Boehringer Ingelheim Pharma GMBH & Co. and Boehringer Ingelheim (India) Pvt Ltd., (Boehringer) filed an application in the High Court of Himachal Pradesh at Shimla, India, praying for interim directions, during the pendency of suits, restraining MSN Laboratories Pvt Ltd., ERIS Lifesciences Limited, Emcure Pharmaceuticals Ltd., and Optimus Pharma Pvt Ltd (defendants / non-applicants) for infringing the rights granted to the plaintiffs / applicants under Indian Patent No. 243301 (‘IN301) for the product Linagliptin. The patent was granted on October 05, 2010 and as the priority date for the patent was October 18, 2003, it is set to expire on October 18, 2023. The product "Linagliptin Tablet and Lenagliptin + Metformin Hydrochloride Tablets" covered under the patent was launched in the Indian market under the brand names Trajenta and Tradenta duo on 27.05.2012 and 21.06.2014, respectively and is used for the treatment of diabetes. Boehringer came to know that defendants / non-applicants were planning to launch Linagliptin 5mg tablets under their respective brand names and also simultaneously in the month of February, 2022, a petition for revocation of the patent ‘IN 301 was filed under Section 64 of the Indian Patents Act 1970.

Boehringer’s application was allowed under Order XXXIX, Rules 1 and 2 read with Section 151 of the Code of Civil Procedure, 1908 and the defendants / non-applicants were restrained from infringing the subject patent covered under ‘IN301, in any form whatsoever. The order was pronounced on June 02, 2022.

Discussion

Patent ‘IN301 for Linagliptin was granted on October 05, 2010 and the product had a successful commercial run after it was launched in the market. There is no pre-grant / post-grant opposition on record nor was any revocation petition filed by anyone for the granted patent till about a year and a half before the due date of expiry of the patent. Boehringer was also granted a related Indian patent IN 227719 (‘IN719) which expired on Feb 21, 2022.

The defendants / non-applicants contended that Boehringer had resorted to ever greening as ‘IN719 represents a genus patent and ‘IN301 is a species patent already covered under genus patent. In support of their contention, it was stated that in the High Courts of Delhi and Ahmedabad, in a case related to the subject matter of IN301, Boehringer had not claimed ‘IN 301 as improvement of over ‘IN719. In other words, Linagliptin was covered in ‘IN719 under the Markush formula, which expired in Feb 2022. The stand taken by the Boehringer now was contrary to the stand taken earlier in the referred Courts of Delhi and Ahmedabad. It was also brought out that the objection related to the species patent was also raised by the examiner of the Indian Patent Office during the examination of the application. The defendants / non-applicants further argued that Boehringer has failed to explain the inventive step that lies in subject matter of ‘IN301 and how the inventive step therein is different from the inventive step of the subject matter of ‘IN719. The defendants believed that they had raised a credible challenge to the patentability of the subject matter ‘IN301 and therefore, the Boehringer’s application ought to be rejected.

Boehringer claimed that ‘IN 719 claims millions of compounds whereas ‘IN 301 claimed specific commercial embodiments and that Linagliptin was specifically claimed and covered under the latter patent. It was further averred that Linagliptin was “claimed and encompassed” in ‘IN 719, whereas it was “claimed and covered” in ‘IN 301. Boehringer also stated that the problem solved by ‘IN 301 cannot be solved by ‘IN 719 and that the subject matter of ‘IN 301 was arrived at only after further research and experimentation. Though the patent office examiner had raised some objections, they were successfully overcome and the patent ‘IN 301 was granted.

A patentee enjoys the rights to his patent but mere grant of a patent does not mean that the patent is valid. A patent is valid as long as it is not challenged. Revocation proceedings against a granted patent under section 64 of the Indian Patents Act 1970 can be initiated any time after the grant of a patent. However, it is necessary that a credible challenge to the validity of a patent has to be raised. The moot point is when one can say that a credible challenge has been raised against a granted patent? The answer lies in convincing a court that a triable question arises with respect to the validity of a patent. If the court is convinced that a triable question to validity has been raised, interim injunction can be granted. However, other factors also need to be kept in mind before granting interim injunction. The question of deciding whether the patent is valid can only be decided during a trial. In other words, it is the question of vulnerability of a patent to invalidation which needs to be decided when preliminary injunction is sought while actual validity of a patent is the issue to be decided at trial. A defendant should, therefore, raise a substantial question regarding the invalidity and such a question does not require as hard evidence as is required at the trial stage. Thus, a credible challenge can be said to have been raised only when a substantial question regarding invalidity has been raised and that the claims at issue are vulnerable. For supporting its averments, the Court referred to judgements of other jurisdictions like Abbot Laboratories v. Andrx Pharmaceuticals Inc.¹ and Helifix North America Corporation v., Blok-Lok, Ltd.²

The defendants / non - applicants spoke about the genus and a species patent with respect to ‘IN 719 and ‘IN 301, respectively, whereas they could have shown how a person skilled in the art could arrive at the subject matter of ‘IN 301 from the genus patent and therefore, raised a credible challenge with respect to the validity of the subject matter of ‘IN 301. The defendants / non – applicants dwelt on the submissions of the plaintiffs / applicants in the courts of Delhi and elsewhere, which was misplaced and did not amount to raising a credible challenge.

It was also apparent that the balance of convenience lied in favour of Boehringer as the defendants did not seek revocation against ‘IN 301 during the validity of ‘IN 719. The Court felt that the defendants had taken a calculated risk and waited till the expiry of ‘IN 719 for filing a petition for revocation of patent ‘IN 301.

¹Abbot Laboratories v. Andrx Pharmaceuticals Inc. (decision dated 22 nd June 2006 of the U.S. Court of Appeals for the Federal Circuit 05-1433)

²Helifix North America Corporation v., Blok-Lok, Ltd. Third Party Counterclaim, 208 F.3d 1339 (3rd Cir. 2000)

What is an open source?

An Open Source Software (OSS) is a term originated from the software industry to imply a software which is released under a license through which the copyright owner grants users the rights to use, study, change, and distribute the software as well as its source code. The Open Source code is different from ‘Publicly Accessible code’, which can be proprietary. An Open Source code has an Open source licence and the usage of the open source code is in accordance with the licence.

What is an Open source license?

An Open-Source license (OS license) is a license granted for a software and other products which allow for the source code, blueprint or design of the said software to be used, modified and/or shared under pre-defined terms and conditions. Usually, an OSS is released under an OS license which serves as a legal agreement between the OSS author and the end-user.

What is a Patent right?

A Patent gives the owner of the patent or a patentee, the right to exclude others from making, using, and selling his/her invention thereby, giving an absolute control over the use of his/her invention.

In contrast, the primary idea behind distributing software under an OS license is for anyone to be able view and use the “source code” of the computer program as well as modify the same for one’s own purposes.

One of the most frequently referenced OS license is the Gnu Public License (GPL) which is a license of copyright rights owned by the original author of software. When an author releases his software under the GPL, he may licenses the said software to those who utilize the software to copy, distribute, and produce derivative works of the software, providing that they then, in turn, release the software and their derivative works under the GPL and make the source code of the software and the derivative works available to the public. For example, the Linux OS is distributed under the GPL. Hence, anyone can obtain the source code for the same and can modify the software as long as they distribute the modified software under the as GPL.

Can Patent Rights and Open Source Co-Exist?

Yes. Patent Rights and Open Source can be said to co-exist in two ways:

1. An author of an OSS may apply for a patent for that OSS *

2. An invention using an OSS modification may be included/specified in a Patent application.

Why an author of an OSS, who is willing to publically share the code of their software, would want a patent for it at the same time?

There are several reasons that a software author may want to obtain a patent for software released using an Open Source license, as the author may:

- wish to license their patent in order to generate revenue or produce a revenue stream;

- want to assert their rights against infringers;

- intend to release a version of the software that doesn't use the Open Source license; and

- want to retain the ability to bring litigation against users that don't follow the terms of the Open Source license.

Can another invention using the OSS modification can apply for a Patent?

A person can apply for patent protection even if he/she modifies piece of software, which was released using an Open Source license, to invent something novel. However, the protections that the person receives will be significantly reduced from what they would get from a standard patent.

Conclusion

Open source has become a way of working that is beyond mere copyright production. Innovations accelerate when ideas are shared, when they are collaborative, open, and modifiable.

When a patent is granted, it is the law that the owner of the patent can limit the use of its invention. However, There is no such thing as a worldwide patent. Patents are granted on a country-by-country basis. If the distribution and/or use of the Software program are restricted in certain countries either by patents or by copyrighted interfaces, the original copyright holder who places the Program under the OS License may add an explicit geographical distribution limitation excluding those countries, so that distribution is permitted only in or among countries not thus excluded.

Henry Higgins in the movie ‘My Fair Lady’ laments in the immortal song – I’ve grown accustomed to her face! This is the typical laconic Britain Academician’s style of expressing love, but, this phrase typifies the whole concept of familiarity.

It is a common saying, ‘Familiarity breeds contempt’, however, in the world of branding and trademarks - ‘Familiarity breeds likeness’!

As consumers, we tend to buy products which we are familiar with even though other goods or products may offer more ‘attractive allure’ i.e. the allure of the unknown. We are tempted to go along in the unfamiliar direction but tend to fall back on the familiar. Do you recollect the umpteen number of times, you picked up unfamiliar products and put them in your cart, but just before you make payment or checkout (online), there is a sense of uncertainty where you question the quality/quantity/ longevity of the product and decided to ‘experiment’ another day?

Familiarity gives us a feeling of comfort. Such comfort is sensed when we taste something familiar, or when we notice a familiar colour shade or combination of colours, or even when we are accustomed to the surroundings.

Want to give it a try? A chocolate in a purple wrapper? A typical McDonald’s outlet with the Ronald McDonald sitting on a bench outside the eatery? The aroma of your favourite biryani? Brand/Brand packaging, advertising/publicity always attempts to establish a bond of familiarity between consumers and the service/product offered. A typical example of using familiarity effectively was the launch of ‘coke zero’ in a black can. The advertisement displayed a bunch of people sitting in the theatre, of which a few bought the regular coke can, only to realize that the coke can was in fact wrapped in ‘red’ paper and on peeling it was actually ‘coke zero’. Thus, instantly creating a bond of familiarity between the consumers of the coke in the red can and the launch of the new coke zero in a black can. In an episode of a TV serial, the sponsor ensures that the advertisement in relation to a brand is telecasted nearly 6-8 times, often to the point of irritating the viewer, but there is a method in the madness. The idea is to focus the brand in the mind of the consumer ‘subliminally’.

Familiarity is thus created with direct or indirect associations. For e.g.: An SUV is advertised by a familiar attractive looking model. This results in the familiarity of the model getting glossed onto the new vehicle. The same is true for products such as tooth powder. When someone like Amitabh Bachchan endorses a tooth powder or bhujia (an evening snack often relished with tea in India), the familiarity of Amitabh Bachchan gets glossed onto the product/brand.

Colour schemes also induce a sense of familiarity. People tend to refrain from using a product if after years of familiarity; the trade dress of the product is changed. Counterfeiters prey on this familiarity experience. Therefore, a counterfeit product will always contain a nearly identical colour combination, in an attempt to bank on the consumer’s familiarity with the colours.

Another important aspect is Word of Mouth (WOM). A negative WOM affects an unfamiliar brand more than a familiar brand, whereas a positive WOM benefits an unfamiliar brand more than a familiar brand. Conclusively, WOM tends to affect unfamiliar brands more than familiar. For e.g.: A bad review on a ‘Philips’ hair dryer or a ‘Sony’ music system is less likely to dissuade a consumer from buying the product and the consumer may choose to purchase the product irrespective of such bad review. However, a bad review of a ‘PQR’ hair dryer will result in the consumer to not purchase the product.

This brings us to another concept of ‘peer familiarity’. A consumer himself may not be conversant with a brand, but the fact that, his peer is familiar with the brand, is bound to result in his positive opinion towards the brand. Isn’t it natural for you to endorse a brand if your best friend has recommended it? Thus, familiarity plays a rather important role in branding than we anticipated, doesn’t it?!

In 2002, Ferid Allani (“Allani”) filed a patent application (IN/PCT/2002/00705/DEL) for his computer related invention titled, “method and device for accessing information sources and services on the web”. As per the Complete Specification, “the invention proposes a method for accessing information sources and services on the Web, that is quicker and easier to use than the present methods for accessing information on internet, notably with an objective of integration within interactive terminals and office automation and communication equipment.” The Indian Patent Office rejected this application stating that it lacked novelty and was hit by the provisions of Section 3 (k) of the Indian Patents Act.

Section 3 (k) of the Patents Act reads as follows:

3. What are not inventions. -The following are not inventions within the meaning of this Act,-

(k) a mathematical or business method or a computer programme per se or algorithms;

Allani appealed to the Intellectual Property Appellate Board (“IPAB”) against the order of the Controller. However, the appeal was dismissed by the IPAB stating that the patent application did not disclose any technical effect or technical advancement.

Allani then appealed to the Delhi High Court in the case of Ferid Allani v. Union of India & Ors W.P.(C) 7/2014 & CM APPL. 40736/2019 citing various claims in the patent specification to show that it disclosed a ‘technical effect’ and a ‘technical advancement’. Allani further contended that the invention is not merely a software invention that can be simply loaded on to a computer, for it also requires a particular method of implementation. He relied upon the Draft Guidelines for Examination of Computer Related Inventions, 2013.

The Defendant submitted that since IPAB had put forth its technical view on the patentability of the invention, the Court could not pass an order with regards to the technical arguments raised before such a Tribunal.

However, the Court held that, “The bar on patenting is in respect of `computer programs per se….’ and not all inventions based on computer programs. In today’s digital world, when most inventions are based on computer programs, it would be retrograde to argue that all such inventions would not be patentable. Innovation in the field of artificial intelligence, block chain technologies and other digital products would be based on computer programs; however the same would not become non-patentable inventions – simply for that reason. It is rare to see a product which is not based on a computer program”.

Thus, the Court held that in light of the amendments to the Guidelines with respect to Computer Related Inventions and the judicial precedents in this regard, since 2013, the meaning of ‘technical effect’ has been clearly churned out. The wisdom of these guidelines and judicial pronouncements was not applied to Allani’s invention as it had not evolved when the application was examined for the first time, in 2005. The Court asked the Patent Office to re-examine the patent application in light of the above observations and in accordance with the Guidelines, judicial precedents, settled practices of patent offices in examining such patent applications.

Selection of a proper brand name in the initial stages of the life cycle of a product plays a vital role in the success or failure of a product. It is advisable, to conduct a search in appropriate trademark classes (depending on the products or services provided) through the online records of the Trademarks Registry to determine whether a mark is likely to conflict with any pending or registered mark(s) in respect of the same or similar goods/services. Upon conducting the search, an owner is confronted with two scenarios. Firstly, the mark is available for adoption and use, or that the mark or a similar mark is registered or pending in the name of a third party proprietor. However, there may exist a third scenario, wherein the chosen mark or a part thereof forms a part of a prior registered/pending mark. This scenario often confuses brand owners as to whether or not they should adopt the mark in question.

The case of Shivam Hardware Store vs. M/S Century World (CW) is a reflection of this principle.

Both parties are involved in the business of hardware. Shivam commenced the business of manufacturing, supply and sale of modular kitchen accessories in the state of Delhi NCR in 2021 and applied for the registration of the trademark “" in Class 6 and 21. These marks are presently pending for registration.

CW is the registered proprietor of the trademark “”. CW filed a suit in the High Court of Delhi (Commercial Division), seeking permanent injunction against Shivam from infringing, passing off, inter alia of its trademarks.

CW claimed that Shivam was using the mark/label/packaging/trade dress ‘SHIVAM CENTURY’, which was nearly identical and/or deceptively similar to its mark of ‘CP CENTURY’ and ‘CWPL CENTURY’.

Source - Judgement

CW further claimed that its trademark was distinctive and associated with its business on account of its long, continuous extensive and exclusive use and reputation. CW added that Shivam was engaged in the same business, the mark ‘SHIVAM CENTURY’ was likely to cause confusion in the mind of the customers, who were likely to be deceived into believing that Shivam’s goods actually emanated from CW.

Against this, Shivam stated that CW did not possess an exclusive and statutory right to use the word ‘CENTURY’ as the said term was a common dictionary word and used by various other companies/brands associated with modular kitchen ware. Shivam also contended that CW’s mark ‘CP CENTURY’ had to be read as a whole and that CW could not monopolise the word ‘CENTURY’. It also asserted that that the font and style used by the respective parties were different and therefore, the public at large could easily distinguish between the two companies and their trademarks and their products.

However, the Court came to a prima facie conclusion that Shivam had infringed CW’s trademark and case of passing off was merited.

The Commercial Court’s Order was based on the following reasons:

1. CW had a registration of trade mark 'CP Century'.

2. Shivam had only applied for a word mark 'Shivam Century' and is not registered proprietor.

3. Shivam’s claim that word 'Century' was commonly associated with the trade of modular kitchenware, was not substantiated by any evidence

4. Shivam failed to show how it had coined the trade mark 'Shivam Century'.

5. Shivam also failed to show that it was a bona fide user of the trade mark

6. The use of the term 'Century' by Shivam appeared to be dishonest.

The Court further held that, Century was prominent in CW’s mark and that, unwary customers could be easily misled into believing that the goods under the mark 'Shivam Century' originate from CW. The Court also held that although the word 'Century' has a dictionary meaning and used commonly in English language, yet since it was registered in the name of CW and CW was the prior user, CW had the right to protect its mark.

The Court granted an interim injunction in favour of CW, restraining Shivam from using the trade mark label /packaging / trade dress 'SHIVAM CENTURY' or any other deceptively similar mark.

Here it is important for us to understand the reasons/ grounds on which the injunction order was passed by the Court. If Shivam would have been able to prove that the word “Century” was in fact common to trade, the result would have been different. If Shivam would have been able to prove it had coined the word SHIVAM CENTURY from some legitimate source, the result would have been different. If Shivam would have been able to prove it was a bona fide user of the trade mark 'Shivam Century” for a long time, the result would have been different. However, Shivam failed to prove any of these factors and therefore it suffered an interim injunction.

Thereafter, Shivam appealed to the Delhi High Court against the Order of the Commercial Court. The Delhi High Court observed Shivam’s defence to the action instituted by CW as two-fold.

1. CW could not claim monopoly in respect of the word ‘Century’;

2. The trademark used by Shivam was materially different from the trademarks of CW and therefore, there was no propensity to cause confusion.

The High Court observed that it was clear from the registered trademarks of the respondent: ‘CP CENTURY’ and, ‘CWPL CENTURY’ that the word ‘CENTURY’ was a prominent feature of the CW trademarks.

In addition, the word ‘CENTURY’ was also a prominent part of Shivam’s trademark (SHIVAM CENTURY).

The High Court noted that “although the word ‘SHIVAM’ is in a larger font, it can hardly be disputed that the word ‘CENTURY’ is a significant part of the said trademark”.

Therefore the High Court concurred with the decision of the Commercial Court and dismissed Shivam’s appeal by stating that the no interference with the interim injunction award was required.

Hence the answer to the Third Scenario i.e. One should not file an application for registration in case a mark chosen or a part thereof is a part of prior registered/ pending mark.

Possible exceptions

1. Common to Trade / Register - If the part that is common in the chosen mark and prior registered/pending marks, is common to the trade i.e. there are various entities in the said business, using the part in their trademarks name/tradename; or is common to the Register i.e there are various registered marks in the same class which have that part common in their trademarks. If the adopter can prove any of the above, he/she can go ahead with filing application for registration of the mark.

2. Honest Conception and Adoption - If the adopter can prove that he/she has coined/conceived or adopted the mark honestly, he/she can go ahead with filing an application for registration of the mark.

Introduction

Indian Record Manufacturing Co. Ltd. (IRM) filed a suit to refrain Ilaiyaraaja from selling his musical works for all his songs in various films produced prior to 2000 by IRM to Agi Music Sdn Bhd.

Backdrop

IRM is a music company engaged in production, distribution and sales of music albums in various forms. IRM acquired the copyright with respect to 30 feature films from its producer directly under an agreement with the producers which entitled IRM for production, reproduction, sale, use and performance including broadcasting throughout the world by any means. IRM was exploiting the right so acquired by making copies of the work in various forms. Ilaiyaraaja is the composer of the songs which are a part of the 30 feature films mentioned above and hence claimed copyright over the musical work being the composer/creator of the work. Ilaiyaraaja contended that in the absence of the agreement between him and the producers of the films, he cannot be injuncted from selling the rights of his musical works.

Plaintiff’s Contentions

IRM as an assignee has the exclusive right to exploit the work as it has been assigned the copyright of the musical work by its producers. As per provisions of the Copyright Act, 1957 (the Act) producer is the first owner of the copyright if there is no agreement to the contrary, as it is the producer, at whose instance the cinematograph film is made. The right of publication or reproduction of the work for publication vests only with the employer (producer). IRM being rightful assignee of the copyright shall be treated as the owner of copyrighted work.

Defendant’s Response

In his response, Ilaiyaraaja denied (as the other two defendants remained ex-parte) that the producers of the films are the first owners of the musical compositions and the sound recording which have been composed by him. He further contended that IRM being a third party to the contract between him and the producer and such third party cannot impeach his copyrights as author. His main contention was that the film producer although has right under Section 14(1)(c) of the Act in the cinematograph film, however, the producer cannot violate the copyright of the composers in the song.

Important Questions of Law that were answered in this case

1. Who is the author and the owner of the musical work and sound recording contained in the Cinematograph Films under dispute?

The Hon’ble Court explained that it is the producer who is the first owner of the cinematograph film; however, in case of musical work in isolation the composer being the author would be the owner of the work. However, this situation changes when the song becomes a part of a cinematograph film as a sound recording. Sound recording is a composite work and the author is the producer of the cinematograph film as per provisions of Section 2(d)(v) of the Act. The Hon’ble Court further held that prior to amendment Act 38 of 1994; the inclusive definition of cinematograph film includes the sound track, if any. Thus, the first ownership of the musical work in a cinematograph film vests with the producer, in the absence of any agreement to contrary.

The Court then went on to explain the logic behind vesting of first ownership of the copyright of a Cinematograph film with the producer. It explained:

“Cinema is a blending of multiple intellectual work like script, music, lyrics etc., with the contribution of the performers like actors, singers etc. The producer is the person who takes the initiative and responsibility of lending several intellectual works and performing artists. For the said purpose, the producer invests and engages the authors of the intellectual work as well the performers. On blending several intellectual works and the performance, he becomes the first owner of the cinematograph film. It is he who can desegregate the blending, if necessary to assign the copyright to others under Section 19 of the Act.”

With respect to audio rights in a particular song it was held that “the music as well as the lyrics are two distinct intellectual works. The music composer cannot have any right over the lyrics and vice versa.” Hence it is the producer who has the rights over the song used in a cinematograph film.

Burden of Proof: The Hon’ble Court held that the Burden of proof is on Ilaiyaraaja to show that he had any contract with the producer by which composer he has retained the copy right of the Sound Recordings, in absence of which Producer will be the owner of the copyright.

2. What rights does the Composer retain?

Upholding the verdict of Agi Music Case, the Hon’ble Court held that the composer only has special rights of protection from distortion, provided in Section 57 of the Act and none else.

3. Will the right of the Producer of the film override the right of the Composer? 

The Hon’ble court upheld the judgement on anidentical issue by Hon'ble Supreme Court judgment in Indian Performing Right Society Ltd Case wherein it was held that “the right of the composer or the lyricist can be defeated by the producer of a cinematograph film in view of proviso (b) to section 17 of the Act.”

Decision

In absence of any agreement to the contrary between the producer and Ilaiyaraaja, the producers of the respective films are the first owners of the copyright in the musical works and sound recordings. Through an assignment deed, IRM has obtained the copyright by assignment, being a written document signed by the assignor. Thereby, IRM has become the owner of the said copyright and have the right to exploit the same.

In the Copyrights Act, the meaning of the word ‘owner’ and the word ‘author’ are neither interchangeable nor synonyms. They connote different meaning and different persons. A music composer is the author of the work, but not the owner of the work unless the producer who employs the composer expressly gives up his right of ownership in favour of the Composer. IRM is the holder of the agreements assigning the copyright to exploit and is hence entitled for the injunction relief prayed for.

- Provided by my good friend, Phil Furgang.

- Provided by my good friend, Phil Furgang.

A sign on a Plumber's truck: "We repair what your husband fixed.”

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On another Plumber's truck: "Don't sleep with a drip. Call your plumber.”

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On an Electrician's truck: "Let us remove your shorts.”

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In a Non-smoking Area: "If we see smoke, we will assume you are on fire and will take appropriate action.”

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On a Maternity Room door: "Push! Push! Push!”

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At a Car Dealership: "The best way to get back on your feet - miss a car payment.”

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*We do not claim any copyright in the above image. The same has been reproduced for academic and representational purposes only.

Founded in 1853 in San Francisco, California, Levi Strauss & Co. is an American clothing company known for its blue denim jeans and its logo is recognizable all over the world.

The iconic batwing was designed by Walter Landor in 1967 and has been used in the company’s branding since 1969.

Levi Strauss and Co. historian, Tracey Panek said the design can be seen on the pockets of the company's 501 famous jeans.

Source - Google

*We do not claim any copyright in the photograph. It has been used for academic and representational purposes only

The Mahajanpada of Matsya, established around 700 BC, was inspired by the ‘Matsya’ avatar of the Hindu god, Lord Vishnu.

The Mahajanpada of Matsya was located in the modern day region of Jaipur-Bharatpur-Alwar in the state of Rajasthan. Its capital was at ‘Viratnagara’ - modern day Bairat in Rajasthan.

This region was suitable for cattle rearing hence the Matsya relied heavily on cattle and therefore, could not compete with the powers that emerged on the basis of settled agriculture. It was absorbed by the mighty empire of Magadh, subsequently.