Your European Legal Team for Transatlantic Expansion

European legal obligations do not disappear when opening in the US. These continue: (1) GDPR obligations if processing EU citizens' data from US operations; (2) European trademarks and patents that must be renewed and defended in the EU; (3) contracts with European distributors that remain binding; (4) AI Act obligations if AI systems are deployed in the EU. You need an active European legal team while your US lawyer manages the American side.

We establish a clear communication protocol between A2 and the US/UK firm: regular strategy alignment meetings, documentation shared in English, and clear responsibility divisions by jurisdiction. For complex projects (acquisitions, global licences), we coordinate the integrated legal strategy. Our experience working in English with international teams enables frictionless collaboration.

Yes. The EU trademark does not protect in the US, Canada or UK. To protect your IP assets in English-speaking markets you need separate registrations: USPTO for the US, CIPO for Canada, and UKIPO for the UK. We coordinate the global registration strategy from Madrid: prior rights searches, application preparation and coordination with local lawyers in each jurisdiction.

The EU-US Data Privacy Framework (DPF), adopted in 2023, is the mechanism that allows transferring EU citizens' personal data to certified US companies without SCCs. However, most companies still need SCCs for non-certified providers, and the DPF only covers personal data (not technical or business data). A2 advises on which mechanism to use in each case and updates transfer contracts to the current framework.

Since January 2021, the UK is no longer part of the EU single market. Key changes for German companies: (1) EUTMs no longer cover the UK, requiring separate UKIPO registration; (2) EU-UK data transfers require the UK Addendum or IDTA mechanism; (3) distribution agreements may need adjustment to the UK Consumer Rights Act; (4) the EU AI Act does not apply in the UK but the new British AI framework is under development. We coordinate the integrated UK-EU strategy.

If they are manufacturers of the AI developed, they will have manufacturer obligations, even if the deployment is outside the EU. However, if your AI system developed in Germany (or by a German subsidiary), in addition to being manufactured, is deployed in the EU as well as in the US, the AI Act applies in the European jurisdiction also with that role. Many German companies with US operations maintain AI systems that run in both markets, requiring a coordinated compliance strategy to simultaneously meet the AI Act (EU) and US AI regulatory frameworks (NIST AI RMF, sector-specific regulations).

Key contracts include: (1) distribution or agency agreement with the US partner (choose applicable law: New York, Delaware or English law); (2) technology or software licence if granting IP usage rights; (3) NDA/Confidentiality Agreement 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.

USPTO fees for registering a trademark in one class are approximately $350 per class (TEAS Plus application, the most efficient option). The typical process takes 12-18 months. Added to this are professional fees for prior rights searches, where applicable, together with application fees. The typical total cost for an uncontested registration without a viability study ranges from €900-1,000 per class. We coordinate with our US partner for a swift and effective response.