Member States cannot preclude such registration as a matter of principle. Although the Directive does not seek to achieve full-scale approximation of the laws of the Member States relating to trademarks, the conditions for obtaining and continuing to hold a trademark have to be the same. Second Question: Criteria for Registering Sound Trademarks The second submitted question asked (a) which requirements sound signs have to fulfill to meet the criteria of Article 2 of the Directive, and (b) what kinds of sound sign are capable of being represented graphically within the meaning of Article 2, in particular, whether musical notes, a written description in the form of an onomatopoeia, a written description in some other form, a graphical representation such as a sonogram, a sound recording annexed to the registration form, a digital recording accessible via the internet, a combination of those methods, or any other form meet the requirements of graphical representation. The Court denied a verdict about types of sound signs that weren't decisive for the case at hand, e.g. sonograms and digital recordings, as these were hypothetical problems. The requirements that have to be met by graphical representations were already determined in the verdict Ralf Sieckmann v Deutsches Patent und Markenamt, which concerned olfactory signs. Thus, within the frame of Article 2 of the Directive, a trademark may consist of a sign that is not in itself capable of being perceived visually, provided that it can be represented graphically, particularly by means of images, lines or characters, and that its representation is clear, precise, self-contained, easily accessible, intelligible, durable and objective. Those conditions are also binding for sound signs. Verdict and Consequences As consequence for the Shield Mark case, the Court ruled that a graphical representation in mere text form such as ‘the first nine notes of "Für Elise" or "the crow of a rooster" at the very least lack precision and clarity and therefore cannot constitute a graphical representation of that sign for the purposes of Article 2 of the Directive. The same applies for onomatopoeia, as it is not possible for the competent authorities and the public, in particular traders, to determine whether the protected sign is the onomatopoeia itself, as pronounced, or the actual sound or noise. Musical notes, however, in the form of a stave, fulfill the requirements set by the ECJ's Sieckmann verdict that such representation must be clear, precise, self-contained, easily