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The Panels interpretation of Article 20 has especially drawn criticism for being a factual assessment and leaving WTO Members with uncertainty as to what other reasons will justify an encumbrance to the use of trademarks.[27] While on this ground alone many trademark rights holders and scholars were hoping that the Panel Report will be reversed, its affirmation will come as a surprise to them

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Just assuming that resale will happen somewhere may be insufficient in order to convict

It's too big to police already