Fashion Law - Runway To Regulations
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Category: General Law
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FASHION LAW: RUNWAY TO REGULATIONS
Bhakti Ravindra Thakare, ILS Law College, Pune
ABSTRACT
Fashion law (FL) is an emerging interdisciplinary field that encompasses various legal aspects affecting the fashion industry, including intellectual property rights, business and finance, international trade, government regulations, consumer culture, privacy, and civil rights. This paper explores the concept of fashion law and its significance in protecting the rights and interests of fashion designers and artists. It traces the historical roots of fashion and highlights its impact on individual identity and societal hierarchy. The paper also discusses the rapid evolution of the fashion industry, the changing trend life cycles, and the need for legal mechanisms to safeguard designers' creations. Fashion law plays a crucial role in addressing issues, such as trademark protection, copyright infringement, geographical indications, and contractual agreements.
Although fashion law is well established in many regions, it is still an emerging field in India. Organizations such as the Fashion Design Council of India (FDCI), The Fashion Foundation of India (FFI), and the Apparels Export Promotion Council (AEPC) are working towards developing and promoting fashion law in the country. The paper emphasizes the importance of fashion law in fostering creativity, innovation, and fair practices within the fashion industry, ultimately benefiting designers, consumers, and the industry as a whole. Keywords: Fashion law, Intellectual property rights, Trademark violations, Copyright infringement, Consumer culture, Fashion Design Council of India (FDCI), Apparels Export Promotion Council (APEC)
Introduction What is Fashion and its emergence? Can one relate fashion to law and interlink both? Does Fashion Law provide opportunities as a career? Fashion is an artistic way of expressing life through signs, symbols, and icons that tells stories about certain people or groups. Fashion in a society varies greatly according to social class, age, gender, and generation, and changes quickly over time. In a common parlance, fashion describes the dominant style of clothing within a certain group or during a given period. It includes various types of apparel and accessories that people wear, such as jewellery, purses, and shoes.
As a core creative component of the business, fashion design is impacted by social and cultural norms, evolving throughout time, and Fashion design, as a fundamental creative element in the industry, is influenced by cultural and social attitudes, adapting across different eras and locations Fashion has a significant impact on an individual, his personality, and how his personality he carries in society. The concept of fashion is not a recent phenomenon but has deep historical roots with origins tracing back to Ancient Rome and Ancient Egypt. In these cultures, clothing and fashion were used as the symbol of status and cultural hierarchy. One such symbols of Roman Citizenship was Toga.
And the world of modern fashion started with a boom in the 80s and 90s, leaving room for even more expansion into the early 2000s and beyond which allowed the fashion industry to have zero rules or guidelines. “Fashion is not something that exists in dresses only. Fashion is in the sky, in the street, fashion has to do with ideas, the way we live, what is happening. ” — Coco Chanel 1 The fashion has a lot more to it than just the clothes, jewels and IP. It provides a massive understanding of a person and his personality. It is fashion that shows not only what a person is wearing or his appearance but makes us understand the personality of that person. The fashion industry is the most astonishing and vast industry in civilization. The fashion industry existed long before the word 'industry' appeared in global economic terms.
The sector has been serving from time immemorial and has had a significant impact on society, justifying
1 António Machuco Rosa, From dandyism to ‘coco’ chanel: A reassessment of Georg Simmel’s theory of
Fashion, 3 International Journal of Fashion Studies 91–110 (2016).
its rapid rise. The fashion industry in India is renowned for its rich cultural heritage, grace, and lively spirit. It showcases the intricate beauty that has endured for many generations. Not only is it comfortable, chic, and visually appealing, but it has also progressed over time. Today, it has made a significant impact on the global fashion scene, blending traditional conventions with contemporary styles. The life cycles of fashion trends today have changed; technology and social media have rendered them much shorter and less predictable than in the past. Luxury and fast-fashion brands move through the trend life cycle differently, and trend forecasting can help decode collection decisions based on different trend behaviors. The life cycle of fashion today is divided into 5 stages. 2
1. Introduction
2. Rise
3. Peak
4. Decline
5. Obsolescence3
However, to protect the fashion industry and the artists of the industry so that they have complete right over their designs there exists a fashion law. But can the fashion and law really be interlinked is the question. To answer this one needs to understand what law is. What is Fashion Law? The word ‘law’ implies in Latin: the command of him who is invested with sovereign power. Law is basically a set of rules and regulations that are created to protect the rights of the people. All individuals are to abide by these laws for the smooth functioning the betterment of the society. The existence of law gives a relief to an individual of protection of himself and his rights in the society.
2 Mélanie Mollard, Understanding fashion trend life cycles: The 5 stages, Heuritech (Jan. 27, 2022),
https://www.heuritech.com/articles/five-stages-of-fashion-trend-life-cycle/.
3 Supra Note 2.
Although the fashion industry has been under scrutiny from various disciplines for several decades and has been working for and with the industry, Law has finally now discovered the love for fashion. According to Susan Scafidi who happens to be the Director of Fashion Law Institute defines that “Fashion Law is law of everything that we wear, including how we create it, how we produce it, how we distribute it and how we sell it. ” 4 Guillermo C. Jimenez (Professor of International Trade and Marketing): “Fashion Law covers issues from Intellectual Property, Business and Finance, International Trade, Government Regulation, Consumer Culture, Privacy and Civil Rights. ”5 These Definitions illustrate the broad and interdisciplinary nature of the fashion law, addressing various legal aspects that affect the fashion industry.
Historically, fashion has been associated with sumptuary laws that served to regulate rank or position in society by imposing dress codes, which were frequently marked by overtly sexist and racist rules. These laws granted the privileged upper class the right to wear certain types of garments while prohibiting the lower classes from wearing specific attire. In ancient Greece, religious or secular rules were often used to regulate clothing. And today there is always a threat to the artists in the fashion industry related to their designs not only in clothes but also in other elements of fashion such as ornaments, footwears, and other accessories. There needs to be a certain mechanism guiding such threats and provide protection to the artists to use or sell their designs and have complete right over it.
Fashion Law therefore serves as the mechanism guiding and protecting the interests of fashion design artists. It encompasses various legal areas such as Intellectual Property rights, Finance, Business, International Trade and Government Regulations, and Consumer Culture and Civil Rights. By addressing issues like Trademark Protection, Copyright Infringement, Protection of Geographical Indications, and Contractual Agreements, fashion lawyers ensures that designers’ creations are legally safeguarded and that their rights are upheld within the industry.
4 Susan Scafidi, Duke FSP https://fsp.duke.edu/speakers/susan-scafidi/.
5 Guillermo Jiménez & Barbara Kolsun, Fashion law: A guide for designers, fashion executives, and
attorneys(Bloomsbury) (2016).
The Fashion Law has been developed in many regions but is yet not that prominent in India. However, The Fashion Law is emerging day by day in India. The Fashion Design Council of India (FDCI)6, The Fashion Foundation of India (FFI) and the Apparels Export Promotion Council (APEC) are two emerging organizations that aim to safeguard the fashion industry. The FFI, founded by prominent Indian designers, is dedicated to preventing arbitrary copying, referencing, and inspiration from infringing upon intellectual property rights. The Fashion Design Council of India (FDCI) is a not-for-profit organization that plays a pivotal role in promoting and nurturing the Indian fashion industry. With over 400 members, including fashion and accessory designers, professionals, educational institutions, and corporates, the FDCI ensures sustainable growth in the business of fashion.
It hosts prestigious events like Lakme Fashion Week and India Couture Week, providing a platform for showcasing innovative designs and fostering industry development. 7 Additionally, the Fashion Foundation of India (FFI) and the Apparels Export Promotion Council (APEC) collectively contribute to the legal framework that safeguards creativity and innovation in the industry. 8 Adidas America Inc. v. Skechers USA Inc (2018): Adidas filed a lawsuit against Skechers, alleging that the latter had infringed and diluted Adidas' three-stripe mark and Stan Smith trade dress. The District Court granted a preliminary injunction in favour of Adidas, which was subsequently upheld by the Ninth Circuit for specific Skechers shoe designs.
9 Analysis of Fashion Design in United States, Europe and India: United States The Fashion Design has had a greatest impact on the United States from the very beginning. It had helped U. S. to their economic growth, in 2012 U. S. alone had generated over $330 billion in revenue via the fashion industry. The Fashion Industry in the U. S. has not only changed the economy in the positive way but also had respected the fashion industry as the form of art. Despite of the artistical and economic development the fashion industry has not given any
6 Fashion Design Council of India ( FDCI ), About Us https://www.fdci.org/about-us.html.
7 Ibid.
8 Fashion Design Council of India, Wikipedia (Dec. 17, 2012),
https://en.wikipedia.org/wiki/Fashion_Design_Council_of_India.
9 Adidas America Inc. v. Skechers USA Inc., 890 F.3d 747 (9th Cir. 2019).
protection in U. S. Here the lines or the sketch or the name given to the garment or by any designer of fashion can be copyrighted but not his dress or a garment that he has designed, even for which that designer must have hand-picked the fabric or meticulously selected the colours or patterns, is not awarded with the copyright protection in the United States. However, the United States provides for several other protections under the Intellectual Property for the designers so that they have the benefit and total right on their design. A designer can secure their designs by investing in a unique logo or trade name that the public recognizes as an indicator of the source of the fashion article.
The Trademark Law offers designers another form of protection known as Trade Dress, which encompasses the appearance of a fashionable item, including "the trade dress seeks protection in the overall look and feel of a product or its packaging that denotes the origin of the product to consumers. "10 Under the Intellectual Property a unique and visually appealing design for a product, a design patent can help safeguard it “new, original and ornamental design for an article of manufacture. ”11 This section describes the various types of works that are considered "works of authority" for the purposes of this section, and apparel is not included among these types of works.
These include literary works, musical works with accompanying words, dramatic works with musical words, pantomimes, cinematographic works, pictorial, graphic, and sculptural works, motion pictures and other audiovisual works, sound recordings, and architectural works. After the Trademarks and Patents, U. S. gives Copyright Protection to the designers, U. S. copyright protects “original works of authorship fixed in any tangible medium of expression. 12 Only the original work can be protected and for such to be proved original, it need only be “independently created by the author (as opposed to copied from other works) and possess at least some minimal degree of creativity.
”13 Since the originality requirement for copyright is a lesser hurdle than the “novelty” threshold required for a design patent, copyright appears to be the most practical intellectual property regime to protect fashion designers. However, fashion designs, i. e. , the particular manner a garment is assembled and tailored, are not protectable under current U. S. copyright law. 10 Michelle Mancino Marsh & Natasha Sardesai-Grant, Safe Protection/Safe Inspiration: An Introduction to Intellectual Property Law for Fashion Designs, 2012 Emerging Issues 6821 (Dec. 12, 2012).
11 U.S.C.A. S171 (west).
12 17 U.S.C.A. S102 (west).
13 Feist publications, inc. V. Rural tel. Serv. Co., inc., 499 U.S. 340, 345, (1991).
Professor David Nimmer differentiates between two separate concepts that fall under the term “fashion designs”: (1) “fabric designs” and (2) “dress designs. ” 14 Fabric designs are the patterns used on the article of clothing, such as the floral design repeated on a blouse, and are copyrightable. However, the latter type—dress designs—which “graphically sets forth the shape, style, cut, and dimensions for converting fabric into a finished dress or other clothing garment,” are not protectable by copyright. 15 In an effort to expand copyright protection to entire fashion articles, a recent congressional proposal has been made to amend the Copyright Act’s definition of “useful article” 16 to include apparel. The most recent proposal is the Innovative Design Protection Act of 2012 (the “IDPA”).
The IDPA was reintroduced from its predecessor bill, the Innovative Design Protection and Piracy Prevention Act. The IDPA would grant protection to fashion designs for three years and would prohibit a claim that a fashion design was copied from a protected design if it “(1) is not substantially identical in overall visual appearance to and as to the original elements of a protected design, or (2) is the result of independent creation. ” Europe Intellectual property protection is at the heart of most European fashion business models; the industry is “driven by fast paced innovation embodied in the creation of seasonal collections of new fashion designs” In contrast to the United States copyright system, Europe’s copyright regime protects dress designs. Europe remains the centre of the haute couture, expensive clothes of original design and high quality.
” The safeguarding of fashion design is a fundamental aspect of its cultural identity and legal frameworks. In the European Union (the “EU”), garments, accessories, and footwear, which encompass traditional apparel categories, can be shielded through national and Community design laws and copyright legislation. The European Union has established a unified, EU-wide design rights protection mechanism by implementing the EU Designs Protection Directive (98/71/EC). This directive mandated that all Member States, the individual countries that make up the European Union, provide registration-based protection for “designs,” which was defined
14 Nimmer on Copyright, S2.08 (h).
15 Galiano v. Harrah's Operating Company, Inc., 416 F.3d 411 (2005)
16 See 17 U.S.C. S101.
as “the visual appearance of a product’s entirety or a component thereof, derived from its features, such as lines, contours, colors, form, texture, or ornamentation. ”17 India The Fashion Industry has been and is significantly growing in the Indian Culture since ancient times, having had a tremendous and massive impact on people's lives and personalities in the eyes of themselves and others. In the initial step, the industry designer creates a design or inspiration for what he expects his design to look like, after which the process continues, beginning with sourcing the fabric, mapping and sculpting the designs, and finally bringing it to life. Once the design is created, the designer has the right to protect, sell, enjoy, and reuse his own design. In order to protect, sell, enjoy, and reuse, the designer must protect these designs, which he can seek from the Intellectual Property.
India has prominently protected the Designs, Art, Titles, etc of the owner by the means of Trademark, Copyrights, Patent and Geographical Indications. And in the same manner the designer to protect his designs can seek protection under the Intellectual Property Rights. In common sense, the fashion industry has not only impacted people's lives but has led to protection of designs under the intellectual property rights. For instance, the traditional art of Yeola Paithani, a type of silk saree made in the Yeola town of Maharashtra, is protected under the Geographical Indications (GI) tag, ensuring that only sarees made in Yeola town can be marketed as Yeola Paithani, and safeguarding the distinct identity of the product. This type of protection is crucial in the fashion industry to prevent the unauthorized use of designs and patterns by other companies or individuals.
Other such examples are Darjeeling tea, Kashmir shawls, and blue pottery from Jaipur, each of which represents a unique aspect of India's cultural identity. Similarly, the fashion industry in India also protects various trademarks and copyrights to ensure the authenticity and uniqueness of its products. Fashion products such as Banarasi silk and Kanchipuram sarees, which are traditional Indian clothing items, are also protected under trademark and copyright laws in India. These protections ensure that only authorized producers can use the names and designs associated with these products, preserving their unique cultural heritage and preventing unauthorized imitation.
17 Directive, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A31998L0071.
One other example of trademark and copyright protection in the fashion industry in India is the brand "Banjara" which is protected under the Trademarks Act, 1999. This ensures that only the original brand can produce and sell their clothing items, and it also protects the brand's reputation and identity. Another example is the "Kanjeevaram saree" which is protected under the Copyright Act, 1957. This ensures that only the original design and pattern can be used, and it also helps to maintain the authenticity and cultural significance of the saree. In the case Ritika Private Limited v. BIBA Apparels Private Limited (2016)18, Ritika, owner of the Ritu Kumar brand, sued Biba for copying their designs. The court ruled that Ritika's designs, which had been industrially produced more than 50 times, lost automatic copyright protection under Section 15(2) of the Copyright Act.
To be protected, these designs needed to be registered under the Designs Act. Intellectual Property Rights Intellectual property rights bestow legal protections that enable individuals to exert control over their creative and intellectual outputs. These rights typically endow the creator with a limited, exclusive license to utilize their work for a specific timeframe. Such protections encompass inventions, trademarks, copyrights, and industrial designs. Notably, the Universal Declaration of Human Rights acknowledges intellectual property rights under Article 2719, affirming that everyone has the right to safeguard their moral and material interests derived from any scientific, literary, or artistic creation they produce.
In India, several laws confer legal protection for intellectual property: the Design Act of 200020, the Copyright Act of 195721, and the Geographical Indications of Goods (Registration and Protection) Act of 199922. These statutes span various industries, including garment and design sectors. The Copyright Act of 1957 shields artistic works, inclusive of illustrations, as delineated in Section 2(c), referring to "any other work of artistic craftsmanship. ” Designs, deemed artistic works, fall under this classification. Per Section 13
18 2016 SCC OnLine Del 2030 (Delhi High Court, 23 March 2016).
19 Universal declaration of human rights, United Nations, https://www.un.org/en/about-us/universal-declarationof-human-rights .
20 The Design Act, No. 16 of 2000, India Code (2016).
21 The Copyright Act, No. 14 of 1957, India Code (2023).
22 The Geographical Indications of Goods (Registration and Protection) Act, No. 48 of 1999, India Code (2022).
of the Copyright Act, a design garners protection when conceived purely from imagination, with evident originality. However, the Design Act 2000 specifically safeguards fashion-related designs. Provisions related to copyright in designs that are registered or eligible for registration under the Designs Act of 2000 are encapsulated in section 15 of the Copyright Act. For protection under the Copyright Act, a design must be either registered under the Designs Act or protected as an artistic work, but not both. Should a design protected by the Copyright Act be replicated more than 50 times through an industrial process by the copyright owner or with their consent, copyright protection lapses.
The Design Act, 2000, defines a design in Section 2(d), encompassing features of shape, configuration, pattern, ornament, or composition of lines or colours applied to any article, whether in two or three dimensions, by any industrial process or means. The finished article must appeal to the eye and be judged solely by the eye, subject to certain exceptions. The design right persists for ten years, with an extension of five years possible under specific conditions. The Designs Act allows the registration of any design, irrespective of the material or metal employed, provided construction methods and mechanical devices are not discussed. The third schedule of the Design Rules (2001) lists an extensive array of goods and objects for which the regulator may request an application.
Additionally, the distinctive, red-soled shoes designed by Christian Louboutin are protected by trademark laws, preventing other shoe designers from reproducing the distinctive style. In the fashion industry, copyright protection is also important for protecting original designs, such as the patterns and prints used on clothing and accessories. The fashion industry relies heavily on intellectual property protection to maintain the distinctiveness and authenticity of its products, and to prevent counterfeiting and infringement. Trademarks Trademarks protect the unique name, logo, or other visual elements of a company or product brand, encompassing business names, logos, slogans, sounds, and colours unique to a single brand. However, the Designs Act of 2000 explicitly excludes trademarks from the definition of "design.
" Consequently, a fashion design doubling as a trademark cannot be protected under
the Designs Act of 2000, nor can a fashion design registered under the Designs Act be protected as a trademark. For example, the iconic Chanel No. 5 perfume, created by French fashion house Chanel, is protected under trademark laws, ensuring that only the original product can be marketed and sold under that name. 23 Fashion Law also gives protection to misrepresentation of authenticity of the design owners. 24 Also restricts reproduction of the designs of the designers without their will/consent. 25 adidas vs. ADIDAS: The Delhi High Court resolved a widely publicized legal dispute in favour of adidas in a trademark infringement case. The court acknowledged that "Adidas" is a created term without any inherent linguistic significance, thereby preserving its distinctiveness and granting the brand the right to protect its trademark. The court additionally imposed a fine of Rs 14.
22 lakh on the infringing party, as specified in the judgment. 26 Geographical Indications The recognition of GIs helps in safeguarding the intellectual property rights of the producers and also promotes the traditional arts and crafts of the region, thereby contributing to the preservation rich cultural heritage. Geographical Indication (GI) is an effective tool that supports local weavers, knitters, and designers, highlighting the collective efforts of indigenous workers and the significance of traditional knowledge. Favourable climatic conditions also play a crucial role in the success of these cultural assets. All agricultural, natural, manufactured, handcrafted, and industrial items, including food, are safeguarded as geographical indications under the Geographical Indications of Goods (Registration and Protection) Act, 1999. Section
4 of the act lists the items that can be protected, including apparel and accessories in terms of
the texture and artistic value of the fabric used. This can be seen in the case of Champagne wine, which is recognized as a GI and is highly valued in the global market, generating significant revenue for the Champagne region of
23 History of the Hero: How Chanel No5 revolutionised the fragrance industry, (Feb. 3, 2023),
https://www.harpersbazaar.com/uk/beauty/fragrance/a41776009/chanel-no5/.
24 Chanel, Inc. v. The RealReal, Inc., 449 F. Supp. 3d 422 (S.D.N.Y. 2020).
25 Ritika Private Limited v. BIBA Apparels Private Limited, CS(OS) No. 182/2011, Delhi High Court, decided on March 23, 2016.
26 Adidas AG v. Keshav H Tulsiani, CS(COMM) 582 of 2018, Decided on 19-07-2024.
France. Similarly, the production of Kashmiri handicrafts in India is protected by a GI, which has helped to preserve the traditional techniques and designs that are unique to the region, while the "Pottery of the City of Valencia" in Spain is a GI for ceramic products. 27 Way Forward Fashion law in India currently lacks a centralized legal framework. The development of comprehensive legislation dedicated to fashion law would provide clearer guidelines and protections for designers, brands, and consumers. This could include specific provisions for intellectual property rights, design protection, and anti-counterfeiting measures. Enhancing awareness and understanding of fashion law among designers and industry stakeholders is crucial.
Educational programs and workshops can help fashion professionals navigate legal complexities, ensuring they are well-informed about their rights and obligations. Organizations like the Fashion Design Council of India (FDCI) should advocate for stronger fashion laws and represent the interests of the fashion community in legislative discussions. This would ensure that the voices of designers and industry stakeholders are heard, leading to more effective and relevant legal reforms. By implementing these changes, the future of fashion law in India can create a more robust legal environment that supports creativity, innovation, and ethical practices, ultimately contributing to the growth and global competitiveness of the Indian fashion industry. The role of lawyers and fashion law firms becomes increasingly important in the extension of fashion law.
These legal professionals can work with the government and industry stakeholders to draft and enforce regulations that protect intellectual property, promote sustainable practices, and ensure fair labour standards. By providing legal guidance and support to designers, manufacturers, and retailers, fashion lawyers can help the industry navigate the complex legal landscape and avoid costly mistakes. Additionally, fashion law firms can offer a range of services, including contract drafting and review, dispute resolution, and regulatory compliance, to help the industry thrive in a rapidly changing global market. Ultimately, the extension of fashion law and the involvement of legal professionals can ensure that the Indian fashion industry remains competitive and continues to contribute to the country's economic growth.
27 Protection of geographical indication in the EU, Your Europe https://europa. eu/youreurope/business/runningbusiness/intellectual-property/geographical-indications/index_en. htm.
Fashion law can be extended by ensuring that legal professionals and fashion law firms have a thorough understanding of the industry's unique needs and challenges. Lawyers play a crucial role in providing legal advice and representation to designers, brands, retailers, and other stakeholders in the fashion industry. They can also help in drafting and negotiating contracts, protecting intellectual property rights, and complying with regulatory requirements. By extending the reach of fashion law, lawyers and fashion law firms can help the Indian fashion industry to flourish and compete on a global stage. By implementing these changes, the future of fashion law in India can create a more robust legal environment that supports creativity, innovation, and ethical practices.
Lawyers and fashion law firms play a crucial role in this process, as they can provide expert legal guidance and support to designers, brands, and other stakeholders in the industry. This can include drafting and negotiating contracts, protecting intellectual property rights, navigating regulatory compliance, and addressing disputes through alternative dispute resolution methods. With the right legal support, the Indian fashion industry can continue to thrive and establish itself as a global leader in fashion innovation and sustainability. Conclusion In conclusion, Fashion Law, the intersection of fashion and law, has emerged as a vital field that protects and regulates the dynamic and culturally significant fashion industry. Fashion, as a form of expression deeply embedded in society, has evolved through history, influencing social norms and identities.
Today, Fashion Law plays a critical role in safeguarding the intellectual property rights of designers, ensuring their creative expressions are protected against unauthorized use and infringement. Across regions like the United States, Europe, and India, differing legal frameworks highlight the complexities and challenges within Fashion Law. Trademark protection, copyright laws, and geographical indications are among the legal mechanisms that serve to preserve the authenticity and cultural heritage embedded in fashion products. While the US focuses on trademark and limited copyright protections, Europe offers broader safeguards encompassing dress designs under copyright laws. In India, Fashion Law is evolving, leveraging intellectual property rights to safeguard traditional crafts and contemporary designs alike.
The future of Fashion Law in India holds promise with the potential for a dedicated legal framework. Such legislation would provide clarity and enhanced protection, fostering creativity, innovation, and ethical practices within the industry. Organizations like the Fashion Design Council of India (FDCI) and legal professionals are pivotal in advocating for stronger laws and educating stakeholders about their rights and obligations. In essence, as fashion continues to influence global cultures and economics, Fashion Law stands as a crucial pillar supporting its growth and sustainability. By navigating legal complexities and promoting fair practices, Fashion Law ensures that the industry thrives while respecting the creativity and contributions of designers worldwide.