A. SOUND MARKS When India granted registration for sound trademarks, India simply borrowed the Shield Mark doctrine which was given in the case of Shield Mark BV v Joost Kist, by the ECJ. The ECJ regarded the description of sound by its written description and held that since the written description of a sound lacked clarity and precision, it cannot be considered a graphical representation. But the Court also opined that if the sound was distinctive and people were able to recognize it,