EUTMs: Ensuring rights maintained in UK Model Timing Unilateral or bilateral Initial cost to business UKIPO resource Post-division conflicts Legal certainty EU plus EUTM system becomes ETM system, covering EU & UK Brexit Bilateral Low High Jersey UK treats EUTMs as covering UK Unilateral Medium Montenegro EUTMs brought onto UK register as UKTMs Brexit/ window Medium-low Tuvalu Option to bring EUTMs onto UK register as UKTMs Veto Option to bring EUTMs onto UK register as UKTMs, but UKIPO retains veto Medium-high Ireland Option to bring EUTMs onto UK register as UKTMs at renewal. EUTM covers UK in interim At renewal/ long window Conversion Option to convert EUTMs into UK applications, with full examination as of filing date etc

RCDs: Ensuring rights maintained in UK Model Unilateral or bilateral Cost to business UKIPO resource Post-division conflicts Legal certainty ‘Decoupling’ – Community design system becomes European design system, covering UK + EU. Bilateral Low High   ‘Jersey’ – UK treats RCDs as covering UK. Unilateral Medium ‘Montenegro’ – RCDs brought onto UK register as UKRDs. Medium [?] Medium-Low ‘Tuvalu’ – option to bring RCDs onto UK register as UKRDs. ‘Veto’ – option to bring RCDs onto UK register as UKRDs, but UKIPO retains veto. [Note: Query relevance for registered designs given the very limited scope of pre-grant examination conducted by EUIPO/UKIPO] Medium-High Medium-High [Note: possibly 'low' due to limited examination requirements] ‘Conversion’ – option to convert RCDs into UKRD applications, with full examination as of filing date etc. [Note: given the very limited scope of pre-grant examination conducted by EUIPO/UKIPO, arguably no difference between this model and Veto little done on design exam so this would be same as Veto?] [Note: possibly 'low' due to limited examination requirements]