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ARTICLE · 28 OCTOBER 2026

How Apple Registered The “iPhone Duo” Trademark Without Disclosing It

Major corporations like Apple strategically file trade mark applications in jurisdictions with limited public disclosure to maintain secrecy about upcoming products. This practice, known as submarine filing, exploits international priority rights under the Paris Convention while creating uncertainty for other businesses conducting clearance searches.

LiechtensteinIntellectual Property

On 9 September 2026, Apple unveiled the new iPhone Duo—and that is probably already well known. What is less widely known, however, is that it had filed an application for the trade mark in Liechtenstein six months earlier. Apple had adopted a similar approach in 2014 in relation to the first Apple Watch, by filing an application in Trinidad and Tobago. This practice is known as “submarine filing” or the use of “submarine trade marks”.

Why Did Apple Choose Liechtenstein? The Submarine Trade Mark Strategy

The choice of jurisdiction was not accidental. Liechtenstein’s trade mark office expressly states that its online register displays “only trade marks and designs that have actually been registered and published”. In other words, a pending trade mark application does not appear in the register before it has been examined and published.

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