bank- america Travelers Cheque" on some cheques; "Bank of Ameri- ca" on earlier issues. While the additional inscription "B of A Travelers Cheque" appears on one issue, this too is in type much smaller than that of the dominant words. The "BA" imprint is thus subordinated to the trade mark "Bankamerica", and such subordination to another mark which appears concur rently serves to attenuate the "BA" mark.
Furthermore, subsection 6(5) of the Act requires the Court to consider the nature of the services associated with the allegedly confusing trade marks. Thus, on the one hand, BANTSA's travellers cheques are marketed among a large group: that part of the general public which travels. On the other hand, the services provided by the appellant consist of highly specialized printing, and are supplied to certain groups of technicians and professionals, who know precisely with whom they are dealing.
Accordingly, the confusion objected to by BAFSL does not exist.
If the Court's decision turned upon a point which was a matter for the Registrar's discretion, its authority to overturn the ruling of the Registrar might be open to question. Although the Act says that the Court may exercise any discretion vested in the Registrar, the decision of the Supreme Court of Canada in Rowntree establishes that this Court may replace the Regis trar's view with its own only if, in exercising his discretion, the Registrar proceeded upon some wrong principle or failed to exercise his discretion judicially. However, the Registrar's assessment of the likelihood of confusion is an adjudication upon facts, not the exercise of a discretion. Hence the Court does have authority to overrule his judgment on that point.
The appellant must take great care to prevent its trade mark from losing its distinctive characteristics. A trade mark must be used to distinguish the services of its owner alone. The other six companies involved in the Group might become registered users of the trade mark, or they might have a contractual relation ship with the appellant whereby they solicit and perform print ing work on the appellant's behalf, but aside from such pos sibilities, the use of a trade mark with respect to the services of a company other than its owner constitutes infringement, even if the user is a subsidiary of, or otherwise closely related to, the owner. There is no place for the concept of a "single organiza tion", referred to by Angers J. in the Good Humor case, unless the seven companies in the Group have formed a partnership; however, if that were so, the partnership, not simply the appellant, would have applied for the registration.
CASES JUDICIALLY CONSIDERED
APPLIED:
Silhouette Products Limited v. Prodon Industries Ltd., [1965] 2 Ex.C.R. 500.
NOT FOLLOWED:
Good Humor Corporation of America v. Good Humor Food Products Limited et al., [1937] Ex.C.R. 61.
DISTINGUISHED:
Rowntree Company Limited v. Paulin Chambers Com pany Limited, [1968] S.C.R. 134.
CONSIDERED:
Re W & G du Cros Ltd.'s Application (1913), 30 R.P.C. 660 (H.L.); Benson & Hedges (Canada) Limited v. St. Regis Tobacco Corporation, [1969] S.C.R. 192.
REFERRED TO:
Office Cleaning Services, Ld. v. Westminster Window and General Cleaners, Ld. (1946), 63 R.P.C. 39 (H.L.), affirming (1944), 61 R.P.C. 133 (C.A.); Eno v. Dunn (1890), 15 App. Cas. 252 (H.L.).
COUNSEL:
P. D. Blanchard for appellant. R. D. Gould for respondents.
SOLICITORS:
Gowling & Henderson, Ottawa, for appellant. Smart & Biggar, Ottawa, for respondents.
The following are the reasons for judgment rendered in English by
CATTANACH J.: This is an appeal from a deci sion of the Registrar of Trade Marks, dated Sep- tember 18, 1980, the Registrar having acted through a member of an opposition board as he is authorized to do by subsection 37(9) of the Trade Marks Act, [R.S.C. 1970, c. T-10, as am. by S.C. 1976-77, c. 28, s. 44,] whereby the appellant's application for the registration of the trade mark THE B A BANK NOTE GROUP was refused.
In doing so the Registrar maintained the opposi tion thereto by the three respondents on the two fold grounds that:
(1) the trade mark applied for was not distinctive of the applicant's services, and
(2) the applicant (the appellant herein) was not the person entitled to registration of the trade mark.
That is an invocation by the Registrar of the grounds for opposition set out in paragraphs 37(2)(c) and (d) of the Trade Marks Act with overtones from paragraph 37(2)(b).
The opposition to the application for the regis tration before the Registrar was and still is on appeal: (1) that the trade mark is not distinctive of the appellant's wares or services because of the use of unregistered trade marks in Canada by one or more of the respondents and of trade names fea turing the letters of the alphabet "B" and "A" in that sequence as both unregistered trade marks and trade names; and (2) that the appellant is not the person entitled to registration because of such prior use by one or other of the respondents.
The basis of the ground of opposition in the second contention is that contained in section 16 of the Act.
By paragraphs 16(1)(a) and (c) an applicant for the registration of a trade mark that has been used or made known in Canada by the applicant or his predecessor in title in association with wares or services is entitled to registration of the trade mark in respect of such wares or services unless on the date of first use or making known of the trade mark it was confusing with:
(1) a trade mark that had been previously used in Canada or made known in Canada by any other person, or
(2) a trade name that had been previously used in Canada by any other person.
This second contention must also be read with the definition of "confusing" in section 2 of the Trade Marks Act which reads:
2....
"confusing" when applied as an adjective to a trade mark or trade name, means a trade mark or trade name the use of which would cause confusion in the manner and circum stances described in section 6;
Because of the inclusion in the definition of "confusing" of section 6 by reference, section 6 is reproduced in its entirety:
6. (1) For the purposes of this Act a trade mark or trade name is confusing with another trade mark or trade name if the use of such first mentioned trade mark or trade name would cause confusion with such last mentioned trade mark or trade name in the manner and circumstances described in this section.
(2) The use of a trade mark causes confusion with another trade mark if the use of both trade marks in the same area would be likely to lead to the inference that the wares or services associated with such trade marks are manufactured, sold, leased, hired or performed by the same person, whether or not such wares or services are of the same general class.
(3) The use of a trade mark causes confusion with a trade name if the use of both the trade mark and trade name in the same area would be likely to lead to the inference that the wares or services associated with the trade mark and those associated with the business carried on under such trade name are manufactured, sold, leased, hired or performed by the same person, whether or not such wares or services are of the same general class.
(4) The use of a trade name Causes confusion with a trade mark if the use of both the trade name and the trade mark in the same area would be likely to lead to the inference that the wares or services associated with the business carried on under such trade name and those associated with such trade mark are manufactured, sold, leased, hired or performed by the same person, whether or not such wares or services are of the same general class.
(5) In determining whether trade marks or trade names are confusing, the court or the Registrar, as the case may be, shall have regard to all the surrounding circumstances including
(a) the inherent distinctiveness of the trade marks or trade names and the extent to which they have become known;
(b) the length of time the trade marks or trade names have been in use;
(e) the nature of the wares, services or business;
(d) the nature of the trade; and
(e) the degree of resemblance between the trade marks or trade names in appearance or sound or in the ideas suggested by them.
Subsections 6(2) and 6(3) are pertinent in that confusion is caused between one trade mark and another and between a trade mark and a trade
name in both subsections if the use of both trade marks and a trade mark and a trade name
in the same area would be likely to lead to the inference that the wares or services associated [with such trade marks in the case of trade marks and in the case of a trade name the wares or services associated with the business carried on under the trade name] are manufactured, sold, leased, hired or performed by the same person, whether or not such wares or services are of the same general class.
I revert to the first contention that the trade mark sought to be registered by the appellant was not "distinctive" because of the use and making known of unregistered trade marks and trade names in Canada by the respondents as an objec tion to the appellant's application in the light of paragraph 37(2)(d), to which prior reference was made and which reads:
37....
(2) Such opposition may be based on any of the following grounds:
(d) that the trade mark is not distinctive.
Paragraph 37(2)(d) must be read in conjunction with the definition in section 2 of the Act which is as follows:
2....
"distinctive" in relation to a trade mark means a trade mark that actually distinguishes the wares or services in association with which it is used by its owner from the wares or services of others or is adapted so to distinguish them;
The appellant is a joint stock company incorpo rated by statute in 1866, a year prior to Confed eration in 1867, under the name of British Ameri- can Bank Note Company with head office at Montreal, Quebec and has been engaged in the printing of steel-engraved documents since that date.
The explanation of the selection of the name was that the engravers employed were citizens of the United States of America, popularly called
Americans even at that time, and the printers employed were of British Anglo-Saxon stock.
In 1909 the appellant company elected to become subject to the predecessor statute to the Canada Corporations Act, [R.S.C. 1970, c. C-32,] as if incorporated thereunder, and accordingly the corporate name became British American Bank Note Company Limited. The change was the addi tion of the concluding word "Limited" in full as part of the corporate name, the use of that word or alternatively its abbreviation "Ltd." being manda tory under the statute then in effect.
In corporate names the use of general words descriptive of the business in which the company is engaged cannot be monopolized by one trader just as is the case with trade marks. If such is done the protection offered to such a corporate or trade name is negligible. The general words descriptive of the business should be made distinctive by the use of a distinguishing feature (see Office Clean ing Services, Ld. v. Westminster Window and General Cleaners, Ld. (1946), 63 R.P.C. 39 [H.L.]).
But the use of general words descriptive of a business in conjunction with a distinguishing prefix serves as an indication of the purposes and objects for which a company so named has been incorpo rated to carry on.
Also indicative of the business in which the appellant is engaged are the wares and services with which the trade mark, THE B A BANK NOTE GROUP, is associated as set forth on the application for registration dated February 10, 1977, amended on December 7, 1977, and further amended on February 14, 1978. The services are therein described as follows:
Printing services, namely, the printing of currency, stock cer tificates, bonds, stamps, lottery tickets, debentures, annual reports, prospectuses, trust deeds, proxies and banking forms.
The corporate name and the services which the appellant provides are a clear indication of the business in which the appellant is engaged, that is to say the printing of highly specialized documents by a steel-engraving method to provide the utmost security in the resultant documents with every precaution taken to prevent counterfeiting and
ensure durability by the use of high-quality paper, as well as intricate design and the like.
On application for registration of the trade mark, THE B A BANK NOTE GROUP, the words THE, BANK, NOTE and GROUP were disclaimed at the direction of the Registrar because such words are in the public demesne to be available to all traders, leaving only the letters of the alphabet B and A as not being in that category.
While all words in the trade mark applied for have been disclaimed, nevertheless it is the trade mark, THE B A BANK NOTE GROUP, as a whole and in its entirety that must be considered in determin ing the possibility of confusion with other trade marks.
In the application dated February 10, 1977 for registration of this trade mark, the appellant stated that the mark "had been used in association with the services described therein," that is print ing services particularly the printing of currency, stock certificates, bonds, stamps, debentures and the like since January 1, 1973.
This date of first use is not made an issue in the pleadings but it was raised by the hearing officer of the opposition board in his reasons when he said "[the] applicant's [the appellant herein] own evi dence opens the question as to whether the appli cant has indeed satisfied the provisions of section 29 in respect of its date of first use".
By virtue of section 29 an applicant for registra tion of a trade mark shall file an application the content of which is specified in the section and in the form of application (Form 1) in the Trade Marks Regulations, [C.R.C., c. 1559, Schedule II]. All that is required is a statement that the trade mark "has been used" in association with the services provided since a date to be specified. That information is not required to be verified by affidavit.
That being so the applicant for registration would be entitled to registration of the trade mark applied for if registration were not precluded otherwise.
In the present instance registration as a matter of course is impeded by the opposition under sec tions 16 and 37 quoted above.
The issues so raised and in my view the crux of the present appeal is whether the trade mark, THE B A BANK NOTE GROUP, sought to be registered is confusing with a trade mark previously used or made known in Canada by the respondents or a trade name used by the respondents in Canada.
The appellant filed affidavit evidence which establishes a variety of devices used over its busi ness history to identify the source of its highly specialized printed material.
The letters "B A" were used on excise stamps printed in 1934 for use by the Federal government and die proofs on which the letters "B A B N" are displayed.
The words and letters "B A Bank Note Co." and "B A Bank Note" are printed on interest coupons attached to Government bonds on the face of which is printed the corporate name of the appellant, "British American Bank Note Company Limited" and the legend, "Printed in Canada B A Bank Note Ottawa".
Also used are such expressions as "Engraved B A Bank Note Co.", "BABN Co. Ltd." and "B A Bank Note Group".
This, at the most, demonstrates that over the years a plethora of variations of the appellant's corporate name designed in some way to identify the source of its printed material in an abbreviated form without real consistency other than the use of the letters "B A", `BABN" and the words "Bank Note" in conjunction with the letters "B A".
The respondent Bank of America National Trust and Savings Association was incorporated under the laws of the United States of America pertaining to national banking on November 30, 1930, with head office in San Francisco, Cali-
fornia, U.S.A. and is a wholly-owned subsidiary of Bank American Corporation.
The purposes and objects of this particular respondent are described as those of a "full service national bank" (whatever that means) in the State of California and other "specialized services" referred to, and with particular reference to Canada are the marketing of travellers cheques; 2 otherwise its activities are the provision of banking services which must, of necessity, be very special ized and limited in Canada.
The respondent B.A. Financial Services Limited is a joint stock company incorporated pursuant to the laws of the Province of Quebec by letters patent dated October 30, 1974. Having been so incorporated its head office must be situate in that province. It may have a place of business in other provinces. To swear that it has "a principal place of business" at 11 King Street West, Toronto, Ontario is a misapprehension of terminology by the affiant who applies foreign concepts to Canadi- an corporations.
Whatever purposes and objects this company has been authorized to carry on are those implicit in its corporate name, that is the business of supplying "financial services" to prospective customers.
It provides credit and loans to enterprises in need thereof in exchange for payment of interest on such loans.
This company is also a wholly-owned subsidiary of the Bank American Corporation which is the source of its funds to be laid out either on long or short terms.
The third respondent is B A Cheque Corpora tion, incorporated under the laws of the State of Delaware, one of the United States of America, on October 27, 1972. This respondent engaged in the business of "marketing, distributing and servicing of travellers cheques"—that is, those issued by the first respondent.
z Note the word "travellers" as it precedes the word "cheques" is so spelled to conform with the preferred spelling in this jurisdiction although in the specimen forms and other material filed by the respondents the version prevalent in the United States ("travelers cheques") is consistently used, except that in The Living Webster the words are spelled "traveler's cheques".
This respondent did not begin to "market, dis tribute and service" BANKAMERICA travellers cheques in Canada until well into 1973.
There is no question that the business engaged in by B.A. Financial Services Limited differs widely from that of the appellant, as too does the business engaged in by B A Cheque Corporation.
Despite this, accepting as I do the premise that the appellant first used the trade mark THE B A BANK NOTE GROUP on January 1, 1973 it follows that any use of the trade names "B.A. Financial Services Limited" and "B A Cheque Corpora tion", or use by these entities of the letters "B A" in a context other than in their trade names, was well subsequent to the use of the trade mark registration of which was applied for by the appellant.
Thus the trade names of those two respondents or any trade-mark use by them of the letters "B A" was not previous to the use by the appellant nor could any trade mark have been previously made known by them.
Therefore such use, being subsequent to that by the appellant, cannot constitute an obstacle to registration of the appellant's trade mark as con trary to section 16 of the Trade Marks Act.
There thus remains the opponent to the appel lant's application for registration of THE B A BANK NOTE GROUP as a trade mark, Bank of America National Trust and Savings Association, which conducts a "full service" banking business in the United States. Perhaps it conducts some interna tional banking business in Canada but the evi dence is overwhelming that its business in Canada is in travellers cheques which it markets through the branches of chartered banks across Canada in denominations of $10, $20, $50, $100, $500 and $1,000.
This respondent is the registered owner of the Canadian trade marks of BANK OF AMERICA and BANKAMERICARD.
The Registrar of Trade Marks in the reasons for his decision now under appeal said with respect to
these trade marks that he rejected the opposition based thereon:
... because there is nothing in the evidence to suggest any likelihood of confusion between the trade mark applied for and the registrations held by the opponents.
I am in complete agreement with the Registrar's conclusion in this respect and that finding by him has not been the subject of appeal.
The Bank of America National Trust and Sav ings Association is also the registered owner of a trade mark in the United States consisting of the letters "B A" and of those letters in a stylized form. It does not appear to be the registered owner of a trade mark of "B of A" but that device has been utilized by it upon its travellers cheques.
There have been introduced in evidence fac similes of BANKAMERICA travellers cheques mar keted in Canada by this respondent.
On the face of the instrument the words "BANKAMERICA TRAVELERS CHEQUE" predominate.
On prior issues, some of which are still in circu lation, the words BANK OF AMERICA predominate. This particular issue also displayed the words in much smaller type "B of A TRAVELERS CHEQUE".
Worked into the paper upon which the travellers cheques are printed, which is pale yellow in colour, are the letters "BA" in a design form printed in a darker yellow. This forms the subdued background and appears to me to be in the nature of water-marks.
In the borders and in the corners the design formed by the letters "BA" appears in very small type.
Of course this same device is also worked into the paper upon which the banking instruments essential to carrying on a full service bank, such as letters of credit and the like, are printed.
Counsel for the appellant has contended that when an opponent to the registration of a trade mark applied for relies on prior use of a trade
mark or trade name with which the mark applied for is confusing, the onus lies upon the opponent to establish a reputation in the trade in connection with a mark of the same character.
In my view that stark statement is much too simplified.
The onus is upon an applicant for the registra tion of a trade mark to establish his right thereto and that onus is constant upon him (see Eno v. Dunn (1890), 15 App. Cas. 252 [H.L.]) and that includes the onus of showing that confusion is unlikely.
But before an opponent can base an objection on prior use under section 16, the opponent must establish a reputation in the trade under a style with which confusion may result. That to me is not an onus but a burden of proof. An onus never shifts but a burden of proof does. The applicant may rebut the proof proffered by the opponent.
Shorn of all subtleties this appeal, in my view, falls to be determined upon the crucial issue whether the trade mark THE B A BANK NOTE GROUP applied for by the appellant for use in association with highly specialized printing ser vices would likely lead to the inference that those services are provided by the same person who supplies travellers cheques upon which the letters "BA" appear.
From Lord Shaw's decision, in Re W & G du Cros Ltd.'s Application (1913), 30 R.P.C. 660 [H.L.], a trade mark consisting only of letters of the alphabet, without any accompanying distinc tive indicia, is a trade mark that lacks inherent distinctiveness. Accordingly such a trade mark is characterized as a "weak mark".
In short, where a trader has appropriated letters of the alphabet and seeks to prevent others from doing the same thing, the range of protection to be
given that trader should be more limited than in the case of a unique trade mark and comparatively small differences are sufficient to avert confusion and a greater degree of discrimination may fairly be expected from the public in such instances (see remarks concerning trade names in Office Clean ing Services, Ld. v. Westminster Window and General Cleaners, Ld. (1944), 61 R.P.C. 133 [C.A.] at page 135).
The appellant's trade mark is THE B A BANK NOTE GROUP as contrasted with the use of the first-named respondent in the style of cause of the letters "BA", a design formed by these letters and "B of A" in rarer instances. All words in the appellant's trade mark have been disclaimed except the letters B A but that does not detract from the fact that the trade mark must be looked at in its entirety.
Added to this the use by the first-named respondent of the letters "BA" and in its stylized form upon travellers cheques, which constitute the bulk of its business in Canada, is issued in con junction with its trade mark BANKAMERICA in a very prominent position. The letters "BA" are used as background and as such fade into relative insignificance.
Noël J. has said in Silhouette Products Limited v. Prodon Industries Ltd., [1965] 2 Ex.C.R. 500, a trade mark is somewhat diluted and attenuated by simultaneous use, one of which is subservient to a more dominant trade mark. The use of "BA" is certainly subjected to the trade mark, BANK- AMERICA.
I have reproduced at the outset subsection 6(5) of the Trade Marks Act in which factors to which regard shall be had in determining if one trade mark is confusing with another are set out, para mount amongst which is the nature of the services and the business or trade.
Regard must be had to the class of services to which the trade mark is applied.
Bearing those considerations in mind the travellers cheques marketed by the first respondent
are directed to the travelling public at large and are widely available. The purchaser is one who is taking a trip and wishes to conserve his funds in a manner affording security to him.
On the other hand the appellant provides highly specialized printing services, currency for foreign governments, bonds, debentures, share certificates and like investment securities. Its services are sup plied to technical and professional people such as those floating issues of stocks and bonds. That being so those people know precisely with whom they are dealing and any risk of confusion is most remote.
It is for the foregoing reasons that I disagree with the conclusion reached by the member of the opposition board that the trade mark applied for by the appellant is confusing with the initials, "BA", as used by the first respondent.
In so concluding I do so on the authority of the decision of the Supreme Court of Canada in Benson & Hedges (Canada) Limited v. St. Regis Tobacco Corporation, [1969] S.C.R. 192, which is based upon the function the Registrar was per forming in the matter under review.
While the Trade Marks Act provides that on appeal the Court may exercise any discretion vested in the Registrar, Ritchie J. said in Rowntree Company Limited v. Paulin Chambers Company Limited, [[1968] S.C.R. 134,] that this is not to be taken as meaning that the Court is entitled to substitute its view for that of the Registrar unless it could be shown that he proceeded upon some wrong principle or that he failed to exercise his discretion judicially.
But when the Registrar arrives at a decision on the question of the likelihood of confusion he is deciding a question of fact and is exercising a function of adjudication and not of discretion.
In differing with the decision of the Registrar in this case I am differing from him on a point which is a matter of adjudication upon the facts and not a matter of the exercise of a discretion.
This being so the Supreme Court was unani mous in its decision that the appellate Court can substitute its judgment for that of the Registrar.
There was one matter which arose incidentally in the course of the hearing and upon which I did not have a full factual explanation nor argument thereon.
In a brochure appended to an affidavit THE B A BANK NOTE GROUP was described as consisting of seven corporate entities listed as follows:
1. British American Bank Note Company Limited (the appellant herein and the applicant for the registration of that trade mark),
2. Atlantic Banknote Limited,
3. Yvon Boulanger Limited,
4. The Franklin Press Limited,
5. Winnipeg Banknote Company Limited,
6. Alberta Security Printing, and
7. Security Printing Corporation Ltd.
In my view a trade mark must be used only to distinguish the services of the owner of the trade mark and it is infringement to use it for the services of a closely related company, even the subsidiary of the registered owner of the trade mark.
It is possible that should the appellant become the registered owner of the trade mark the other six companies might become registered users thereof under section 49 of the Trade Marks Act provided always that they qualify to do so.
It may also be that the six other companies have entered into a contractual relationship with the appellant to solicit printing business on its behalf and perhaps to accept on a farm-out basis that printing obtained by the appellant which it cannot fulfil itself.
I do not accept the concept of a "single organi zation" such as conceived by Angers J. in the Good Humor case [Good Humor Corporation of America v. Good Humor Food Products Limited
et al.] [1937] Ex.C.R. 61 (at page 74) unless there is a partnership of all seven companies in the Group in which instance the partnership would be the applicant for registration and not the appellant.
I mention this matter in passing to alert the appellant to the extreme care to be exercised to prevent the trade mark from losing its distinctive characteristics essential to a valid trade mark, a matter I am not called upon to decide nor do I decide.
For the foregoing reasons the appeal is allowed and the appellant shall be entitled to its taxable costs.
 You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.