Nis 09 2014

Alan Adları İle Coğrafi İşaretler Arasındaki Uyuşmazlıklara UDRP Prensiplerinin Uygulanması

Kısaca açıklamak gerekirse “Alan Adı Sistemi”, okunması ve akılda tutulması kolay olan ve genelde aranan adres sahipleri ile ilişkilendirilebilen simgesel isimlerle yapılan adreslemede, karşılığı olan IP adreslerini bulan ve kullanıcıya veren sistem; alan adı da bu IP adreslerine verilen isimdir.

Alan adı teknik özelliklerle ilgili bir önekten (www gibi), tematik veya coğrafi karakter belirten bir sonekten (.com,.tr gibi) ve basit veya bileşik bir sözcükten oluşan bir kökten oluşur. Kök özel bir isimden, tanınmış bir markadan, coğrafi işaretten vb.den oluşabilir. Kökün seçimi tamamen keyfidir, seçenin iradesine bırakılmıştır.

Alan adlarının tahsisi konusunda geçerli olan “ilk gelen ilk alır” prensibi bunu kötüye kullanmak isteyenlere fırsat tanımıştır. Örneğin ünlü bir markayı, ismi veya coğrafi işareti alan adı olarak tescil ettirenler bunların sahiplerine bu alan adlarını satmışlar veya satmak istemişlerdir.

Bu durumun gittikçe daha ciddi boyutlara gelmesi üzerine uluslararası platformda önlem alınması ihtiyacı kendini hissettirmiştir. Dünya Fikri Mülkiyet Örgütü (WIPO,OMPI) siber-korsanlık olarak adlandırılan bu durumu önlemek için birinci danışma sürecini başlatmıştır.

Bu süreç, 24 Eylül 1999’da Tahsis Edilmiş Ad ve Sayılar İnternet Birliği (ICANN) tarafından “Yeknesak Uyuşmazlık Çözüm Sistemi (UDRP)”nin kabul edilmesiyle sonuçlanmıştır.

Bu sistem, markalarla alan adları arasında ortaya çıkan uyuşmazlıkların hızlı ve ucuz olarak çözümlenmesini amaçlamaktadır. Sistem 1 Aralık 1999’dan beri yürürlüktedir ve bugüne kadar binlerce uyuşmazlığı çözerek başarısını göstermiştir.

UDRP prensiplerinin en büyük eksikliklerinden biri sınırlı bir uygulama alanına sahip olmasıdır. Yani ağırlıklı olarak markalar hukuku bağlamında uygulanmaktadır. Markalar dışındaki durumlarda örneğin bu yazının konusunu oluşturan coğrafi işaretlere ilişkin uyuşmazlıklarda bu prensiplerin uygulanıp uygulanmayacağı çok büyük tartışmalara yol açmaktadır. Dünya Fikri Mülkiyet Teşkilatı’nın 1. danışma sürecinde yapılan uyarılar da bu durumu doğrulamaktadır. Bu uyarılarda özellikle coğrafi işaretler üzerinde durulmuştur. Son yıllarda artan bir biçimde coğrafi işaretlerin kötüye kullanılır biçimde alan adı olarak tahsis edildiği görülmektedir.

Geniş anlamda “coğrafi işaret” terimi coğrafi kaynak (menşe) işaretleri kavramını, dar anlamda coğrafi işaretleri ve coğrafi isimleri kapsar. 1883 tarihli Paris konvansiyonu 1.2 ve 10. maddelerinde “coğrafi kaynak işaretleri” terimini kullanır ancak bir tanım yapmaz. 15 Nisan 1994 tarihli “Fikri Mülkiyet Haklarının Ticaretle İlgili Yönleri Hakkında Anlaşma (TRIPS, ADPIC)” coğrafi işaretleri dar bir manada tanımlamaktadır. Buna göre coğrafi işaretler ürünün kalitesinin, ününün veya diğer bir karakteristiğinin esas olarak o coğrafi kaynağa maledilebileceği durumlarda, toprak parçası kökenli bir ürünü belirtmektedir.

Coğrafi isimler ise yer isimlerini (şehir veya bölge isimleri), jeopolitik terimleri (ülke isimleri) ve jeo-etnik terimleri (halk isimleri) içine almaktadır.

Küresel ve ulusal düzeyde coğrafi işaretler ve menşe işaretleri geleneksel olarak tanınan belirtme sisteminin ve küresel ve ulusal düzenlemelerin içinde yer almaktadır. Bu konuda küresel düzeyde 4 önemli çok taraflı sözleşme bulunmaktadır:

• 1883 Paris Konvansiyonu
• Ürünler hakkında yanlış ya da yanıltıcı menşe işaretlerinin önlenmesiyle ilgili Madrid protokolü.
• Lizbon Protkolü
• Fikri Mülkiyet Haklarının Ticaretle İlgili Yönleri Hakkında Anlaşma (TRIPS, ADPIC)

Bu sözleşmelerin önemli iki yönünü ürünlerin menşei ile ilgili yanlış, kafa karıştırıcı işaretlerin kullanımının yasaklanması ve coğrafi işaretlerin kütüye kullanımının yasaklanması oluşturmaktadır.

Ülkemizde bu husus 555 sayılı “Coğrafi İşaretlerin Korunması Hakkında Kanun Hükmünde Kararname” ile düzenlenmiştir. KHK’nin amacını ve kapsamını açıklayan 1. maddeye göre:

“Bu Kanun Hükmünde Kararname, doğal ürünler, tarım, maden ve el sanatları ürünleri ile sanayi, ürünlerinden bu Kanun Hükmünde Kararnamede yer alan tanımlara ve koşullara uygun her türlü ürünün coğrafı işaretlerle korunmasına ilişkin kuralları ve şartları kapsar”.

KHK’nin tanımlar başlıklı 3. madeesinde ise coğrafi işaretlerin, menşe adı ve mahreç işaretlerinin tanımları yapılmıştır maddeye göre:

Bu Kanun Hükmünde Kararname anlamında coğrafı işaret, belirgin bir niteliği, ünü veya diğer özellikleri itibariyle kökenin bulunduğu bir yöre, alan, bölge veya ülke ile özdeşleşmiş bir ürünü gösteren işaretlerdir.

Bu Kanun Hükmünde Kararname anlamında coğrafi işaretler, menşe adı ve mahreç işareti olarak ikiye ayrılmıştır.

Bir ürünün menşei olan yöre, alan veya bölge adı, aşağıdaki şartların birlikte karşılanması durumunda “menşe adını” belirtir.

a) Coğrafi sınırları belirlenmiş bir yöre, alan, bölge veya çok özel durumlarda ülkeden kaynaklanan bir ürün olması;

b) Tüm veya esas nitelik veya özellikleri bu yöre, alan veya bölgeye özgü doğa ve beşeri unsurlardan kaynaklanan bir ürün olması.

c) Üretimi, işlenmesi ve diğer işlemlerinin tümüyle bu yöre, alan veya bölge sınırları içinde yapılan bir ürün olması.

Üçüncü fıkrada belirtilen koşulları karşılayan ve belirli bir yöre, alan veya bölgeden kaynaklanan bir ürünü belirtmek için geleneksel olarak kullanılan güncel dilde yerleşmiş coğrafi veya coğrafi olmayan adlar da menşe adları olarak kullanılabilir.

Bir ürünün menşei olan yöre, alan veya bölge adı, aşağıdaki şartların karşılanması durumunda “mahreç işareti” göstergesini belirtir.

a) Coğrafi sınırları belirlenmiş bir yöre, alan, veya bölgeden kaynaklanan bir ürün olması;

b) Belirgin bir niteliği, ünü veya diğer özellikleri itibariyle bu yöre, alan veya bölge ile özdeşleşmiş bir ürün olması;

c) Üretimi, işlenmesi ve diğer işlemlerinden en az birinin belirlenmiş yöre, alan veya bölge sınırları içinde yapılan bir ürün olması.
Şunların ise coğrafi işaret olarak tescil edilemeyeceği düzenlenmektedir:

“Aşağıda sayılanlar coğrafi işaret olarak tescil edilmez.

a) 3 üncü maddedeki tanımlara uymayan adlar ve işaretler,

b) Ürünlerin öz adı olmuş adlar ve işaretler,
Bu Kanun Hükmünde Kararname anlamında ürünlerin öz adı, o ürünün ilk üretildiği veya pazarlandığı bölge veya yöre ile ilgili olsa da bir ürünün genel adı haline gelmiş olan adıdır. Ürünün öz adı olup olmadığının tespitinde o adın kaynaklandığı bölge ve tüketim alanlarında halkın bu adı kullanımı göz önüne alınır.

c) Ürünün gerçek kaynağı konusunda halkı yanıltabilecek olan bitki türleri, hayvan soyları veya benzeri adlar,

d) Kamu düzeni ve genel ahlaka aykırı işaretler,

e) 2 nci maddede sayılan ülkelerde korunmayan veya koruması sona ermiş veya kullanılmayan adlar ve işaretler”.

Coğrafi işaretlerin yasal düzenlemelerini küresel ve ulusal ölçekte böylece kısaca gördükten sonar alan adları ile coğrafi işaretler arasında ortaya çıkabilecek uyuşmazlıkları incelemeye başlayabiliriz.

Uluslararası ve ulusal düzeydeki korumaya rağmen bugün birçok coğrafi işaret o yer veya ad ile hiç alakası olmayan üçüncü kişiler tarafından alan adı olarak tescil ettirilmektedir. Bu sebeple coğrafi işaretlerin asıl sahipleri alan adı almak istedikleri zaman kendilerine bazı bileşik veya türetilmiş alan adları seçenek olarak sunulmaktadır. Böylece asıl coğrafi işaret sahipleri bu bileşik veya türetilmiş isimler sebebiyle internet üzerinde yerlerini alamayacak hale gelmektedir. Ayrıca o coğrafi ismin veya işaretin tanınmışlığı zayıflamakta ve halkın kafasında önemli ölçüde karışıklık meydana gelmektedir.

Bu konuda en sık rastlanan durumlardan biri kendi web sitesine insanları çekmek isteyen kişilerin coğrafi ad veya işareti – hiç ilgisi olmamasına rağmen – kullanmalarıdır. Örneğin www.champagne.org alan adının tescilinde bunu görebiliriz. Bazen de coğrafi ad ve işaretler herhangi bir sitede kullanılmaksızın yüksek fiyatlardan satılmak üzere alan adı olarak alınmaktadır.

Ulusal mahkemelerin bu konuda çözüm getirmekte zorlanmaları üzerine WIPO bunlara UDRP prensiplerinin uygulanıp uygulanamayacağını belirlemek için coğrafi işaretler meselesini incelemiştir.

Bununla birlikte 30 Nisan 1999 tarihindeki alan adları hakkındaki WIPO 1.Danışma Süreci’nin nihai raporunda iki sebepten dolayı kötüniyetli tescil kavramının ticaret ve hizmet markalarına tecavüzün dışına genişletilmemesi tavsiye edilmiştir:

1- UDRP prensiplerinin etkinliğinin ispatlanmasını beklemek.

2- Bu prensipleri diğer fikri ve sınai mülkiyet hakları için genişletmeden önce prosedürün uygulanmasında belirli bir deneyim kazanmak.

Böylece UDRP prensiplerinin uygulanmasından bir yıl sonra 28 Haziran 2000’de, WIPO üye devletleri tarafından birinci danışmalar sürecinden sonra askıda bırakılmış olan alan adları sisteminde ortaya çıkan problemler ve özellikle coğrafi işaretlerin kötü niyetli tescili üzerine eğilinmesinin teşvik edilmesi kararlaştırıldı. Bunun sonucunda da 10 Temmuz 2000’de WIPO İnternet alan adları hakkında ikinci danışmalar sürecini başlattı.

UDRP prensiplerinin coğrafi işaretlerle ilgili meselelere uygulanıp uygulanamayacağına bakmadan önce verilmiş bazı kararlara gözatmakta fayda vardır:

WIPO Hakemlik ve Arabuluculuk Merkezi’ne götürülen davaların hepsi yer isimleri ile ilgili olanlardır. Bu davalardan en önemlilerinden biri “barcelona.com” davasıdır.

Bu davada davacı Excelentisimo Ayuntamiento de Barcelona (Barselona Belediye Meclisi) “barcelona” markasını bütün sınıflardan tescil ettirmiş ve “barcelona.com” markasının tescili için de başvuruda bulunmuştur. Fakat 21 Şubat 1996’da new York merkezli barcelona.com şirketi bu alan adını kendi adına tescil ettirmiştir. Bunun üzerine Barselona Belediye Meclisi UDRP kurallarına göre WIPO nezdinde dava açmıştır.

4 Ağustos 2000 tarihli kararı ile WIPO hakemi davalının “barcelona” markası üzerinde hiçbir hakkının bulunmadığına ve dolayısıyla “barcelona.com” alan adını kötüniyetli olarak aldığına karar vermiştir. Bu karar üzerine “barcelona.com alan adı davacıya nakledilmiştir.

Barcelona.com şirketi bu kararı ABD Anayasası’nın bir maddesine dayanarak temyiz etmiştir. Buna göre alan adı UDRP prensiplerine göre geçici olarak askıya alınan veya nakledilen bir alan adı sahibi, bu alan adının tescili ve kullanımının yasadışı olmadığını ortaya koymak için mahkeme önüne bir dava götürebilmektedir.

Bölge Mahkemesi “barcelona.com” alan adının Barcelona.com şirketi tarafından kullanımının yasadışı olduğu gerekçesiyle bu talebi reddetmiştir. Mahkeme bu karara varırken İspanyol markalar hukukunu uygulamış ve İspanyol hukuku’na göre bu kullanımın hukuka aykırı olduğuna karar vermiştir.

Bu kararı inceleyen Amerikan Temyiz Mahkermesi’nin Dördüncü Dairesi 2 Haziran 2003’te Bölge Mahkemesi’nin Amerikan hukuku’nu uygulaması gerekirken İspanyol hukuku’nu uyguladığı gerekçesiyle bu kararı bozmuştur. Barcelona.com şirketinin dayandığı Amerikan Anayasası’nın ilgili maddesi kullanımın yasal olup olmadığının tespiti için Lanham Kanunu’nun yani Amerikan hukuku’nun uygulanması gerektiğini düzenlemektedir.

Amerikan hukuku’nu uygulayarak Dördüncü Daire Barcelona.com şirketinin eyleminin Amerikan markalar hukukuna göre, “hiçkimsenin bir coğrafi yer ile ilgili bir markayı kullanamayacağı ölçüde” yasadışı olmadığını kabul etmiştir. Karara göre “Barcelona” bir marka gibi değil sadece tasvir edici bir terim olarak görülmelidir. Mahkeme bu gerekçeye dayanarak “barcelona.com” alan adının ilk sahibine nakledilmesine karar vermiştir.

WIPO alan adları ve coğrafi işaretlerle ilgili olarak daha birçok karar vermiştir. Bunlara örnek olarak şunlar sayılabilir:

Barcelona.com davasındakinin aksine ihtilaflı alan adlarının davacıya nakledildiği 22 Ocak 2001 tarihli “lapponia.net” ve “lapponia.org” ve 20 Aralık 2000 tarihli “wembleystadiumonline.com” kararlarından sözedilebilir. Bununla birlikte 17 Ağustos 2000 tarihli “smoritz.com” , 14 Mayıs 2001 tarihli “brisbane.com”, 18 Haziran 2001 tarihli “roven.com ve roven.net” kararlarında davalar reddedilmiştir.

Burada dikkat edilmesi gereken husus şudur. Bu davalarda davacılar hep tescilli bir markaya dayanmış ve yer isimlerini içeren alan adlarının kötüye kullanımını ileri sürmüşlerdir. Yani bu kararlarda coğrafi işaretler sadece bir markayla bağlantılı oldukları için ele alınmış ve UDRP prensipleri uygulanmıştır. Yoksa başlı başına coğrafi işaretlere tecavüzden dolayı bir inceleme yapılmamıştır.

Ulusal hukuklarda nasıl bir koruma sağlanmaktadır?

Avrupa mahkemeleri belirli durumlarda şehir ve ülke isimlerinin alan adı olarak tescili ile ilgili uyuşmazlıkları ele almışlardır.

Fransa’daVersay Temyiz Mahkemesi 29 Mart 2000’de “Elancourt” davası olarak bilinen davadaki kararını açıklamıştır. Söz konusu davada Elancourt şehrinin bir sakini “Elancourt, Elancourt’a hoşgeldiniz” isimli özel bir web sitesi açmıştır. Oysa bu şehrin zaten resmi bir web sitesi mevcuttur. Versay temyiz mahkemesi her iki site arasında muhtemel bir karışıklık olmadığına zira dava konusu sitenin sahibinin kendi özel olma niteliğini çok açıkça belirttiğine karar vermiştir.

Almanya’da görülen “heidelberg.de” davasında bir şirket “heidelberg.de” alan adını bölge hakkında bilgiler veren bir siteye yönlendirmek için almıştır. Mahkeme, bu siteyi ziyaret eden internet kullanıcılarının bölge hakkında değil Heidelberg şehri hakkında bilgi edinmeyi umduklarını ve bu sebeple bu alan adı tescilinin Heidelberg şehrinin haklarına tecavüz ettiğini belirterek alan adının şehre transfer edilmesine karar vermiştir. Bu kararın ardından Almanya’da şehir isimleri ile ilgili birçok benzeri karar verilmiştir.

Kaynak adları ile ilgili kararlar ise daha azdır. Örneğin bir Paris mahkemesi “Comite interprofessional du vin de Champagne – Rockynet Com Inc, Saber Enterprises Inc.” Davasında “Champagne” adının korunması yolunda bir hüküm vermiştir.

Bu davada “Saber Enterprises Incorporated” şirketi ABD’de Internic nezdinde “champ-pagne.com” alan adını tescil ettirmiş ve bu siteyi kullanarak “champ-pagne” isimli bir suyu satışa sunmuştur. Bunun üzerine davacı davalının “champagne” adını kendine mal etme ve kaynak adının tanınmışlığını zayıflatmaktan dolayı www.champ-pagne.com alan adının silinmesi için mahkemeye başvurmuştur.
Sonuç olarak bu davada mahkeme davalının “champagne” kaynak adına zarar verdiğine ve onun tanınmışlığını zayıflatıp tüketicilerin kafasında karışıklık yarattığına karar vererek alan adının davalı adına yapılan tescilinin iptali yönünde hüküm kurmuştur.

Yukarıya alınan bu kararlardan da anlaşılacağı üzere UDRP prensipleri yalnızca bir coğrafi ad bir marka tarafından korunduğu zaman uygulama alanı bulabilmekte buna karşın bir marka ile korunmayan coğrafi işaretler ve adlar ulusal hukuka göre korunmaya çalışılmaktadır.

Hukukumuzda durum nedir?

Coğrafi işaretleri düzenleyen 555 sayılı KHK’de sağlanan korumanın kapsamı 15. maddede şöyle belirtilmiştir:

“Coğrafi işaret başvurusu yapma hakkına sahip kişiler ile tescil edilmiş coğrafi işareti kullanım hakkına sahip kişiler, üçüncü kişiler tarafından aşağıda sayılanların yapılmasını önleme hakkına sahiptir.

a) Tescilli adın ününden herhangi bir biçimde yarar sağlayacak kullanımlar veya tescil kapsamındaki ürünleri andıran yada çağrıştırabilen ürünlerle ilgili olarak tescilli adın dolaylı veya dolaysız olarak ticari amaçlı kullanımı,

b) Sözcük olarak gerçek coğrafi yeri ifade etmekle birlikte halkta haksız biçimde ürünün başka yer kaynaklı olduğu izlenimini bırakan kullanımı; veya korunan adın tercümesinin kullanımı; veya ‘stilinde’, ‘tarzında’, tipinde’, ‘türünde’, ‘yöntemiyle’, ‘orada üretildiği biçimde’ veya benzeri diğer açıklama veya terimlerle birlikte kullanımı,

c) Ürünün iç veya dış ambalajında, tanıtım ve reklamında, veya ürünle ilgili herhangi bir yazılı belgede doğal veya esas nitelik ve özellikleri ile menşei konusunda yanlış veya yanıltıcı herhangi bir açıklama veya belirtiye yer verilmesi,

d) Ürünün menşei konusunda halkı yanıltabilecek biçimde ambalajlanması veya yanılgı yaratabilecek diğer herhangi bir biçimde sunulması.”

Coğrafi işaretlere tecavüz niteliğini taşıyan fiiller ise 24 ve 24/A maddelerinde şöyle belirtilmiştir:

“Tescil edilmiş coğrafi işaretler, bunların kullanım hakkına sahip olmayan üçüncü kişiler tarafından aşağıda yazılı biçimde kullanımları coğrafi işaret hakkına tecavüz sayılır:

a) Tescilli adın ününden herhangi bir biçimde yarar sağlayacak kullanımlar veya tescil kapsamındaki ürünleri andıran yada çağrıştırabilen ürünlerle ilgili olarak tescilli adın dolaylı veya dolaysız olarak ticari amaçlı kullanımı,

b) Sözcük olarak gerçek coğrafi yeri ifade etmekle birlikte halkta haksız biçimde ürünün başka yer kaynaklı olduğu izlenimini bırakan kullanımı; veya korunan adın tercümesinin kullanımı; veya ‘stilinde’, ‘tarzında’, tipinde’, ‘türünde’, ‘yöntemiyle’, ‘orada üretildiği biçimde’ veya benzeri diğer açıklama veya terimlerle birlikte kullanımı,

c) Ürünün iç veya dış ambalajında, tanıtım ve reklamında. veya ürünle ilgili herhangi bir yazılı belgede doğal veya esas nitelik ve özellikleri ile menşei konusunda yanlış veya yanıltıcı herhangi bir açıklama veya belirtiye ver verilmesi,

d) Ürünün menşei konusunda halkı yanıltabilecek biçimde ambalajlanması veya yanılgı yaratabilecek diğer herhangi bir biçimde sunulması,

e) Bu maddenin önceki a, b, c ve d bendlerinde yazılı fiillere iştirak veya yardım veya bunları teşvik etmek veya hangi şekil ve şartlarda olursa olsun bu fiillerin yapılmasını kolaylaştırmak,

f) Kendisinde bulunan ve haksız olarak üretilen veya ticaret alanına çıkarılan coğrafi işarete sahip malın nereden alındığını veya nasıl sağlandığını bildirmekten kaçınmak.”

“Madde 24/A

a- Coğrafi işaret hakkı sahibi olarak belirtilmesi gereken kimlik bildirimini gerçeğe aykırı olarak yapanlar, coğrafi işaret koruması olan bir eşya veya ambalajı üzerine konulmuş, coğrafi işaret koruması olduğunu belirten işareti yetkisi olmadan kaldıranlar, kendisini haksız olarak coğrafi işaret başvurusu veya coğrafi işaret*marka hakkı sahibi olarak gösterenler hakkında, bir yıldan iki yıla kadar hapis cezasına ve üçyüz milyon liradan altıyüz milyon liraya kadar para cezasına,

b- Korunan bir coğrafi işaret hakkının sahibi olmadığı, herhanği bir sebeple coğrafi işaret hakkının hükümsüzlüğü veya coğrafi işaret korumasından doğan hakkının sona ermesi durumlarında; kendisinin veya başkasının imal ettiği veya satışa çıkardığı eşyaya veya ambalajlarına veya ticari evrakına veya ilanlarına, hukuken korunan bir coğrafi işaret hakkı ile ilgili olduğu kanısını uyandıracak şekilde, işaretler koyan veya bu amaçla yazılı ve görsel basındaki ilan ve reklamlarda bu tarzda yazı, işaret veya ifadeleri kullananlar hakkında, iki yıldan dört yıla kadar hapis cezasına ve altıyüz milyon liradan bir milyar liraya kadar para cezasına,

c- 24 üncü maddede yazılı fiilerden birini işleyenler hakkında, iki yıldan dört yıla kadar hapis cezasına ve altıyüz milyon liradan bir milyar liraya kadar para cezasına, ayrıca işyerlerinin bir yıldan az olmamak üzere kapatılmasına ve aynı süre ticaretten men edilmelerine hükmolunur.

Yukarıda yazılı suçlar hizmetlerini yaptıkları sırada bir işletmenin çalışanları tarafından doğrudan doğruya veya emir üzerine işlenmişse çalışanlar ve suçun işlenmesine mani olmayan işletme sahibi, müdür veya temsilcisi ve hangi unvan ve sıfatla olursa olsun işletmeyi fiilen yöneten kişi de cezalandırılır. Bir tüzelkişinin işleri yürütülürken 24 üncü maddede sayılan suçlardan biri işlenirse, tüzelkişi, masraflar ve para cezasından müteselsilen sorumlu olur. Fiile iştirak edenler hakkında olayın mahiyetine göre Türk Ceza Kanunu’nun 64, 65, 66 ve 67 nci maddeleri hükümleri uygulanır. Yukarıda sayılan suçlardan dolayı kovuşturma şikayete bağlıdır.

Bu madde hükümlerinin uygulanmasında 1412 sayılı Ceza Mahkemeleri Usulü Kanunu’nun 344 üncü maddesinin birinci fıkrasının 8 numaralı bendi uygulanmaz. coğrafi işaret korumasından doğan hakları tecavüze uğrayandan başka, 24 üncü maddede sayılanlar dışında kalan suçlarda Enstitü; coğrafi işaret hakkı sahibi olarak belirtilmesi gereken kimlik bildiriminin gerçeğe aykırı olarak yapılması ile korunan bir coğrafi işaret hakkının sahibi olmadığı veya herhangi bir sebeple coğrafi işaret hakkının hükümsüzlüğü veya coğrafi işaret korumasından doğan hakkının sona ermesi durumlarında; kendisinin veya başkasının imal ettiği veya satışa çıkardığı eşyaya veya ambalajlarına veya ticari evrakına veya ilanlarına , hukuken korunan bir coğrafi işaret hakkı ile ilgili olduğu kanısını uyandıracak şekilde, işaretler koyma veya bu amaçla yazılı ve görsel basındaki ilan ve reklamlarda bu tarzda yazı, işaret veya ifadelerin kullanılması durumlarında 5590 veya 507 sayılı Kanunlara tabi kuruluşlar ve Tüketici Dernekleri de şikayet hakkına sahiptir. Şikayetin fiil ve failden haberder olma tarihinden itibaren iki yıl içinde yapılması gerekir.”

Ülkemizde bir coğrafi ad veya işaret alan adı olarak alındığı takdirde –ODTÜ tarafından verilen .tr uzantılı alan adları- ilgililerin bu alan adı tescilinin iptali için başvurmalarına hukuki bir engel olmamak gerekir. Zira KHK’nin metni bu talepleri ileri sürmeye elverişlidir. Kapsamı açıklayan 15. maddenin “a” bendindeki “Tescilli adın ününden herhangi bir biçimde yarar sağlayacak kullanımlar” ifadesi kanımca alan adlarını da kapsayacak biçimde yorumlanmalıdır. Aynı ifade coğrafi işaretlere tecavüz niteliğindeki fiilleri düzenleyen 24. maddede de tekrarlanmaktadır.

KHK tecavüzlere karşı bazı önlemler de öngörmüştür. Suç teşkil eden eylemler için belirli cezalar öngörülmüşken hukuki tecavüzler için de hak sahibinin belirli taleplerde bulunabilmesine imkan tanımıştır. Bunlar:

“a) Fiilin tecavüz olup olmadığının tesbiti,

b) Coğrafi işaretten doğan haklara tecavüz fiillerinin durdurulması ve önlenmesi

c) Tecavüzün giderilmesi ve maddi zararın tazmini

d) Coğrafi işaretten doğan haklara tecavüz suretiyle üretilen veya pazarlanan ürünlere, bunların üretiminde doğrudan doğruya kullanılan araçlara el konulması;

e) Coğrafi işaretten doğan haklara tecavüzün devamını önlemek üzere tedbirlerin alınması, özellikle bu maddenin c bendine göre el konulan ürünlerin ve araçların şekillerinin değiştirilmesi veya coğrafi işaretten doğan haklara tecavüzün önlenmesi için, kaçınılmaz ise, imhası;

f) Coğrafi işaretten doğan haklara tecavüz eden kişi aleyhine verilen mahkeme kararının, masrafları tecavüz eden tarafından karşılanarak, ilgililere tebliğ edilmesi ve kamuya ilan yoluyla duyurulması”

Bu taleplerin tamamının alan adlarıyla ilişkili bir davada istenmesi mümkün görünmektedir. Ülkemizde ODTÜ’nün uyguladığı sistem sebebiyle bu tür uyuşmazlıklarla pek karşılaşılmasa bile .tr uzantılı alan adları için bu kararların verilmesi ve bunların uygulanabilmesi mümkün olacaktır.

KHK’nin buraya alamadığımız daha birçok maddesi bu tür uyuşmazlıklarda uygulanabilir niteliktedir. Fakat bu yazının hacmi ile sınırlı olarak hem yukarıya alınan bazı maddelerin hem de alınmayan ilgili maddelerin analizine girilmeyecektir.

UDRP prensiplerinin coğrafi işaretlere uygulanıp uygulanamayacağı probleminde karşılıklı olarak çeşitli görüşler öne sürülmüştür.

Bir fransız organizasyonu olan Kaynak Adları Ulusal Enstitüsü “Institut National des appellations d’origines”, Üzüm Bağı ve Şarap Uluslararası Bürosu “Office International de la Vigne et du Vin” gibi kuruluşlar WIPO’ya ilettikleri görüşlerde, markalara uygulanan kötüye kullanıma ilişkin prensiplerin aslında coğrafi işaretleri içeren alan adlarında da uygulanabileceğini belirtmişler ve coğrafi işaretlere markalarla eş düzeyde bir koruma getirilmesini talep etmişlerdir.

UDRP prensiplerinin coğrafi adlara uygulanmak üzere genişletilmesine karşı çıkan gruplar da kendi argümanlarını ileri sürmüşlerdir. Örneğin ABD Patent ve Marka Ofisi “United States Patent and Trademark Office” ve Uluslararası Markalar Birliği “Association Internationale pour les Marques” gibi kuruluşlar coğrafi işaretlerin yasal koruma mekanizmalarının bir ülkeden diğerine çok değiştiğini, dolayısıyla UDRP prensiplerinin ortaya konulmasından önce markalar için yakalanmış olan uyum sürecinden coğrafi işaretler bakımından çok uzak olunduğunu bu sebeple de coğrafi işaretlere UDRP prensiplerinin uygulanmasının başarısızlığa mahkum olduğunu ileri sürmüşlerdir. ,

Danışma süreçleri sonunda yayınlanan nihai raporda coğrafi işaretlerin alan adları sisteminde korunması ile ilgili tavsiyelere yer verildiğini belirtmiştik. Bu rapor Markalar Hukuku Daimi Komitesi tarafından da değerlendirmeye tabi tutulmuştur. Burada ortaya çıkan sonuçlar şunlardır:

İlk olarak, bir coğrafi işaretin söz konusu yer ile hiçbir ilgisi bulunmayan bir kişi tarafından alan adı olarak tescili kendiliğinden bir problem oluşturmamaktadır. Alan adıyla ürünler arasında bir bağ olmadığı zaman başlı başına alan adının tescili uluslararası düzenlemeleri ihlal etmez.

İkinci olarak, farklı milli hukukların uyumlaştırılması problemi vardır. Coğrafi işaretlere ilişkin koruma sistemleri ülkeden ülkeye değişiklik göstermektedir. Bundan dolayı bir alan adının tescilinin ve kullanımının coğrafi işaretlere ve coğrafi adlara zarar verip vermediğini belirlemek için ne gibi hükümlerin uygulanacağı konusunda bir yekenesaklık yoktur. Bu sebeple mevcut UDRP prensiplerinde herhangi bir değişikliğe gidilmemelidir.

WIPO’nun 24 Eylül – 3 Ekim 2001 arasında yapılan genel kurul toplantılarında üye devletler sorunun Coğrafi İşaretler, Endüstriyel Modeller ve Dizaynlar ve Markalar Hukuku Daimi Komitesi ( Comite Permanent du droit des marques, des dessins et modeles industriels et des indications geographiques) tarafından ele alınması kararına vardılar. 24 Mayıs 2002’de yapılan özel toplantıya 76 devlet katıldı.

Burada Fransa’nın başını çektiği Avrupa Birliği delegasyonu UDRP prensiplerinin coğrafi işaretlere uygulanmasını savunmuşlardır.

Buna karşılık diğer devletler ulusal mevzuatlar arasındaki farklar ve coğrafi işaretlerin alan adı sisteminde korunmasıyla ilgili kesin kararlar almanın uygun olmayacağını dikkate alarak coğrafi işaretlerin UDRP prensiplerine dahil edilmesinin erken olduğunu savunmuşlardır. Onlara gore coğrafi işaretlerin alan adı sisteminde korunması probleminden önce coğrafi işaretlerin korunmasıyla ilgili temel sorunlara çözüm bulunmalıydı.

Şu an itibariyle alan adı sisteminde coğrafi işaretlerin korunması meselesi halen çözümlenememiştir. Tartışmalar ve çözümler geleceğe bırakılmıştır. Şimdilik sınırlı çözüm coğrafi işaretleri markalar ile ilişkilendirip UDRP prensiplerinin uygulanmasını sağlamaktır. Ama konu hassas bir konudur ve coğrafi işaretlerin UDRP prensiplerine dahil edilmemesini savunanların argümanların gerçekten de bugün itibariyle aksinin ispatlanması zor görünmektedir.

Makale Yazarı

Av. Ali Osman Özdilek, Mart 2004

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