The question of whether an advertisement or offer for sale “targets” consumers in a particular jurisdiction is critical in trade mark infringement cases involving foreign traders selling online. The Court of Appeal recently clarified the term, overturning a decision in a dispute over the sale of goods bearing the BEVERLY HILLS POLO CLUB mark (Lifestyle Equities CV & Anor v Amazon UK Services Ltd & Ors). As we reported on this blog in 2021, Lifestyle, the owner of the relevant