accepted", because, inter alia, they have not been developed (GC, judgment of 13 February 2007 in Case T-256/04 [RESPICORT/RESPICUR], para. 72). However, there are good reasons not to generalize this passage from a single judgment. In fact, OHIM’s practice takes into account that allusive signs are very common in the pharmaceutical sector and, more importantly, that the consumer is used to this practice (see e.g. Board of Appeal, decision of 18 July 2013 in Case R 699/2012-1 [ANGINSAN/JUNIOR-ANGIN], para. 23). What does the consumer understand? direction. By way of example, the GC held that the consumer will not understand CORT as a reference to corticoids (GC, judgment of 13 February 2007 in Case T-256/04 [RESPIRORT/RESPICUR], para. 71); VIR as a reference to antiviral (GC, judgment of 13 September 2010 in Case T-149/08 [NORVIR/SORVIR], para. 39) or Latin or Greek terms such as MENO or CHRON (GC, judgment of 28 April 2014 in Case T-473/11 [MENODORON/MENOCHRON], para. 39). In some cases, the GC also put emphasis on the rule that the consumer generally perceives the mark as a whole, so that it is harder for the end-user to grasp any descriptive meaning of an element, if it is part of a single word (see to this effect GC, judgment of 9 April 2014 in Case T501/12 [PENTASA/OCTASA], para. 50; the GC adopted a similar reasoning in its judgment of 13 September 2010 in Case T-149/08 [NORVIR/SORVIR], para. 39). International Update Hungary PETOSEVIC The Budapest police authorities have recently discovered and seized almost 170,000 pieces of counterfeit medicines in the basement of a building in Budapest. The police arrested a 45-year-old man on suspicion of counterfeiting pharmaceutical products. In any case, the decisive question is not whether the consumer is generally aware of the widespread existence of allusive signs in the pharmaceutical sector, but rather if the consumer is able to understand the descriptive or allusive meaning of a specific sign. The answer to this question depends on the circumstances of the specific case. Consequently, it does not come as a surprise that the relevant case-law does not rely on general guidelines, but appears rather casuistic. With that being said, the following decisions are supposed to give some hints as to the GC’s approach to assess the end consumer’s understanding of suggestive signs. Summary The GC has taken the view that the end consumer is capable of understanding RESPI as a reference to respiratory (GC, judgment of 13 February 2007 in Case T256/04 [RESPIRORT/RESPICUR], para. 71 et seq.); VISC as a reference to viscosity (GC, judgment of 10 September 2008 in Case T-106/07 [PROVISC, DUOVISC/BIOVISC], para. 40]); NICO as a reference to nicotine (GC, judgment of 6 June 2013 in Case T580/11 [NICORETTE/NICORONO], para. 30); CHOL as a reference to cholesterine (GC, judgment of 12 July 2012 in Case T517/10 [HITRECHOL/HYPOCHOL], para. 27) and ECHIN(A) as a reference to the Latin name of the plant Echinacea (Court of First Instance, judgment of 5 April 2006 in Case T-202/04 [ECHINACIN/ECHINAID], para. 44). Whilst the above-mentioned examples could indicate that the consumer has a (partly surprisingly) good understanding of suggestive terms, there is also case-law pointing in the opposite Case-law establishes that the likelihood of confusion between two conflicting trade marks has to be assessed from the perspective of the relevant public. In the case of pharmaceutical trade marks, the relevant public comprises both health professionals and end consumers. With respect to end consumers, the decisive question is if they understand the descriptive meaning of certain elements within suggestive marks. If so, there is room to argue that the element is weak and that the mere coincidence in such elements is not sufficient to cause a likelihood of confusion. There is extensive case-law on the whether and, as the case may be, to what extent consumers understand the descriptive or allusive meaning of suggestive marks. Whilst it can be difficult to predict whether the GC will regard an element as descriptive or not, precise knowledge of the relevant case-law and OHIM’s practice is not only very helpful, but can actually make the difference between winning or losing a case. On 21 October, 2014, the Budapest police received a tip that a man will probably buy narcotics at a certain address in the 3rd district of Budapest. The police went to the site where they checked the identity of two men found standing next to a car. The owner of the car was the 45-year-old man. The police searched the car and discovered several hundred bottles labelled Rivotril, filled with counterfeit pills, as well as pills in unmarked bags, several hundred unmarked bottles, and a bag with white powder of unknown composition. The police discovered that the suspect owns keys to certain premises in the 22nd district of Budapest. After searching the premises, the police discovered large quantities of Rivotril 2mg labels, empty bottles, bottle caps, cotton balls, digital scales, label applicators and other equipment used for making counterfeit drugs. The criminal procedure is underway. Hungary PETOSEVIC The Hungarian National Board Against Counterfeiting announced on its website that in the next few years, European Union member states are expected to implement a stricter prescription drug monitoring system, aimed at preventing counterfeit medicines from entering the supply chain, based on the Falsified Medicines Directive, which will enter into force in 2018 in the EU. According to the Directive, each drug package will need to be tamper-resistant and coated with a unique two-dimensional barcode, containing manufacturer’s code, serial number, national healthcare reimbursement number, batch number and expiration date. These measures will make 3