tribe member, little could be done when designs, symbols, or names were usurped. The law, written to protect the tribes and their cultures as a whole, does not cover individuals, with the result that there is no protection for the works of fashion designers. As part of their tribal tradition, symbols of various tribes are not typically trademarked, but one exception is the name "Navajo", which was legally trademarked in 1943. Soon after the change to US law, public debate in Canada over protection of intellectual property rights became a media topic. There are no Canadian laws which specifically protect against cultural appropriation. The government utilizes international agreements to uphold their fiduciary responsibility to First Nations. As in the US, laws cover communities as a whole and not individual copyright and it is difficult for indigenous peoples to prevent misappropriation of their names and symbols. Most protections that exist are to protect economic rather than heritage rights. In two cases, trademarks have been obtained to protect Native artists. Since 1959, the "igloo tag" may be used only by Inuit to protect their works. The Cowichan Band Council has registered "Genuine Cowichan Approved" as a mark specifically for clothing designs. 1991–2010 The 1990s saw a split in the Native American fashion design styles, with one group pursuing simple silhouettes with defined, smooth transitions between fabric lines, while the other group focused on avant-garde indigenous couture. Among those who favored classic, clean-lines were Betty David (Spokane), known for her shearling coats; Dorothy Grant (Haida), who trained at Vancouver's Helen Lefeaux School of Fashion Design and whose work includes images of flora and fauna of the Pacific Northwest, formline art and basketry designs; and Penny Singer (Navajo), who added photographic images on fabric to her traditional men's and women's shirts and accessories decorated with beads and ribbon work. Virgil Ortiz (Cochiti Pueblo) and Grant were the first Native American fashion designers to exhibit at an event in Manhattan. They held a show together at the Mercedes-Benz New York Fashion Week in 2009, though Ortiz's work generally is known as more cutting-edge and noted for incorporating colors, shapes, and symbols from pottery in his fashion design. Angela DeMontigny (Chippewa-Cree-Métis) of southwestern Ontario, a Canadian First Nation designer, also followed the classic traditional lines, with edgy elements based initially on leather and suede garments before branching into jewelry and accessories. In 1991, D’Arcy J. Moses