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In reaching this conclusion, the Panel noted that the term unjustifiable implies a situation where the use of a trademark is encumbered by special requirements in a manner that lacks a justification or reason that is sufficient to support the resulting encumbrance.[21] The Panel further stated that there may be good reasons that sufficiently support the application of encumbrances on the use of a trademark in a reasonable manner.[22] To determine this, the Panel considered Article 8 of the TRIPS Agreement which according to the Panel, provides guidance for interpreting the term unjustifiably under Article 20

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