Filed under Uncategorized
Patent Revived!
If you receive an issued patent, it is a big accomplishment to protect your invention. You succeeded in showing the United States Patent and Trademark Office (USPTO) that your invention was useful, novel, and non-obvious. Aside from the business implications to monetize the invention covered by the patent, often overlooked are the mandatory payment of maintenance fees at the 3.5, 7.5, and 11.5 year points after issuance of the patent.
Assouline & Berlowe recently helped a client revive an expired patent for unintentional delay. A big win for the client as he regained his patent rights that were lost. If a patent owner misses the deadline to pay the applicable maintenance fee, there is a six month grace period to pay with added filing fees. After the grace period expires, the patent will become abandoned.
If the failure to pay the maintenance fee was unintentional, the patent owner can petition the USPTO to reinstate the patent due the unintentional delay. Such petitions are generally looked upon favorably (if unintentional) by the USPTO if filed within two years from the deadline. However, if the petition is filed after two years from the deadline, the USPTO in 2020 updated their rules for proving unintentional delay.
The USPTO may ask for additional information to assess the circumstances behind the nature of the unintentional delay. The patent owner will have to demonstrate that the entire duration of the delay was unintentional. However, if any portion of the delay was intentional, the delay will not qualify as unintentional and the request will likely be denied.
Given the value of an issued patent, it is important for patent owners to calendar the maintenance fee deadlines upon receipt of the issued patent. Notably, the maintenance fee deadlines are printed on the inside of the patent deed, both electronically and in hard copy. If a patent maintenance fee deadline is missed unintentionally, it is critical to act promptly and engage knowledgeable patent counsel to petition for reinstatement of the abandoned patent.
If you have questions about your patent or Intellectual Property rights, please contact Florida Bar Board Certified Intellectual Property Attorney Greg Popowitz.
Greg M. Popowitz, Esq.
Board Certified in Intellectual Property Law
Registered Patent Attorney
Miami Tower
100 SE 2nd Street, Suite 3105
Miami, Florida 33131
Main: 305.567.5576
Fax: 305.567.9343
Email: GMP@assoulineberlowe.com
http://www.assoulineberlowe.com/
Intellectual Property, Labor & Employment, Creditors’ Rights & Bankruptcy, Business Litigation, Corporate & Finance, Real Estate, International Law, Succession Planning
Filed under Intellectual Property, Patent Prosecution
EMPLOYMENT LAW UPDATE ON INDEPENDENT CONTRACTORS By: Ellen M. Leibovitch, Esq.
EMPLOYMENT LAW UPDATE – From Ellen Leibovitch, Head of Labor & Employment, Assouline & Berlowe – Nearly three (3) years ago, the Department of Labor (DOL) advised as to its plan to revise the rules on determining when workers could be properly classified as independent contractors. Effective March 11, 2024, the final rule will officially be published and the 2021 proposed rule rescinded.
The final rule retains the same factors from the proposed rule, but employers are now required to use a “totality of the circumstances” analysis where no single factor or group of factors carries greater weight than any other factor. This final rule differs from the 2021 proposed rule under which two factors – the employer’s control over the work and the worker’s opportunity for profit or loss – carried greater weight over the other factors.
The six factors to be considered in classifying a worker as an independent contractor under the final rule are the following:
1. The degree to which the hiring entity controls how the work is done.
2. The worker’s opportunity for profit or loss.
3. The amount of skill and initiative required for the work.
4. The degree of permanence of the working relationship.
5. The worker’s investment in equipment or materials required for the task.
6. The extent to which the service rendered is an integral part of the hiring entity’s business.
The DOL believes this final rule will reduce the possibility of employees being misclassified as independent contractors. The DOL also aims to offer increased guidance for businesses that engage individuals who are in business for themselves. A detailed compliance guide from the DOL can be found at the following link:
https://lnkd.in/en9bYnZM
For more information contact Ellen M. Leibovitch at 561-361-6566 or by email at eml@assoulineberlowe.com
Filed under Human Resources, labor and employment law
ELON MUSK PROTECTED BY THE APEX DOCTRINE
Florida Appeals Court Quashes Effort to Depose Elon Musk in fatal Tesla crash case citing Florida’s Apex Doctrine.
Barrett Riley crashed his Tesla Model X driving 116 mph. Riley, along with his passenger, Edgar Monserratt (estate of Monserratt is respondent) died in the crash.
Monserratt’s father, as personal representative, sued Tesla for negligence alleging that a Tesla service technician deactivated the control to allow the car to go no faster than 85 mph. After the crash, Elon Musk called the Riley’s father, James Riley to offer his condolences. At some point during the conversation, Mr. Musk said, according to James Riley something to the effect of, “perhaps we should not have removed the limiter.”
The estate of Monserratt sued Tesla in Broward Circuit Court, in Fort Lauderdale, Florida. In December of 2021, Plaintiff sought to take Mr. Musk’s deposition regarding the phone call. Mr. Musk signed an affidavit denoting the conversation as a sympathy call. The affidavit also explained his roles and duties at Tesla, as well as a deposition causing substantial burden and hardship for him. Outside of the sympathetic aspect of the phone call, Musk had no personal knowledge of the situation.
The matter was then administratively transferred to another judge, and Plaintiff once more sought to depose Musk. In lieu of deposition, Musk agreed to respond to discovery (answered ROGS and RFPs) where he once more reiterated that the phone call was made for sympathetic purposes only and he had no other personal knowledge of the situation. Plaintiff once more sought to compel deposition of Musk, and the trial court granted the motion reasoning that there was a dispute as to what was said during the phone conversation.
Rule/Analysis
In 2021, the Florida Supreme Court amended Fla. R. Civ. P. 1.280(h) to expressly adopt the apex doctrine in the corporate context.
The rule states: A current or former high-level government or corporate officer may seek an order preventing the officer from being subject to a deposition. The motion, whether by a party or by the person of whom the deposition is sought, must be accompanied by an affidavit or declaration of the officer explaining that the officer lacks unique, personal knowledge of the issues being litigated. If the officer meets this burden of production, the court shall issue an order preventing the deposition, unless the party seeking the deposition demonstrates that it has exhausted other discovery, that such discovery is inadequate, and that the officer has unique, personal knowledge of discoverable information. The court may vacate or modify the order if, after additional discovery, the party seeking the deposition can meet its burden of persuasion under this rule. The burden to persuade the court that the officer is high-level for purposes of this rule lies with the person or party opposing the deposition.
The rule became effective as of August 26, 2021, and applies to pending cases, inclusive of this one.
In determining whether the trial court departed from the essential requirements of law in granting the motion to compel deposition, the inquiries relevant were whether (1) Tesla demonstrated that Musk met the high level officer requirement, and (2) Tesla produced an affidavit stating Musk had no unique personal knowledge of the issues being litigated.
The Court determined that Musk met the standard of being a high level officer and the affidavit was produced sufficiently.
As such, the trial court was required to issue a protective order unless the Plaintiff could demonstrate exhausted other means of discovery, that such discovery was inadequate, and that Musk had unique personal knowledge of discoverable information.
The only arguable unique information Musk possesses is whether or not he remembered the phone conversation. Musk has twice provided responses saying as such. The Court determined that a deposition of Musk at this point would only serve to harass and burden Tesla, and disrupt Musk’s duties as CEO of Tesla.
The trial court departed from the essential requirements of law by compelling Musk for deposition. Therefore, the petition was granted, and the order for deposition was quashed.
This analysis was provided by Assouline & Berlowe (@assoulineberlowe) Litigation Associate Daniel B. McCain, Esq. in Miami. To reach Daniel, or Eric N. Assouline, who works with Daniel contact the Miami office at 305-567-5576.
Eric N. Assouline’s email address is: ena@assoulineberlowe.com
Daniel B. McCain’s email address is: dbm@assoulineberlowe.com
Filed under Uncategorized
BANKRUPTCY UPDATE – 341 Meetings Going to Zoom
The U.S. Trustee’s office has recently announced that all U.S. Trustee Program jurisdictions will be transitioning to virtual Section 341 meetings of creditors in Chapter 7, 12, and 13 cases. The Southern District of Florida has announced that this new rule will apply to 341 meetings that are scheduled to take place on or after October 1, 2023. The Southern District of Florida has scheduled a Zoom training and information session on September 14, 2023, at 12:00 p.m., with a repeat training session on September 28, 2023, at 12:00 p.m. Additional information about Zoom 341 meetings can be found here: 341 Zoom Meeting Locations
For more information, please sign up for an information session.
REGISTER [HERE] For September 14, 2023
REGISTER [HERE] For September 28, 2023
Iris S. Rogatinsky, Esq., Bankruptcy Attorney
Miami Tower
100 SE 2nd Street, Suite 3105
Miami, Florida 33131
Main: 305.567.5576
Fax: 305.567.69343
Email: isr@assoulineberlowe.com
http://www.assoulineberlowe.com/
Intellectual Property, Labor & Employment, Creditors’ Rights & Bankruptcy, Business Litigation, Corporate & Finance, Real Estate, International Law, Trust & Estates, Probate and Guardianship
Filed under Uncategorized
International Arbitration Update – 11th Circuit Reverses Course
THE U.S. ELEVENTH CIRCUIT OVERULES ITS DECADES-LONG POSITION ON ANNULMENT OF INTERNATIONAL ARBITRAL AWARDS ISSUED IN THE UNITED STATES
For more than 20 years the U.S. Court of Appeals for the Eleventh Judicial Circuit (with jurisdiction over federal cases originating from Alabama, Florida and Georgia), had sustained that the grounds to seek the annulment of a non-domestic arbitral award rendered in the United States where exclusively those included in Article V of the New York Convention and not the grounds set out in U.S. domestic law, mainly adopted in Chapter 1 of the Federal Arbitration Act (“FAA”). A non-domestic arbitral award is one issued by a panel seated in the United States but arising out of a relationship which is international in nature, thus falling under the U.N. Convention on the Recognition and Enforcement of Foreign Arbitral Awards, commonly known as the New York Convention. Now, in Corporación AIC, SA v. Hidroeléctrica Santa Rita S.A., No. 20-13039, 2023 U.S. App. LEXIS 8887 (11th Cir. April 13, 2023), the Court in banc has decided to join the other courts of appeals in extending the grounds for annulment applicable to domestic awards to non-domestic awards. A copy of the decision can be accessed at https://media.ca11.uscourts.gov/opinions/pub/files/202013039.enb.pdf.
The 11th Circuit’s long-standing position on annulment of non-domestic awards is developed in two decisions. In Industrial Risk Insurers v. M.A.N. Gutehoffnungshutte GmbH, 141 F.3d 1434 (11th Cir. 1998), the Court refused to review an arbitral award rendered in Tampa, Florida based on the moving party’s assertion that the award was “arbitrary and capricious”, a non-statutory ground to vacate a domestic arbitral award. Likewise, in Inversiones y Procesadora Tropical INPROTSA, S.A. v. Del Monte International GmbH, 921 F.3d 1291 (11th Cir. 2019), the Court also refused to vacate an award issued in Miami, Florida on grounds that the arbitration panel had “exceeded their powers” within the meaning of 9 U.S.C. § 10(a)(4) of the FAA—a ground not specifically provided by the New York Convention.
The 11th Circuit’s position arising out of these opinions was in conflict with the holding of other courts of appeals. These courts correctly maintain that the grounds for annulment of any arbitral award rendered in the United States, whether falling under the FAA or the New York Convention, are those set out in U.S. domestic law. As such, the 11th Circuit’s rationale had received substantial criticism from scholars, including the American Law Institute in its Restatement of the Law, U.S. Law of Int’l Com. Arbitration and Investor-State Arbitration (ALI Proposed Final Draft 2019). As a matter of fact, many scholars had called out the 11th Circuit for refusing to review its position on the grounds for annulment even after U.S. Supreme Court, in BG Group PLC v. Republic of Argentina, 572 U.S. 25, 44-45, 134 S. Ct. 1198, 1212-13, 188 L. Ed. 2d 220 (2014), had considered the annulment of a non-domestic arbitral award under the FAA.
With Corporación AIC, the 11th Circuit has finally agreed to modify its long-standing criteria and align with other U.S. courts of appeal. This decision equals the annulment of non-domestic arbitral awards to that applicable to domestic awards (both falling under the FAA), a very convenient development for practitioners. From now on, a moving party will be able to seek the annulment of a non-domestic award issued in Florida asserting the existence of any of the grounds set forth in the FAA (for example, that the arbitrators exceeded their powers) or any of the non-statutory grounds developed by U.S. courts (for instance, that an award is arbitrary or capricious). Although most of the grounds of annulment included in the FAA coincide with the reasons not to recognize a foreign arbitral award under the New York Convention, it is generally accepted that the grounds for annulment of the FAA are slightly broader than the grounds for non-enforcement of the New York Convention.
For practitioners, Corporación AIC is also a welcomed development as it shows a more scientific approach by the 11th Circuit in resolving international arbitration cases. Previous opinions by the 11th Circuit on arbitration issues may have lacked a deep analysis of fundamental concepts. Only two years ago, the U.S. Supreme Court reversed a decision of the 11th Circuit (Energy Power Conversion France SAS, Corp. v. Outokumpu Stainless USA, LLC, 140 S. Ct. 1637, 1645 (2020)) that was clearly mistaken. In Corporación AIC it can be observed a laudable effort by the Court to establish clear and sounds principles applicable to the annulment of international awards rendered in the United States.
Should you have any questions about the contents of this note, please contact Daniel E. Vielleville at dev@assoulineberlowe.com or (305) 567-5576.
Miami Tower
100 SE 2nd Street, Suite 3105
Miami, Florida 33131
Main: 305.567.5576
Fax: 305.567.69343
http://www.assoulineberlowe.com/
Intellectual Property, Labor & Employment, Creditors’ Rights & Bankruptcy, Business Litigation, Corporate & Finance, Real Estate, International Law, Trust & Estates, Probate and Guardianship
Filed under Appeals, Arbitration, International, International Arbitration
Employment Law Update: Telework Under the Fair Labor Standards Act and Family and Medical Leave Act
On February 9, 2023, the Wage & Hour Division of the Department of Labor issued a Field Assistance Bulletin (No. 2023-1) on (1) how to ensure workers who telework are properly paid in accordance with the Fair Labor Standards Act (FLSA), (2) how to apply FLSA’s protections to nursing employees to express milk while teleworking from their home or another location, and (3) how to apply eligibility rules under the Family and Medical Leave Act (FMLA) when employees telework or work away from an employer’s facility.
Hours Worked Under the FLSA
The FLSA requires employers to pay nonexempt employees for all hours worked regardless of the location of work. “Hours worked” includes not only active productive labor but also time spent on short breaks of 20 minutes or less. Whether an employee works from home or at the employer’s worksite, these short breaks must be considered work time.
Bona fide meal breaks (usually 30 minutes or longer), when an employee is completely relieved from work duties, are not considered hours worked nor are breaks that are longer than 20 minutes when the employee can effectively use the time for their own purposes. Again, this rule applies regardless of where the employee performs his work or take his breaks.
Break Time for Pumping Breast Milk
The FLSA requires employers provide covered employees with “reasonable break time” to express breast milk for up to one (1) year after the birth of their nursing child, as well as a location to express milk that is shielded from view and free from intrusion by co-workers and the public. This applies to employees who work at their worksite and to employee who telework from home or another location.
Employers cannot deny employees the right to take this needed break. While employers are not required to compensate nursing mothers for these breaks, an employer that compensates employees for breaks must compensate a nursing mother who uses her break time to express milk. Additionally, if an employee is not completely relieved from duty during these breaks, the time must be compensated as work time.
Telework and the Family and Medical Leave Act
The FMLA provides eligible employees with job-protected leave for qualified medical and family reasons. To be eligible for FMLA leave, an employee must be employed at a worksite where 50 or more employees are employed by the employer within 75 miles of that worksite, and the employee must have worked for at least one year and worked at least 1,250 hours in the year prior to taking leave. The law requires employers to maintain employees’ health benefits during FMLSA leave and to restore employees to their original or equivalent position when they return to work.
Employees who work remotely are entitled to the same FMLA benefits as those who work at on site. For FMLA eligibility purposes, a teleworker’s worksite is the office where the employee reports for work or the office from where they receive their assignments.
The Bottom Line
Employees who work remotely, whether from home or another location, are still entitled to the rights and benefits provided by the FLSA and the FMLA (if applicable) as set forth above. If you have any questions navigating issues arising under these laws or other employment-related matters, please feel free to contact Ellen.
Ellen M. Leibovitch
Board Certified Labor & Employment Lawyer
ASSOULINE & BERLOWE, P.A.
2385 NW Executive Center Drive, Suite 100
Boca Raton, FL 33431
Main: 561-361-6566
[Bio] [V-card] [Directions]
Filed under Labor & Employment
Employment Law Update: The Speak Out Act (SOA)
In a rare show of bipartisan cooperation, the Speak Out Act (SOA) was approved by the House of Representatives November 16, 2022 and signed into law by President Biden on December 7, 2022.
The SOA limits the enforceability of non-disclosure and non-disparagement clauses in settlement agreements entered into before an allegation related to sexual assault or sexual harassment has been made or before a claim has been filed by an employee (or an independent contractor). Note that the SOA applies only to pre-dispute agreements.
After a dispute has arisen, i.e., after an employee has alleged sexual harassment or sexual assault in a charge of discrimination or a lawsuit, employers can still include enforceable non-disclosure and non-disparagement clauses in settlement agreements. Note that the SOA does not define “dispute,” so whether an employee’s making a complaint to a supervisor or human resources without a formal filing is sufficient to create a dispute is unclear. I would argue that an internal complaint that puts the employer on notice of a dispute is sufficient.
Accordingly, if an employee signs a non-disclosure or non-disparagement agreement before an allegation for sexual harassment has been made, the employer may not be able to enforce those terms against the employee. Conversely, after the employee complains of harassment and the employer offers to settle the matter and requires the employee to sign a non-disclosure or non-disparagement agreement as part of the settlement, then such terms in the settlement agreement are enforceable.
Important to note is that the SOA was enacted to prevent situations where alleged victims of sexual harassment or assault cannot, due to having previously signed a non-disclosure and non-disparagement agreement, speak publicly about what occurred. Based on the recent enactment of the SOA, employers should now review (or have legal counsel review) employment agreements, separation agreements, confidentiality agreements, arbitration agreements, and employment policies to ensure that any non-disclosure and non-disparagement clauses therein exclude unknown disputes arising from sexual assault and sexual harassment allegations and that such documents are otherwise compliant with the SOA.
The SOA follows the enactment of the “Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act,” another federal law that prohibits employers from requiring arbitration of sexual harassment or sexual assault claims and even after an employee has signed an agreement requiring arbitration of these matters.
The SOA does not apply retroactively to agreements made before December 7, 2022 and does not bar non-disclosure and non-disparagement agreements entered into in settlement of other employment-related disputes.
For any inquiries regarding the SOA or any other employment-related matter, please feel free to contact Ellen.
Ellen M. Leibovitch
Board Certified Labor & Employment Lawyer
ASSOULINE & BERLOWE, P.A.
2385 NW Executive Center Drive, Suite 100
Boca Raton, FL 33431
Main: 561-361-6566
[Bio] [V-card] [Directions]
Filed under Labor & Employment
Protecting Trade Secrets in a Remote Work World
The recipe to make Coca Cola is one of the oldest trade secrets. But what is a trade secret and how do you protect it?
The Defend Trade Secret Act (DTSA) was signed into federal law in 2016. Since being enacted, the parameters detailing how to interpret the DTSA has worked its way through the federal court system, as is typical for any new federal law. However, with the proliferation of remote work starting in 2020 due to the Covid-19 pandemic, maintaining trade secrets by remote workers has become a challenging task. The safeguards required for on-site employees must be revised to account for employees accessing trade secrets remotely.
The DTSA defines a trade secret as:
all forms and types of financial, business, scientific, technical, economic, or engineering information, including patterns, plans, compilations, program devices, formulas, designs, prototypes, methods, techniques, processes, procedures, programs, or codes, whether tangible or intangible, and whether or how stored, compiled, or memorialized physically, electronically, graphically, photographically, or in writing if
(A) the owner thereof has taken reasonable measures to keep such information secret; and
(B) the information derives independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable through proper means by, another person who can obtain economic value from the disclosure or use of the information.
The DTSA requires an owner to take “reasonable measures” to keep trade secret information secret, but the term “reasonable measures” is not defined in the DTSA. Courts have held that “reasonable measures” include implementing written confidentiality policies, execution of nondisclosure agreements, limiting access to the trade secrets to personnel on a “need to know” basis using multi-layer credentialed access, and placing restrictions on the unauthorized transfer and use of company owned data.
Before addressing how such reasonable measures can be extended to employees working remotely, the following should be considered:
- Is the employee at a home office or in a public setting?
- Do other persons have access to the employee while viewing the trade secret?
- Is the trade secret being accessed on an open Internet connection?
- How long is the trade secret available for viewing once opened?
- Is the trade secret downloaded or stored on the remote employee’s local computer indefinitely?
- Is the trade secret itself password protected and not only credentialed access for downloading the trade secret?
- Should certain trade secrets only be accessible on-site at the employer’s facilities?
Failure to take reasonable measures to protect a company’s trade secrets could result in the trade secret losing its protected status. If that occurs and the trade secret is made public and accessible to competitors without recourse, the company may lose its competitive advantage.
An employer should have a robust employee manual that details how trade secrets are treated, who should have access to the trade secret depending on their status/role within the company, and other industry-specific factors to ensure the trade secret remains secret.
Another aspect of the DTSA is a safe harbor provision for employees (whistleblowers) who disclose a trade secret solely for the purpose of reporting or investigating a suspected violation of law or in a lawsuit made under seal. Employers are advised to pay close attention to the notice provision within the whistleblower section of the DTSA since compliance with the DTSA whistleblower notice provision could affect the ability of the employer to seek certain remedies. To be clear, employers must notify employees of the existence of whistleblower immunity under the DTSA in order to seek punitive damages and attorney’s fees against a former employee for trade secret misappropriation.
Notice of whistleblower immunity under the DTSA should be included in employee manuals, policies, confidentiality and other employment-related agreements. Employers should look at the language in these materials to ensure protection of trade secrets in the new remote work world, which certainly appears to be here to stay. If proper safeguards are not in place, the employer may lose trade secret protections and leave their trade secrets unprotected.
For any questions about the DTSA and complying with its requirements to protect your important trade secrets, contact Greg Popowitz, Board Certified Intellectual Property Attorney, and Ellen Leibovitch, Board Certified Labor and Employment Attorney.
Miami Tower
100 SE 2nd Street, Suite 3105
Miami, Florida 33131
Main: 305.567.5576
Fax: 305.567.69343
Email: GMP@assoulineberlowe.com and EML@assoulineberlowe.com
http://www.assoulineberlowe.com/
Intellectual Property, Labor & Employment, Creditors’ Rights & Bankruptcy, Business Litigation, Corporate & Finance, Real Estate, International Law, Trust & Estates, Probate and Guardianship
Filed under Intellectual Property, IP Litigation, Labor & Employment
Trademark Litigation: Don’t Go Up in Smoke
So far in 2022, GS Holistic, LLC has filed 98 lawsuits in Florida federal courts for trademark infringement to enforce its rights in various brands for vape products and accessories, including G-Pen and Stündenglass. Most consumers expect a cease and desist letter before a party initiates a lawsuit but that is not required. A plaintiff does need to conduct its own due diligence before filing a lawsuit to assess the merit in its claims. If a lawsuit is baseless or frivolous, the plaintiff may be subject to sanctions under Rule 11 of the Federal Rules of Civil Procedure.
To assess the infringement, a plaintiff may use a third party investigator to order the allegedly infringing product. When the product is received, the plaintiff assesses whether or not the seller’s product is infringing any of their intellectual property, including trademark rights. If yes, the plaintiff may file suit and use the investigator’s order as evidence of infringement.
That is the tactic in most of GS Holistic’s cases. Given the volume of federal lawsuits GS Holistic has filed in Florida this year, use of their brands G-Pen and Stündenglass are prevalent across the state. As part of a trademark owner’s rights is the obligation to police against unauthorized use of confusingly similar marks. If you suspect there is infringement, you should actively enforce your rights. If not, you may lose your trademark rights.
In case of trademark infringement, defendants should look at the DuPont factors to assess the strength or weakness of the plaintiff’s trademark infringement claim. A defendant should also look to affirmative defenses, such as laches, statute of limitations, and invalidity of the underlying trademark registration. Being served with a federal trademark infringement lawsuit can be daunting, but engaging competent intellectual property counsel will help you assess the claims and develop a strategy on defending the case, including claims against the individual owners of the entity.
For any questions about your Intellectual Property questions, please contact Greg below:
Greg M. Popowitz, Esq.
Board Certified in Intellectual Property Law
Registered Patent Attorney
Miami Tower
100 SE 2nd Street, Suite 3105
Miami, Florida 33131
Main: 305.567.5576
Fax: 305.567.69343
Email: GMP@assoulineberlowe.com
http://www.assoulineberlowe.com/
Intellectual Property, Labor & Employment, Creditors’ Rights & Bankruptcy, Business Litigation, Corporate & Finance, Real Estate, International Law, Trust & Estates, Probate and Guardianship
Filed under Intellectual Property, IP Litigation, trademark
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