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[Trademark] 2024 (Gyo-Ke) 10055, “Shifuku no Girisha” (Blissful Greece) <Hibiku Shimizu> (Plaintiff: Hellenic Republic)

3 日前
読了時間: 2分

更新日:2 日前


Article information

Article type: Case note

Category: Trademarks

Topics: —

First published on this website: 2026-11-01

Display and classification checked: November 2, 2026


Originally published on Ameblo: 2025-07-01 (Japan time). Full English translation.

[Trademark] 2024 (Gyo-Ke) 10055, “Shifuku no Girisha” (Blissful Greece) <Hibiku Shimizu> (Plaintiff: Hellenic Republic)

*“Shifuku no Girisha” (Blissful Greece) is not understood as being limited or specifically confined to “produced in Greece.”

⇒ No violation of Article 3(1)(iii) of the Trademark Act or the other provisions at issue.

(Excerpt from the court's reasoning)

 The trademark at issue combines the words “shifuku no” (blissful) with “Girisha” (Greece), … and is found to convey a single coherent meaning along the lines of “Greece, a country of unsurpassed happiness.” It therefore calls to consumers' minds the country or region of Greece itself together with the positive image conveyed by “blissful,” and projects that image onto the designated goods at issue, namely yogurt. Unlike a trademark consisting solely of “Greece,” it does not descriptively indicate a place of production or sale. Rather, it merely uses an abstract image associated with the country or region of Greece to indicate that the goods are connected with Greece in some way. That connection is not confined to a place of production or sale, and the mark cannot be regarded as indicating “Greece” as the place of production or sale. Neither the actual circumstances of trade in yogurt, which encompasses the designated goods, nor the Internet search results for “Shifuku no Girisha” … provide sufficient evidence that “Shifuku no Girisha,” or similar signs combining words such as “blissful” with the name of a country or region, are generally used to indicate the place of production or sale or other characteristics of goods. The examples cited by the plaintiff, such as “Blissful Hawaii” and “Blissful America,” … are used in articles and advertisements introducing overseas travel or overseas real estate as expressions referring to the country or region itself, and are not examples of indications identifying the place of production of particular goods. Accordingly, the trademark at issue cannot be described as a “trademark consisting solely of a sign indicating, in a commonly used manner, the place of production, place of sale, or other characteristics of the goods.” …



Update history

The first-published date remains unchanged. Display maintenance, classification changes, related-article updates, and text corrections are recorded separately.

November 1, 2026: First published on this website.

November 2, 2026: Added article information, classification, topics, language navigation, related articles where the same case was confirmed, consultation guidance, and SEO. The original text and first-published date were preserved.

 
 
 
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