Your European Legal Team for Transatlantic Expansion

European obligations do not disappear when opening in the US. These continue: (1) GDPR if the US subsidiary processes EU citizens' data; (2) EUTMs and European patents that must be renewed and defended; (3) contracts with European distributors that remain binding; (4) AI Act if AI systems are deployed in the EU. The European legal team must remain active throughout the transatlantic expansion.

We establish a clear communication protocol between A2 and the US/UK firm: regular strategy alignment meetings, all documentation shared in English, and clear responsibility divisions by jurisdiction. Our experience working in English with international teams — including firms in New York, Boston, London and Toronto — enables frictionless coordination.

Yes. The EU trademark does not protect in the US, Canada or UK. To protect your IP in English-speaking markets you need separate registrations: USPTO for the US ($350/class), CIPO for Canada, and UKIPO for UK (£200/class). We coordinate the global registration strategy: prior rights searches, applications coordinated with local lawyers, and opposition management across all jurisdictions.

The IDTA (International Data Transfer Agreement) is the UK ICO's mechanism for personal data transfers from the UK to the EU. For French companies with a UK subsidiary: if the British subsidiary transfers employee or customer data to the French parent, it needs an IDTA or the UK Addendum to EU SCCs. We manage these agreements to ensure EU-UK data transfers comply with both regimes (GDPR and UK GDPR).

Official fees are: USPTO $350/class, CIPO CAD $400/class (via Madrid Protocol), UKIPO £200/class. For a trademark in one class across all three markets, official fees total approximately €800-1,000. Professional fees for coordination, prior rights searches and application management add €1,500-2,500. Total cost for an uncontested registration across all three markets ranges from €2,500-4,000.

The EU AI Act applies within EU territory. If your French company develops AI systems also deployed in the EU, the AI Act applies to the EU jurisdiction regardless of any US deployment. For systems deployed exclusively in the US, the AI Act does not formally apply, but the US NIST AI Risk Management Framework and sector-specific regulations may. We coordinate compliance strategies that anticipate both regulatory frameworks.

Key contracts include: (1) distribution or agency agreement with the US partner (choice of law: New York or Delaware preferred); (2) technology or software licence if granting IP usage rights; (3) NDA to US standard; (4) Data Processing Agreement with US cloud providers (SCC + local addendum); (5) Terms of Service and Privacy Policy adapted to CCPA/CPRA if selling to US consumers.