16.2 Counter-statement for declaration of invalidity (Regulation 109)

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A counter-statement to an application to the Commissioner for a declaration of invalidity must contain the following information:

The name and address for service of the owner of the trade mark;
If the owner opposing has an agent, the agent’s name;
A response to the applicant’s grounds for a declaration of invalidity, by admitting, denying, or claiming lack of knowledge of, each assertion made in the grounds for a declaration of invalidity;
A brief statement of the facts on which the owner relies in support of continued registration.