From science fiction to law: the European Parliament proposes a legal framework for robotics

On 16 February 2017, the European Parliament adopted a resolution which includes a series of recommendations to the European Commission regarding civil law rules on robotics. (1) With this document, the Parliament calls on the Commission to submit a proposal for a directive. These recommendations have been under review for two years, a time necessary to conduct a rich and thorough reflection on a multi-faceted matter which will deeply disrupt our civil, industrial and economic societies.

Robotics includes not only robots and artificial intelligence (“AI”), but also bots, drones, autonomous vehicles. This area raises ethical and legal questions which must be addressed now at a supranational level, especially since robotics is already present in a number of industries, such as the automotive and electronics industries.

The resolution of the Parliament stresses the necessity to define an ethical framework around the development, programming and use of robots, to define a legal framework around robotics to allow a harmonised and legally secured development, and to define new legal liability principles for actions performed by smart robots.


1. An ethical framework based on Asimov’s laws of robotics

Good science fiction has often been predicting the evolution of technology and society. Numerous technology tools appear in our daily environment which are directly inspired from communication “gadgets”, from the Star Trek saga (smart phones and connected things), to motion pictures such as Minority Report and Moneyball (predictive analysis), or 2001, A Space Odyssey and I, Robot (smart robots). (2)

Prior to these movies, Isaac Asimov, the famous 20th century science fiction writer, set down the three laws of robotics governing the relationship between man and robot:
    1. A robot may not injure a human being or, through inaction, allow a human being to come to harm;
    2. A robot must obey the orders given it by human beings except where such orders would conflict with the First Law;
    3. A robot must protect its own existence as long as such protection does not conflict with the First or Second Laws. (3)

These laws have inspired the members of the European Parliament to establish the foundation of their recommendations on a preliminary draft of European civil law on robotics, reminding “the intrinsically European and universal humanistic values that characterise Europe’s contribution to society”. These laws are directed primarily at the designers, producers and operators of robots.

Based on these principles, the European Parliament recommends to develop a clear, precise and efficient ethical framework applicable to the design, development, production, use and modification of robots.

Robots must serve humanity especially by performing repetitive, difficult or dangerous tasks. But robotics, through its social, medical and bioethical implications also comes with societal risks for humans, including in the areas of liberty, safety, health, privacy and personal data protection, integrity and dignity.

This resolution takes a practical approach by integrating a Charter on robotics comprised of a Code of ethical conduct for robotics engineers, a Code for research ethics committees (REC), and licences for designers and for users.

The Code of ethical conduct for robotics engineers covers all R&D activities and recalls the strict obligation for researchers and designers to respect the dignity, privacy and safety of humans. This ethical framework should be based on principles of beneficence (robots should act in the best interests of humans), non-maleficence (robots should not harm a human), autonomy (the capacity to make an informed, un-coerced decision about the terms of interaction with robots), and justice (fair distribution of the benefits associated with robotics; affordability of homecare and healthcare robots). The Code also defines principles of fundamental rights, rights of precaution, transparency, safety, reversibility and privacy.

The Code for research ethics committees (REC) stresses the principle of independence to avoid conflicts of interest between the researchers and those reviewing the ethics protocol, and between the reviewers and the organisational governance structures. The Code also defines the role and constitution of a research ethics committee and monitoring rules.


2. The foundations of a legal framework- to define the notion of “robot” and support the development of cyber technology

The resolution also includes several recommendations aimed at setting the ground rules of a harmonised European legal framework adapted to robotics. Such legal rules must permit the cross-border use of robots (principle of mutual recognition), thereby avoiding fragmentation of the European market.

    - The notion of “smart robot”
The Parliament calls on the Commission to propose common definitions within the European Union regarding the notions of cyber physical systems, autonomous systems and autonomous and smart robots, and their sub-categories. A “smart robot” would include the following characteristics:
. the acquisition of autonomy through sensors and/or by exchanging data with its environment (inter-connectivity);
. self-learning capacity from experience and by interaction;
. at least a minor physical support;
. the capacity to adapt its behaviour and actions to its environment; and
. absence of life in the biological sense.

A Community system of registration for certain “advanced” categories of robots could be created for purposes of traceability.

    - Intellectual property rights
The Parliament draws attention to the necessity to address the issue of intellectual property rights in robotics through a horizontal and technologically neutral approach applicable to the different sectors in which robotics could be used.

    - Right to privacy and personal data protection
Extending the right to privacy and personal data protection to the relationship between humans and robots is fundamental. Indeed, the robots used by individuals in a domestic environment (autonomous vehicles, domestic robots, care robots and medical robots) will collect and process personal data. These robots will usually be connected, making it easy to analyse and shared the data collected.

The Community rules on the right to privacy as well as the provisions of the General Data Protection Regulation (GDPR), especially the rules regarding systems security, must be extended to robotics. However, such rules must be complemented, where necessary, to take into account the specificities of robotics.

    - Standardisation, safety and security
The development of robotics includes the creation of technical standards that must be harmonised internationally to avoid dividing up the European market, and foster a high level of product safety and consumer protection. Communication between robots shall also require the adoption of open and interoperable standards.

To avoid the fragmentation of the European market, testing, certification and market approval in a Member State should be recognised in the rest of the EU.

    - Education and employment
The development of the use of robots will create a new industrial and societal revolution. Even though its actual impact on employment is not fully known, less skilled jobs will be more severely affected as well as labour-intensive industries. Automation will lead to more flexibility of skills. For that matter, the Parliament calls on the Commission to monitor medium and long-term job trends as a result of the increased use of robots, and to support education to digital skills so as to align the job market with the demand.

Finally, the Parliament recommends the creation of a designated EU Agency for Robotics and Artificial Intelligence to provide its technical, ethical and regulatory expertise at the Community and National levels.


3. The issue of legal liability: can an autonomous robot be considered as a person responsible for its actions?

An autonomous robot (having the ability to adapt and learn) can make decisions and implement them independently, which means that its behaviour includes a level of unpredictability. Such autonomy is however merely technical. Also, the more autonomous a robot is, the less it can be considered as a simple tool controlled by a human (manufacturer, operator, owner). Therefore, a specific status - the electronic person - could be created for autonomous robots.

The current legal liability rules are not adapted to autonomous robots, which cannot be held liable  in case of damages caused to a third party. Under the current state of the law, humans are liable, i.e. the manufacturer (product liability), the operator, the owner or the user of the robot (liability for damages).

The Parliament calls for the Commission to review liability laws to determine the regime that will be more adapted to this matter, i.e. either a regime of strict liability (ability to prove the damage, the defect in the robot and the causality between the defect and the damage), or a liability regime based on risk management (ability to manage risk and its consequences).

The liability of the parties involved should be proportional to the level of instructions given to the robot and its degree of autonomy (the greater the robot’s autonomy, the greater the responsibility of its trainer). In parallel, a specific insurance system for robots should be created.

    As a conclusion, this resolution by the European Parliament manages to provide practical orientations about a very complex matter, especially since we don’t yet know the full extent of the impacts of robotics on our society. This document provides a good overview of the issues raised by robotics. This resolution draws the major trends of a legal framework with a purpose to secure the development of robotics and of its multiple uses. It lays necessary ethical foundations and tries to contain fears related to the consequences of an uncontrolled development of AI. The ball is now in the camp of the European Commission to propose a directive within a reasonable timeframe so that Europe is not overtaken by the evolution of robotics which is happening very fast.


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(1) “European Parliament resolution of 16 February 2017 with recommendations to the Commission on Civil Law Rules on Robotics” (2015/2103(INL))

(2) These movies are mostly adapted from books: Minority Report (by Philip K. Dick, published in 1956!); Moneyball (The Art of Winning an Unfair Game, by Michael Lewis, published in 2003); I, Robot (by Eando Binder, published in 1939 and re-written by Isaac Asimov in 1950)

(3) Asimov’s three laws of robotics appear in “Runaround”, published in 1942.

Photo © ClaudeAI.uk (https://claudeai.uk/ai-blog/ )

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May 2017

Choosing an out-of-court procedure to recover domain names : a fast and cost effective process

 Cybersquatting consists in the practice of registering domain names using unauthorized third-party trademarks. The cybersquatter may then try to resell the domain names to their rights owners. Some cybersquatters use these “fraudulent” domain names to redirect online traffic to websites distributing similar competing products or services, while other cybersquatters use these domain names to operate websites selling infringing products or services.

The businesses most affected by cybersquatting are primarily fashion brands, followed by banking and finance services, and internet and IT services.

The rights owners can either enter into legal proceedings or opt for an out-of-court procedure to recover or remove the domain names that include their trademarks. Out-of-court procedures such as the ICANN Uniform Domain-Name Dispute Resolution Policy (UDRP) are now widely used as a fast and cost-effective process to recover domain names.


1. Using the UDRP to recover a domain name

The UDRP can be used by rights owners for disputes involving domain names registered abusively using their trademark, and only for domain names with the following generic extensions (gTLDs): .com, .net, .org, but also .aero, .asia, .biz, .cat, .coop, .info, .jobs, .mobi, .museum, .name, .pro, .tel, .travel and new gTLDs. (1)

UDRP cases are handled by ICANN-accredited dispute resolution organizations, including the WIPO Arbitration and Mediation Center (based in Geneva, with an office in Singapore), the National Arbitration Forum (United States) and the Asian Domain Name Dispute Resolution Center (ADNDRC) (based in Hong Kong, with offices in China, Korea and Malaysia). (2)

To be admitted, the rights owner’s complaint must meet three cumulative conditions:
    i) Identical or confusingly similar: the allegedly fraudulent domain name must be identical or similar to a trademark owned by the rights owner and create confusion in the mind of the public/consumers ;
    ii) Rights or legitimate interests: the registrant of the allegedly fraudulent domain name must have no rights on the domain name and no legitimate interest related to that domain name; and
    iii) Registered and used in bad faith: the allegedly fraudulent domain name must have been registered and used in bad faith.

The proceedings are quite simple and include the following steps: a complaint is filed by the complainant, a response is sent by the respondent, the case is reviewed by an expert panel, the expert panel renders a decision and the decision is executed.

The case is usually handled over a period of 60 days. The administrative charges are reasonable and are usually between USD1,500 and USD5,000. The administrative charges are paid by the complainant unless the respondent requests a panel of several experts, in which case the cost is split between complainant and respondent. However, under this process, the complainant cannot request damages. A UDRP decision will either order the disputed domain names to be removed, transferred to the complainant (rights owner), or the complaint may be rejected if it doesn’t meet the three cumulative conditions mentioned above.

In its 2016 annual report, the WIPO claims a 10.5% increase in the number of UDRP cybersquatting cases handled concerning 4,364 domain names, compared to the previous year. (3)


2. The Moncler case: an example of a cybersquatting case handled through UDRP (4)

The Moncler case, held in early 2016, is a good example of cybersquatting and how a rights owner can claim back disputed domain names under the UDRP process.

Moncler, an Italian high end fashion sportswear company owns several trademarks, including the Moncler trademark and several domain names including moncler.com.

Three Chinese individuals had registered fifty domain names including the Moncler trademark (<monclersaleie.com>, <monclersaleireland.com>, <ukmoncleroutlet.com>, <outletmoncleruk2015.com>, <moncleroutletbest.com>, etc.). Most of these domain names led to websites using the same format, wording and pictures from the Moncler official website and selling counterfeit goods. Other domain names led to parking pages offering pay-per-click links, some of which leading to competitors’ websites.

Moncler filed a UDRP complaint with the WIPO Arbitration and Mediation Center to claim back the infringing domain names.

The case was reviewed by the WIPO panel according to the three conditions of the UDRP :

- After confirming Moncler’s rights in the Moncler trademark, the panel found that each disputed domain name contained the full Moncler trademark. The panel held, citing a previous case, that “The fact that a domain name wholly incorporates a complainant’s registered mark is sufficient to establish identity or confusing similarity for purposes of the Policy.”

Most of the disputed domain names also included the word “outlet” which, used with the trademark, was confusingly similar to that trademark.

- Moncler argued that the respondents had no rights or legitimate interests in respect of the Moncler domain names. The respondents had not been authorized to include the Moncler trademark in the domain names or to make any other use of the trademark, and they were using the domain names to sell counterfeit goods online and to refer to activities in competition with Moncler’s activities.

The panel found that the complainant had established its prima facie case. Without any evidence from the respondent to the contrary, the panel held that the complainant had satisfied the second element of the policy.

- The third element of the Policy is whether the domain name was registered and used in bad faith.

Moncler argued that the domain names were used in connection with websites offering counterfeit goods for sale, that the domain names were used in connection with PPC websites (parking pages) containing links to Moncler’s competitors and that by registering 50 domain names using the Moncler trademark, the respondents had engaged in a pattern of conduct that also constituted bad faith.

The panel held that the complainant had satisfied the third element of the policy.

Therefore, the Panel decided that the complainant had met the three conditions of the policy and ordered that the disputed domain names be transferred to Moncler.

The decision was issued on 18 January 2016, less than six weeks after the complaint was filed with the WIPO Arbitration and Mediation Center.


      In conclusion, the UDRP process allows to resolve trademarks vs. domain names disputes within a few weeks and for a lesser cost than a full legal procedure. This process is also often used for international cases, when complainant and respondent are located in different jurisdictions. With a UDRP decision, the complainant may get the disputed domain names removed or transferred, without an exequatur process, which would usually be necessary to get a court decision recognized and enforced in another jurisdiction.

However, as mentioned above, a UDRP complaint cannot include a claim for damages and the administrative costs are usually borne by the complainant. UDRP decisions are final, with no appeal process. This is the reason why complainants often choose to file legal proceedings in addition to a UDRP process, and claim damages especially if several domain names are involved and if they also have an intellectual property claim (such a the sale of counterfeit goods), an e-reputation claim or a fraud claim.


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(1) See www.icann.org, Domain Name Dispute Resolution Policies.

(2) Country domain names (ccTLDs) disputes can also be filed with the WIPO Arbitration and Mediation Center under their Domain Name Dispute Resolution Service. Not all ccTLDs are concerned though (see http://www.wipo.int/amc/en/domains/cctld/). Also, for .fr domain names, Afnic, the French registrar and country code manager has launched a domain names dispute resolution policy in 2011 called Syreli (https://www.syreli.fr/)

(3) Report of the Director General to the 2016 WIPO Assemblies

(4) WIPO Arbitration and Mediation Center, Administrative Panel Decision, Moncler S.p.A. v. Yao Tom, Lee Fei & Geriy Wang, Case n°D2015-2244


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December 2016

Software license audits challenged in French court

Software vendors (licensors) have increased the number of software license audits over the past few years to chase intellectual property infringement through illegal use of software. Infringing users (licensees) are required to pay additional licensing fees or else they will be sued. Even if the user is duly licensed to use the software, only limited rights are granted by the licensors. The purpose of license audits is to ensure that the licensee complies with the rights granted by contract.

However, licensees tend to challenge software license audits more often. Their claims are often legitimate: increased complexity of the license agreements, difficulty for the licensees to keep track of the licensing rights actually used, or even bad faith by certain vendors who would threat to launch an audit to pressurize the client at the time of contract renewal.

The amounts at stake are usually quite high for both parties, vendors and licensees.

Two recent French cases, both involving Oracle Corporation, illustrate the tension between vendors and licensees, especially at the time of renewing - or not - the existing licenses. (1) These cases raise the issue of the purpose, scope and limitations of a software license audit, and of the legal grounds on which a case may be brought when challenging the non-compliance between the rights granted and actual software use.


1. Purpose, scope and limitations of a software license audit

Software is protected by intellectual property law. (2) The author, or software publisher, enjoys exclusive rights over his/its work and is free to decide how to distribute it, including the scope of the rights granted and the licensing fees charged.

The rights granted to the licensees are provided in the software license agreement. The scope of the rights granted is different depending on the vendors. The licensing rights can be limited according to the type or number of terminals, or servers, number of named users or of CPUs, user volume, etc. Limitations can also be territorial, per location, facility, country or region.

Each vendor is also free to set its own fee system: through the payment of a one-time licensing fee, through a recurring subscription assessed according to the number of terminals or user volume, or through fees evolving with the software (upgrades), etc.

To ensure that the software is used in accordance with the rights granted, software vendors usually include software license audit clauses in their contracts.

However, one of the fundamental principles of civil law is that contracts must be performed in good faith (art. 1134 of the French civil code). Under this principle, software audits must not be carried out for a purpose other than the original objective or be used as a threat against the licensee at the time of renewing the contract, in order to put financial and operational pressure on the licensee or to overreach and access licensee’s proprietary confidential data.

Both examples were raised in the cases examined here.

- The Oracle vs. Carrefour judgment of 12 June 2014 (Summary judgment)
In this first case, Oracle sued Carrefour after the latter had resisted Oracle’s request to run its data collection scripts on Carrefour’s systems during the software audit process.

Two Carrefour affiliates, Carrefour SA and Carrefour Organisation et Systèmes Groupe had entered into a framework license agreement to use the Oracle Database Management software. On 27 January 2012, after the agreement had expired, Oracle France notified Carrefour its decision to conduct a software license audit to check the compliance of the software used with the rights granted under the license agreement. The notification included a request to run scripts allowing to assess the number of licenses used and to check the documents provided by Carrefour regarding the use of the software.

Carrefour didn’t resist the audit but refused the process imposed by Oracle, i.e. to run Oracle’s auditing tools. Carrefour considered that the scripts used by Oracle gave them access to Carrefour confidential information, which was unnecessary for the purpose of the audit and which imposed a security risk on its IT systems.

In a summary judgment rendered on 12 June 2014, the Civil court of Nanterre (Tribunal de grande instance de Nanterre) held that Oracle could not compel Carrefour to run Oracle’s scripts to collect data for the audit since this process was not imposed by the agreement nor by law.

The judges held that Oracle did however justify a legitimate reason to be granted an expert assessment to establish evidence of potential contractual breaches and intellectual property violations by the defendants. On the other hand, Carrefour was not compelled to run Oracle’s data collection scripts, but the judges confirmed that Oracle could use all necessary data collected during the expert assessment to check Carrefour’s compliance of the use of the software programs with the licenses granted.

- The Oracle vs. AFPA decision of 6 November 2014
In a second case opposing Oracle to the AFPA (Adult professional training association) before the Civil court of Paris (Tribunal de grande instance de Paris), the AFPA claimed that Oracle had overreached its software auditing right to put pressure on them at the time of their license renewal with the intent to limit competition and to abuse its right to bring legal action against the AFPA if they didn’t renew the licenses.

The AFPA claimed that Oracle was using their audit right abusively “by distorting its purpose” to put pressure on the AFPA to deter them to migrate to a competitor’s software at the time of the license renewal. This method allegedly resulted in limiting competition (per art. L.420-2 of the commercial code) on the SGF and RDBMS solutions markets.

The judges were not convinced by the AFPA’s claim regarding an abuse of dominant position by Oracle, as they considered that in this case, Oracle’s dominant position on the RDBMS market was not ascertained.

Regarding the abuse to bring legal action, the judges recalled that engaging legal proceedings is a right. If this right is used abusively, then the claimants must prove that a fault was committed, under article 1382 of the civil code (fault, damages and causality between the fault and the damages suffered).

However, although Oracle threatened the AFPA to launch an audit at the time of license renewal, in the present case, the AFPA didn’t demonstrate having suffered specific damages, other than the cost incurred in this legal procedure.


2. Characterizing an alleged non-compliance to the license: intellectual property infringement or contractual breach?

The case opposing Oracle to the AFPA raised a second interesting legal issue regarding the characterization of the dispute over the alleged non-compliance to the software license.

- The facts
Oracle distributes an ERP solution called Oracle E-Business Suite, comprising over 70 software application programs dedicated to enterprise management and clustered into “suites” (“Financials” for accounting and finance software, “Procurement” for purchasing management and suppliers).

Unlike most enterprise software, the E-Business Suite licensing system doesn’t work with activation keys used to manage licenses (blocking and unblocking access to the software, managing the license term, etc.), but instead is delivered on a CD which includes all the programs. The client or its service consultant is then responsible for the installation of the licensed programs on the client’s systems.

Following an RFP launched in September 2001, the AFPA executed an agreement with Sopra Group (an Oracle distributor and consulting company) for the provision of the Oracle E-Business Suite - Finance, for an initial group of 475 users.

In July 2008, Oracle France notified the AFPA its decision to carry out a software audit. The audit was actually conducted in May/June 2009, when the AFPA launched a new RFP to roll out the Procurement solution. According to the audit results, the AFPA was using 885 Purchasing software licenses. This software program was part of the Procurement suite, which was not included in the license granted.

After failing to settle the matter amicably, Oracle decided to bring an action against the AFPA on the grounds of counterfeiting based on the unauthorized use of the Purchasing software suite. To this effect, Oracle claimed the AFPA (and Sopra Group, under the contractual indemnification terms) to pay 3,920,550 euros as lump sum indemnification for the unauthorized copy and use of the Purchasing software for 885 named users, plus 9,487,731 euros as indemnification for the unauthorized use of the technical support services and Purchasing software upgrades, i.e. a total of 13,408,281 euros.

The defendants claimed that Oracle knew that the Purchasing software suite was part of the solution proposed by Sopra to the AFPA under the contract, the solution having been approved with the purchase order issued by Oracle. Indeed, Sopra had invoiced the AFPA for the installation, use and support services for the Purchasing program. The AFPA also claimed that they had been using Purchasing in good faith since the beginning of the contract term and that they had committed no breach.

- Disagreement over the legal qualification of the audit conclusions
In this case, the parties’ claims were based on conflicting legal characterizations resulting in  distinct legal consequences: intellectual property infringement vs. breach of contract

Oracle claimed that since the AFPA wasn’t authorized to use the software under dispute, they were infringing (counterfeiting) Oracle’s intellectual property rights. Counterfeiting is a continuing offense, not subject to prescription, and the counterfeiter cannot claim good faith.

Contrary to Oracle, the AFPA claimed that this was a contractual issue. According to the AFPA, the Purchasing suite was included in Oracle’s licensed software programs. If not, the AFPA claimed that they had performed the contract in good faith since the software programs had been installed by Sopra. Contractual claims are prescribed after 5 years (art. 2224 of the French civil code). Indemnification is governed by the rules regarding contract performance set forth in the Civil code.

- The Court decision
To characterize the dispute, the judges recalled that the only existing issue between the parties was whether the license included the Purchasing suite. Oracle never claimed that the AFPA had used counterfeit software or rolled out software not supplied by Sopra, or that the number of licenses did not correspond to the number of users. The judges therefore held that the dispute was only focusing on the scope and performance of the contract and not on a counterfeiting issue. Therefore, the 5 year statute of limitation and contractual indemnification rules applicable to the damage suffered as outlined in the French civil code are applicable.

Regarding the performance of the contract, Oracle had delivered four CDs, including one containing the Oracle Applications/E Business Suite II i solution, with the Financial and Purchasing suites. Oracle’s position was that although the Purchasing software was on the CD, it was not included in the license.

Based on the documents disclosed during the proceedings, the judges held that Oracle maintained doubt and confusion on what was really included in the software solution licensed: either the Purchasing software program wasn’t included in the scope of the AFPA license, and then it shouldn’t have been delivered to them, or it was included in the license since it was actually delivered in execution of the purchase order.

The judges decided that the AFPA used the Purchasing software suite without fault since this program had been included in the CDs prepared by Oracle. Oracle must have always understood and admitted that the license included the use of that software suite.

As a consequence of this legal characterization, the judges held that the AFPA didn’t infringe Oracle’s intellectual property rights since the software was presumably included within the contractual scope of the license. The judges therefore decided that Oracle’s claims against the AFPA were prescribed and Oracle’s claims of 13,408,281 euros were unfounded. In addition, Oracle had to pay procedural fees to the AFPA and to Sopra amounting to 100,000 euros (art. 700 of the procedural code). This decision is pending appeal.


    Based on this case law, software license audits are indeed legitimate tools for vendors to check that the licenses are performed within the contractual boundaries. However, audits should not be used outside and beyond their original purpose. As shown with these two cases, given the amounts claimed by the vendors, users no longer hesitate to challenge such practice, claiming bad faith or abuse from the vendors (although such claims much be proved legally). Another potentially valid claim could be the complexity of certain types of licensing rights which can be extremely difficult for licensees to manage effectively.

Although these cases didn’t raise the issue of license complexities, but were brought essentially because of misunderstandings and communication issues between the parties, we recommend that software vendors ensure that licensing rights are set forth in clear terms and that licensees can easily keep track of the rights used.


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(1) Nanterre civil court of first instance (Tribunal de grande instance de Nanterre), summary judgment, 12 June 2014, Oracle Corp., Oracle International Corp., Oracle France vs. Carrefour, Carrefour Organisation et Systèmes Groupe ; Paris civil court of first instance (Tribunal de grande instance de Paris) 6 November 2014, Oracle Corp., Oracle International Corp., Oracle France vs. Association Nationale pour la Formation Professionnelle des Adultes (AFPA) & Sopra Group

(2) Article L.112-2 of the Intellectual property code

 

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December 2015