In trademark law, Sieckmann v German Patent and Trademark Office (case C-273/00) issued on December 12, 2002, is widely recognised as a landmark decision of the European Court of Justice on the graphical representation of non-conventional trademarks under the European Trade Marks Directive. The case illustrates difficulties with the graphical representation of scent marks, as the ECJ held that these representations, whether individually or collectively, could not satisfy this requirement.