Passing off – Trade name. The appeal of the claimant National Guild of Removers and Storers (NGRS) was dismissed, and the cross-appeal of the defendants was allowed in part, in a dispute concerning a claim on two websites that the third defendant company was a member of NGRS. The Chancery Division held that, among other things, the first and second defendants were not jointly liable with the third defendant in relation to passing off stemming from the misrepresentation on the third defendant's website.