By Emmanuel Chinalu Okorie, Esq. & Christian N.Oti, Esq.

INTRODUCTION

In the world today where the commercialization or public expansion and distribution of creative or artistic work is germane to the personal fulfilment and satisfaction of an author, the need to always expand and point out how the skills and distinctive work of a person can be marketable through intellectual property law becomes imperative.

It is trite that these intangible rights can be a huge source of income as well to inventors or authors and a big boost to the economy of a nation. This is why the frontiers of intellectual property rights must continually be expanded and protected by the law.

This paper seeks to highlight some marketable skills in the area of sports and makes a case that these skills can be preserved properly when the law of intellectual property is given a true and purposive meaning and expansion. The relevance of doing so at this time is pointed out and the challenge of linking sports skills to intellectual property law is also expressed. It concludes with some recommendation on what can be done to effectively cover these skills in sports.

MEANING, TYPES AND NATURE OF INTELLECTUAL PROPERTY

Intellectual property refers to the aggregate of rights, interests and authority that a person has over creative work. Intellectual property rightsare the resources that an author, inventor, designer, statutory or true owner expends to produce a distinctive work of the mind. They are intangible rights and are mostly described properly as a chose in action.

The nature of intellectual property is to help maintain the intellectual and industrial rights of creators vide the law. Intellectual property rights are immovable in nature. The rights of an inventor or creator can be in the form of copyright, trademark, patent and industrial designs. The idea of copyright is to protect the very expression of creativity. Trademark deals with the distinctive mark, name, symbol or inscription used in business or commercial relations by the owner.Patent and Industrial designs are instructive with respect to inventions and industrial processes that are novel or not obvious to the state of the arts. The inventor is thus given a monopoly sort of, over the invention to produce and market the same over a specific period.

It is noteworthy to state that the foundation of these rights is as provided by the law. However, we must point out that copyright need not as it went through any formal registration for the right therein to inure to the creator. It is strictly intrinsic and to be enjoyed by him. These rights can, however, be licensed exclusively or partly to another for use, with or without royalty.

RELEV ANCE OF INTELLECTUAL PROPERTY LAW TO SPORTS

The relevance of intellectual property has become really glaring lately considering the fact that sport is no longer in the realm of entertainment but more importantly has metamorphosed to a billion-dollar business enterprise.You talk about the branding of the players’ jerseys with their names, of course, the broadcasting and transmission of the games, the special skills or styles expressed in the field or track, the commentaries, e.t.c., all form valid aspects of the sport that intellectual property law protects.

Patent, for instance, helps to protect many of the technological and scientific inventions that are used for the enablement of good sporting activities, like the goal line or video assistant referee. The sporting wears enjoys the benefit of a trademark as well. This shows us the enormous advantage of intellectual property law affords in the marketability of sports.

INTELLECTUAL PROPERTY AND SPORTS

The 2019 world Intellectual Property Day came with an interesting theme: Intellectual Property and Sports. To put the theme into achievable perspective and to properly capture the existing synergy between Intellectual Property and Sports, below is an excerpt of World Intellectual Property Organisationʼs statement made available on its official website; “the global sports ecosystem is made up of a complex web of players and commercial relationships underpinned by IP rights. The strategic use of these rights has, to a large extent, enabled the rapid growth of the global sports industry, and will continue to play a central role in the future evolution of sports in a rapidly evolving and evermore technology-driven landscape. A focus on IP and sports also offers significant opportunities to foster the social, economic and cultural development of all nations”.[1]

On this, there have been campaigns by sports stakeholders on the need to protect the name,[2] mark, skill, sound and sports moves of sportspersons. As nothing remains constant other than change, so as athletes do not remain on limelight throughout their lifetime. It is a known fact that most sportspersons retire before their fortieth birthday. To keep the body and soul together, some take up coaching, marketing and scouting, fitness training, sports commentating and analyzing, while some disappear from the radar of sports with no trace. But the protection of a famous name, mark, sound and novel innovation could last for a valuable time which could be of commercial sustenance to an athlete, clubs and federations, hence, intellectual property (rights) in sports[3].

INTELLECTUAL PROPERTY AND STAKEHOLDERS IN SPORTS

Intellectual property law protects the skills, names,[4] marks,[5] images[6] and innovations[7] of individuals for a given period of time. Aspects of intellectual property law include trademarks, copyrights, patents, designs and trade secrets. It is interesting to note that a particular sports design, technology or invention could cover or have more than one aspect of intellectual property[8]. Sportspersons, coaches, sports companies, federations, sponsors and inventors could take exclusive control of their skills, marks, names, game plans and inventions through the above-listed aspects of intellectual property law. In Lionel Andres Messi Cuccittini v. European Union Office for Intellectual Property (EUIPO)[9], delivered on the 26th of April, 2018, the General Court of the European Union stated that Lionel Messi may register his trade mark `MESSIʼ for sporting equipment and clothing. It held that the football player’s fame counteracts the visual and phonetic similarities between his trademark and the trademark `MASSIʼ belonging to a Spanish company. It was further held by the General Court of European Union that the level of fame associated with the name Messi was sufficient to preclude any likelihood of confusion. Earlier before the above appeal, in November 2011, the Spanish company’s notice of opposition to the registration of MESSI before EUIPO was upheld. On the appeal, it was allowed and Lionel Messi successfully registered his name after a prolonged legal battle with ʼMassiʼ, the famous cycling brand in Spain.

The essence of intellectual property in sports is to prevent unauthorized persons from associating with such sports invention, work, mark, name or sound with the patented, trademarked or copyrighted work, mark, name or sound. This is to ensure that the fame attached to such mark, name[10] and sound is not commercially shared and impeded.

Another daunting intellectual property challenge faced by stakeholders is Cyber squatting. This is a regular problem faced by celebrities, athletes, clubs and federations on a daily basis. The World Intellectual Property Organization (WIPO) has determined hundreds of cases on this. These cases involved football clubs, federations, sportsperson and inventors. Cyber squatting is where an unauthorized person secures the name of a famous sportsperson, club or federation as a domain name[11] with the intention to make a profit from such name. In most situations, the public would believe that it is the famous sportsperson or company that owns such website[12] or that the famous athlete or club is associated with the website or page. In Paris Saint of Germany (PSG) v. MHP Private[13], where the complainant (PSG), in January 2019, filed a complaint against the Respondent (MHP Private based in Utrecht, Netherland) for securing and using psgfootball.com, a domain name which was confusingly similar to its trademark (PSG). It was evidenced that the Respondent registered the domain name in October 2, 2017, without getting approval or having any existing relationship with the complainant. It was held that the domain name was confusingly similar to complainant’s trademark, that the domain name was to compete with the complainant or to capitalize on the goodwill of the complainant’s mark, and the panel further held that the registration was done in bad faith. The panel ordered that the disputed domain name be transferred to the complainant.

Some athletes, clubs[14] and federations[15] have argued that the use of their names by some unauthorized persons is a clear deprivation of their publicity, an infringement on their trademarks rights to enjoy their fame and also a violation of trademark Act, thereby impeding their commercial activities. The truth is, with the increasing and easier access to the internet, the use of famous names of celebrities and athletes by unauthorized persons is bound to increase.

Presently, Cyber-squatting is not only a trademark infringement in Nigeria, but it is also a criminal offence. This is made pursuant to the enactment of the Cyber Crime Act, 2015. Section 58 of the Act defines Cyber-squatting as:

The acquisition of a domain name over the internet in bad faith to profit, mislead, destroy the reputation and deprive others of registering the same, if such domain name is: (i) similar, identical, or confusingly similar to an existing trademark registered with the appropriate government agency at the time of the domain name registration;

(ii) identical or in any way similar with the name of a person other than the registrant, in the case of a personal name; and

(iii) acquired without right or with an intellectual property interest in it.

This means, that an owner of a trademark may not only seek injunctions and̸ or damages against an infringer, but the owner could also report the infringer to the appropriate criminal prosecuting authorities.

In sports, the commercial currency with which an athlete trade with is his or her name and the huge endorsement deals secured by an athlete is sealed majorly by his famous name. This is the reason why most athletes give their all to break records or have some records to their names because a second gained in a sporting event could be the defining moment for good endorsement deals[16].So, the protection of the name, mark, sound and invention of the stakeholders in the protection of the future of the ecosystem[17].

To determine whether a complainant deserves to claim back a domain name, the court looks at whether the complainant has built up commercial value[18] in the name, how the use of the name has affected his reputation, whether unauthorized operator operates the name in bad faith[19] and whether the respondent knew about the complainant’s famous name[20] before or at the point the respondent started using the (trademark) name.[21]

Aside from cyber-squatting, legal issues could arise from trademark dilution. Trademark dilution could be in the form of blurring or tarnishment. It is blurring where the defendant drops some known or unique marks in the plaintiff’s work and tarnishment where the defendant uses or presents the plaintiff’s mark in poor quality or bad manner. In the case of NBA Properties v. Untertainment Record LLC,[22] where the defendant who was a producer of albums by artists, had a silhouetted player holding a gun alongside the word ‘Drug’. The silhouetted player was same with Jerry West’s silhouette bouncing a ball which is the official logo of National Basketball Association, the logo in most cases represent the National Basketball Association. The plaintiff’s application for infringement against the defendant was granted on the ground that the use of same silhouetted player with a gun and the word ‘Drug’ instead of its usual bouncing ball is tantamount to trademark dilution (tarnishment) and would tarnish the image and reputation of the National Basketball Association (NBA) in the eyes of the public, their partners and corporate customers.

There is hardly any equipment, item, innovation used within the sports community that is not trademarked, copyrighted or patented. Sportspersons are also allowed to use their trademarked names for sporting equipment and clothing lines.[23] Recently, Lamar Jackson filed an action against Amazon,[24] claiming that Amazon is selling unlicensed merchandise using his likeness and registered trademarks. Lamar Jackson who used trademark laws to protect marks associated with his name, also claimed that the unauthorized action of Amazon is commercially affecting his merchandise company, Era 8 Apparel. In the case of Football Dataco Ltd & Ors v. Yahoo! UK Ltd and Britten Pools & Ors,[25] the Plaintiff sued the Defendants for publishing its premiership fixture list, claiming that the fixture list was protected as a literary work. The Defendants argued that a football fixture could not come under a literary work because of lack of originality. The Plaintiff was able to establish that the creation of premiership fixture list goes through a series of processes with professional inputs from experts. The court ruled in favour of the plaintiff that there were sufficient skill and expertise involved in the creation of the list, therefore, it is protected by copyright as a literary work.

Novel technological innovations have enhanced the efficiency of measurements within the sports community, the review of on-field decisions in real-time,[26] the image quality and analysis of sports participants,[27] the regulation and control of doping issues, improved betting systems within the available markets and the consumption of the products of sports by sports consumers. The essence is not only to encourage innovation by giving an innovator an exclusive right over his innovation but to promote better innovation among sports technologists. These aspects of Intellectual property in sports help in promoting investment and commercialization of novel sports technologies.

MARKETABLE AND SECURED SKILLS

There have been arguments whether an athlete’s skill or sports moves, celebration or mode of playing (golf) are marketable and could be patented or trademarked.[28] The argument on granting a patent application to a sports move has not received legal backing because it may amount to unnecessary restriction and stifling of a style of play on-field or individuals’ reactions at a given time of play. Generally, Patent Acts in most jurisdictions provide for the protection of tangible novel innovations like sports applications, gadgets and equipment, the Acts did not provide for intangibles things like human movement, the pattern of reaction towards a game etc. Also, the issue of originality comes to mind when considering a sports move. One can easily determine the originator of a novel sports technology or innovation, but it will be difficult to determine the originator of a skill. How would the authorities determine that a particular sports move originated by a person? How would the authorities determine that the ʼsnake-biteʼ move originated from Ronaldo de Assis Moreira (Ronaldinho)? The above may make it difficult for a sports move to come under patent registration.

A skill or sports move[29] may not be made exclusive to a particular sportsperson where another sportsperson uses same skill or celebration in the field of play but where it relates to the use of a given celebration style or sports move on a surface or clothing, the originator could claim exclusive right over it through trademark.[30] The Ultimate Fighting Championship all-time ring announcers and masters of the Octagon; Bruce Anthony Buffer and Michael Buffer have trademarked their catchphrases “It’s time” and “Let’s get ready to rumble”[31] respectively. Their unique skills, styles of presentation and voices are the commercial currencies that have made their names known within the Octagon.

THE ROLE OF PLAYERS’ UNION IN SPORTS AND INTELLECTUAL PROPERTY

Players’ Union is one of the most outstanding developments in modern professional sports. These Unions or Associations protect the interest of players in agent regulation, doping regulation, betting, players licensing agreement, sports marketing and rules, equality in sports, players’ remuneration, benefits and welfare of players and also responsible for the sale and management of the players’ intellectual property rights. The growth of the sports industry, the commercialization and consumption of almost all the product of sports brought about the need to collectively protect the rights of players within the sports ecosystem. Professional sports have been positioned to market selected intellectual properties capable of being marketed collectively,[32] to actualize this, Players’ Union of various sports enter into various intellectual property-related contracts on behalf of the players. Players Unions or Associations on behalf of players sell licensing rights of their players as a group. CBS Interactive Inc. v. National Football League Players Association (NFLPA), Inc.[33], it was provided that individual NFL player assigns their Group Licensing Right to NFLPA, which then has the right to license the use of the individual player’s names, signature, facsimile, voices, pictures, photographs, likenesses, and biographical information in connection with “group licensing programs” involving six or more players.

The Regular purchasers of these rights include trading card companies, electronic video games manufacture, digital products, jersey and apparel companies, printed products, collectables and novelties.[34] In some situations, players’ unions sell all intellectual property rights to the league. Under the Universal Declaration of Players Rights, a player has among other rights, right to privacy and the protection of personal data and right to protection of name, image and performance. This means that every player is entitled to have his or her name, image and performance protected. A player’s name, image and performance may only be commercially utilized with his or her consent, voluntarily given.[35] Of a fact, most players experience their first and official contract at their pro level. Some of these contracts come with intellectual property-related rights, these range from image right[36] of an athlete, jersey number of a player, and to the protection of his or her name. The Players Union is usually the first support system received by a player outside his team. The fact is that individual players do not have enhanced bargaining power without the Players Union. Therefore, Players Union are always on the bargaining table to protect the intellectual property right of the players. There are cases where the Players Union have objected on the use of some sporting equipment because they reveal the personal techniques and game plan of an athlete, especially where the novel innovation, contract or policy breaches the right to privacy and the protection of personal data of a player.

CONCLUSION

From the above, it is clear that sportspersons are now thinking of after sports wealth through intellectual property rights and protections. The protected intellectual property sports products produced by sportspersons, clubs, federations and sports innovators usually consumed by sports consumers are all within the exclusive rights of the producers. It is apparent that sports consumers taste are increasing and changing, novel innovations in sports technologies and applications that will aid sporting skills and activities in the homes of athletes and in sports isolated training centres are on the increase.

More also, Covid-19 pandemic has created room for the use of indoor sports technology and applications. The advancements in the sports ecosystem have given us new perspectives on the need to invent better sports technology, commercialize the novel innovations and also protect them. Before now, there has been growth in out-door facility training equipment, the next level of creation will be in-house training gadgets or equipment for active and contact sports. When these sports aided devices are invented, the right for exclusive control, use and marketing of these equipments become paramount, hence, the need for a patent, trademark registration, copyright and design. Presently, due to the growth in sporting technology,[37] use of sporting applications[38] and the application of computers[39] in sports-related events, sports technology innovators do not only commercialize their novel sports technologies, but they also seek to have exclusive control of their innovations through patents. This has led to Sports Technology Awards (STA), where the vital roles technology plays in sports are celebrated.

[1]Intellectual Property and Sports. Available at https:∕∕www.wipo.int∕ip-outreach∕en∕ipday∕2019∕ip_sports.html. Accessed on May 29, 2020.

[2]Usain Bolt, Cristiano Ronaldo and Lionel Messi are Sporting celebrities that successfully trademarked their names. Available at https:∕∕www.lexology.com∕library∕details.aspx?g=23638806-354d-4d22-962f-d6310a25aoe5. Accessed on June 2, 2020.

[3]The International Trademark System and Sports. Available at https:∕∕www.wipo.int∕ip-outreach∕en∕ipday∕2019∕madrid_trademarks_sports.html. Accessed on May 29, 2020.

[4]Eldrick “Tiger” Woods v. Whistan Bay Golf Shop, Claim No.FA0608000772886, National ArbitrationForum, decided on September 21, 2006. The Respondent secured the domain:tigerwoodscoursedesign.com. Available at: https:∕∕www.adrforum.com∕domaindecisions∕772886.htm. Accessed on May 29, 2020.

[5]Nike, Inc. v. Circle Group Internet, Inc. WIPO Mediation and Arbitration Centre Case No. D2002-0544. Decided on September 10, 2002. The compliant of the complainant was that the respondent registered a domain name: justdoit.net. https:∕∕www.wipo.int∕amc∕en∕domains∕decisions∕html∕2002∕d2002-0544.html. Accessed on May 29, 2020.

[6]Image rights and international footballers: the curious case of Mohamed Salah and the Egypt Football Association by Jake Cohen. Available at http:∕∕www.lawinsport.com∕topics∕item∕image-rights-and-international-footballer-the-curious-case-of-mohamed-salah-and-the-egypt-football-association. Accessed on May 29, 2020.

[7]Improved Formula 1 cars and tour bikes, improved rackets for long tennis

[8]Sports and Intellectual Property. Available at https:∕∕www.wipo.int∕ip-sport∕en∕. Accessed on May 29, 2020

[9]GCEU judgement in Case T-554̸14, delivered on April 26, 2018.

[10]Lionel Messi successfully registered his name after a prolonged legal battle with ʼMassiʼ, the famous cycling brand in Spain. Massi opposed the registration of the name Messi because believe it was very similar and were likely to give rise to consumer confusion. It was held by the General Court of European Union that the level of fame associated with the name Messi was sufficient to preclude any likelihood of confusion

[11]Eldrick “Tiger” Woods v. Whistan Bay Golf Shop, Claim No.FA0608000772886, National Arbitration Forum, decided on September 21, 2006. The Respondent secured the domain: tigerwoodscoursedesign.com. https:∕∕www.adrforum.com∕domaindecisions∕772886.htm. Accessed on May 29, 2020.

UEFA v. Funzi Furnitures, WIPO Mediation and Arbitration Centre Case No. D2000-0710.

[12]Nike, Inc. v. Circle Group Internet, Inc. WIPO Mediation and Arbitration Centre Case No. D2002-0544. Decided on September 10, 2002. The compliant of the complainant was that the respondent registered a domain name: justdoit.net. https:∕∕www.wipo.int∕amc∕en∕domains∕decisions∕html∕2002∕d2002-0544.html. Accessed on May 29, 2020.

[13]WIPO Mediation and Arbitration Centre Case No. D2019-0036, decided on February 18, 2019

[14]FC Bayern Munchen AG v. Pamella Kraft, WIPO Mediation and Arbitration Centre Case No. D2017-0516. Decided on March 9, 2017. The compliant of the complainant was on the registration and use of bayernmunchfcproship.com. Club Athletica Borca Juniors Civil Association (Borca Juniors) v. Perfect Privacy, LLC, WIPO Mediation and Arbitration Centre Case No. D2019-2634, decided on January 7, 2020. In this case, the Respondent secured a domain name: bocajuniors.com.

[15]Federation International de Football Association (FIFA) v. Moussa Riffi, WIPO Mediation and Arbitration Centre Case No. D2019-0390, decided on April 19, 2019. National Collegiate Athletic Association v. WhoisGuard Protected, WhoisGuard Inc, WIPO Mediation and Arbitration Centre Case No.D2020-0336, decided On April 4, 2020. The complainant in this case has several trademarks and websites called MARCHMADNESS. The Respondent secured a domain name: marchmodeness.com, the respondent was ordered to return the domain name to the complainant.

[16]Usain Bolt records were all on seconds differences. http:∕∕en.m.wikipedia.org∕wiki∕100_meters. Accessed on May 29, 2020.

[17]Christopher Renzi v. JBS Textile Group A∕S and Cristiano Ronaldo a.k.a. Cristiano Ronaldo Dos Santos Aveiro, U.s District Court for Rhode Island. Case No. 14-cv-00341. (This case is still pending in court. It is an action against Cristiano Ronaldo and the company (JBS Group) behind his line of sleek underwear over a cease and desist letter to the complainant on the use of a trademark CR7. https:∕∕www.google.com∕amp∕s∕mobile.reuters.com∕article∕amp∕idUSKBN0FZ1ZK20140730. Accessed on May 29, 2020.

[18]Barry v. Zito, ICANN, Claim No. FAO207000114773 (2002)

[19]Eldrick “Tiger” Woods v. Whistan Bay Golf Shop, Claim No.FA0608000772886, National Arbitration Forum, decided on September 21, 2006. The Respondent secured the domain: tigerwoodscoursedesign.com. Available at https:∕∕www.adrforum.com∕domaindecisions∕772886.htm. Accessed on May 29, 2020.

[20]Federation International de Football Association (FIFA) v. Moussa Riffi, WIPO Mediation and Arbitration Centre Case No. D2019-0390. Decided on March 19, 2019. The compliant of the complainant was that the respondent registered and used a domain name: fifa2022.com.

[21]Green v. Fornario, decided on May08, 2007 by the United States Court of Appeal, Third Circuit, Case No. 06-2649. Available at https:∕∕caselaw.findlaw.com∕us-3rd-circuit∕1339444.html. Accessed on May 29, 2020.

[22]No. 99 Civ. 2933 U.S. Dist. LEXIS 7780 at 15 (S.D.N.Y. May 25, 1999)

[23]GCEU judgement in Case T-554∕14, delivered on April 26, 2018.

[24]https:∕∕www.espn.com∕nfl∕story∕_∕id∕28958317∕ravens-qb-lamar-jackson-sues-amazon-unlicensed-merchandise%3fplatform=amp. Accessed on June 2, 2020.

[25](2010) EWHC 841 (CH).

[26]Use of Video Assistant Referee (VAR). Available at https:∕∕football-technology.fifi.com∕en∕media-tiles∕video-assitant-referee-var∕. Accessed on May 29, 2020.

[27]Various football clubs partnerships with Intel to deploy Intel® True VR technology. https:∕∕www.google.com∕amp∕s∕www.cnbc.com∕amp∕2019∕02∕08∕intel-teams-up-with-epl-teams-offers-soccer-fans-immersive-experience.html. Accessed on May 29, 2020.

[28]https:∕www.upcounsel.com∕how-to-patent-a-spor. Accessed on June 2, 2020.

[29]Ronaldihoʼs snake bite, Cristiano Ronaldoʼs `siiiiiʼ celebration, Kylian Mbappeʼs crossing his arms in celebration of a goal, Erling Haaland’s meditation or yoga pose and LeBron Jamesʼs Lower the Roof Dance.

[30]https://money.cnn.com/2016/08/19/news/trademarks-athletes-usain-bolt-olympics/. Accessed on June 6, 2020.

[31]https:̸̸i.stuff.co.nz∕sport∕other-sports∕89076771∕lets-get-ready-to-rumble-five-words-that-have-earned-michael-buffer-millions. Accessed on June 2, 2020.

[32]CBS Interactive Inc. v. National Football League Players Association, Inc., et al. Available at https:∕∕www.loeb.com∕en∕insights∕publications∕2009∕05∕cds-interactive-inc-v-national-football-league-p_. Accessed on June 1, 2020.

[33]Ibid.

[34]https:∕∕nhlpa.com∕the-pa∕business-affairs∕licencsing. Accessed on June 1, 2020.

[35]https:∕∕nhlpa.com∕the-pa∕pa-programa-and-partnerships∕universal-declaration-of-players-rights. Accessed on June 1, 2020.

[36]Image rights and international footballers: the curious case of Mohamed Salah and the Egypt Football Association by Jake Cohen. Available at http:∕∕www.lawinsport.com∕topics∕item∕image-rights-and-international-footballer-the-curious-case-of-mohamed-salah-and-the-egypt-football-association. Accessed on May 29, 2020.

[37]https:∕∕www.topendsports.com∕resources∕technology.htm. Accessed ON June 2, 2020.

[38]Golf Swing Analyzers. Available at: https:∕∕www.topendsports.com∕sport∕golf∕apps.htm. Accessed ON June 2, 2020.

[39]Use of Hawk-Eye Technology (for Tennis and Cricket), Video Assistant (VAR) and Goal line technology (for football). https:∕∕www.topendsports.com∕resources∕technology.htm. Accessed ON June 2, 2020.

EMMANUEL CHINALU OKORIE is a Sports Law enthusiast who is also interested in Tax Law. He is currently involved in rendering of pro bono legal services to indigent persons standing trial for criminal offences; and this he does in conjunction with Hope Behind Bars Africa Initiative in Benin City, Edo State., +2348032301666, [email protected]

CHRISTIAN N. OTI, is a passionate lawyer in active legal practice. He is enthusiastic of Real and Intellectual Property Law., [email protected]