Dear Sirs, Please note that on 26 October 2021, the German Association for the Protection of Intellectual Property (GRUR) published an opinion on the impact of the ECJ's decision of 8 September 2020 in Case C-265/19 Recorded Artists Actors Performers Ltd v Phonographic Performance. This opinion was then sent to the German Ministry for Justice and Consumer Protection.
GAP
German Association for the Protection of Intellectual Property (GRUR)
NGO · Germany · EU Transparency Register nonenot in register snapshot
This register number is the organization’s own declaration on its submission. It is not in the 2 Sept 2026 snapshot of the EU Transparency Register, so we neither link to it nor use it to identify this organization.
2
positions filed
in the 583 files tracked
2
legislative files
of 583 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
German Association for the Protection of Intellectual Property (GRUR) filed 2 positions between 16 Sept 2022 and 20 Jan 2023, across 2 of the 583 legislative files tracked here, attaching a full position paper 2 times.
2022 · 1 filed2023 · 1 filed
What they argued
We hereby submit the Comments of the GRUR Committee for Design Law on the European Commissions Proposal for a Regulation amending the Community Designs Regulation [COM(2022)666] and a Proposal for a Directive on the legal protection of designs [COM(2022)667] with annexes, for your kind consideration.
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