Your European Legal Team for Transatlantic Expansion

In the US there is no GI protection system equivalent to the European one. Protection of Italian denominations such as 'Parmigiano Reggiano', 'Prosciutto di Parma' or 'Prosecco' is achieved primarily through: (1) registration of a Certification Mark at the USPTO (which can be applied for by the producer consortium); (2) registration of a Collective Mark for the denomination; (3) unfair competition and passing off actions if the name is used to deceive consumers. The system differs from the European one but allows effective protection of the most valuable Italian denominations.

The US and UK share a common law system but have important differences for Italian companies: (1) trademarks: USPTO for the US and UKIPO for UK are two completely separate registrations; (2) data: CCPA/CPRA applies in California (US) while UK GDPR applies in the UK; (3) contracts: the choice-of-law clause must specify whether New York, Delaware, English or Scottish law applies; (4) litigation: costs and timelines differ significantly (US tends to be more costly and lengthy). For Italian fashion or luxury companies, both New York and London are first-line markets requiring differentiated strategies.

Yes. The EU trademark protects in all 27 EU Member States but not in the US, Canada or UK. To protect IP assets in English-speaking markets, separate registrations are required. This is especially important for Italian fashion and food brands, where brand reputation is a critical asset that must be protected before entering the market.

We establish a joint working protocol: A2 manages the European side (EUTMs, GDPR, contracts under Spanish/EU law), the US or UK firm manages the local side. We meet periodically to align strategy. All communication is in English. We have experience working with firms in New York, Boston, Miami and London on IP and international contract matters for Italian clients.

The EU-US Data Privacy Framework (DPF), adopted in July 2023, allows transferring EU citizens' personal data to certified US companies without SCCs. For Italian companies with US subsidiaries, if the US subsidiary is DPF-certified, data transfers from Italy to the subsidiary are simpler. However, for non-certified US cloud and technology providers, SCCs remain the most widely used mechanism. We audit your transfer structure and recommend the optimal mechanism for each case.

Official fees are: USPTO $350/class and UKIPO £200/class. For a single-class trademark in both markets, official fees total approximately €500. Professional fees for prior rights searches, coordination with local lawyers and application management add €1,500-2,000. Total cost for an uncontested registration in both markets ranges from €2,000-3,500 per class. We always recommend registering before commencing commercialisation in each market.

Yes. We are regular representatives at EUIPO, ranked among the Top 25 representatives in Spain. We manage the full cycle: prior rights searches, EU trademark application, response to office actions, opposition management and registration maintenance. One EU trademark covers all 27 Member States including Italy. All communication in English.