Which Countries Should You File IP Protection In?

Mobile app revenue across international markets now accounts for over 70% of total global app store earnings, yet most developers still treat intellectual property protection as an afterthought—usually until its too late. I've watched brilliant app concepts get copied and monetised by competitors in markets where the original creators had no legal recourse. It's honestly one of the most frustrating things to witness as someone who's been in this industry for years.

The thing is, filing for IP protection isn't just about patents anymore (though they're still important). We're talking about trademarks for your app name and logo, design rights for your user interface, and yes—copyright protection for your code. But here's where it gets tricky: intellectual property laws aren't global. What protects you in the UK means absolutely nothing in China or the US unless you file there specifically.

The cost of not protecting your IP internationally is always higher than the cost of filing properly from the start

I've seen too many app developers focus all their energy on building great products while completely ignoring the legal framework that could protect their investment. You might think your app is too small or niche to worry about international IP protection, but that's exactly when you're most vulnerable. The moment your app gains traction in any market, you become a target for copycats—and trust me, they're watching.

This guide will walk you through the practical decisions you need to make about where to file for IP protection. We'll look at the markets that matter most, the costs involved, and how to prioritise your filing strategy based on your app's specific situation and budget.

Understanding IP Basics for Mobile Apps

Right, let's start with the fundamentals—because honestly, most app developers I work with get a bit overwhelmed when IP protection comes up. It's not rocket science, but there are some key bits you need to grasp before deciding where to file.

For mobile apps, you're mainly looking at three types of intellectual property protection. There's copyright (which automatically protects your code and creative assets), trademarks (for your app name, logo, and brand elements), and patents (for unique technical features or methods). The tricky bit? Each country has its own rules and you need to file separately in each territory where you want protection.

What Actually Needs Protection?

Your app's source code is automatically protected by copyright in most countries—that's the easy part. But your app name, distinctive features, and any unique algorithms or processes? Those need active protection. I've seen too many clients launch successfully in one market, only to find copycats operating freely in countries where they didn't bother filing.

Trademarks are usually your first priority. If someone else registers your app name in a major market, you could be locked out entirely or face expensive legal battles later. Patents are trickier and more expensive, but if you've got genuinely novel functionality, they can be worth their weight in gold.

The Filing Reality

Here's what catches most people off guard: IP protection isn't global. That trademark you filed in the UK? It means nothing in the US or China. Each filing costs money, takes time, and requires local expertise. But here's the thing—strategic filing in the right markets can protect the majority of your revenue potential without breaking the bank.

The key markets you choose depend on where your users are, where your competitors operate, and where you plan to expand. Get this decision right, and you've got a solid foundation for global growth.

Choosing Your Core Markets

Right, let's talk about something that keeps many app developers up at night—where exactly should you file for IP protection? I mean, wouldn't it be lovely if we could just tick a box and get worldwide coverage for £50? But that's not how it works, unfortunately. You need to be strategic about this because filing internationally can get expensive quickly.

The first thing I always tell clients is to look at where their users actually are, not where they think they might be someday. If 80% of your revenue comes from English-speaking countries but you're dreaming of cracking the Japanese market "eventually," don't blow your budget on Japan just yet. Start with your bread and butter markets first—the ones that are actually paying your bills.

Your core markets should typically include countries where you have significant user bases, established revenue streams, or clear expansion plans within the next 12-18 months. And here's something people often overlook: you need to consider not just where your customers are, but where your competitors might try to copy you. If there's a country where knockoffs tend to appear frequently in your industry, that might warrant protection even if you're not actively marketing there yet.

Track your app analytics for at least 3-6 months before making IP filing decisions. Real user data beats gut feelings every time when it comes to choosing which territories deserve your protection budget.

I've seen too many startups spread themselves thin by filing in 15+ countries from day one, then running out of money to defend their IP when it actually matters. Better to have strong protection in 3-5 key markets than weak coverage everywhere.

The Big Three: US, EU, and China

Right, let's talk about the big players—the markets that can make or break your app's global success. When I'm advising clients on IP protection, these three regions always come up first, and for good reason.

The US is still the golden goose for most app developers. It's the largest single app market by revenue, and American users are generally willing to pay for premium apps and in-app purchases. Filing for IP protection here is almost non-negotiable if you're serious about monetising your app. The process is relatively straightforward, and the legal framework is well-established. Plus, having US IP protection gives you serious credibility when talking to investors or potential buyers.

Europe: One Filing, Multiple Markets

The EU is brilliant because you can file once and get protection across all member states. That's 27 countries with one application—it's a no-brainer really. The European market is sophisticated, privacy-conscious (thanks to GDPR), and users are willing to spend money on quality apps. I always tell my clients to think of the EU as their second priority after the US, especially if they're building productivity or business apps.

China: The Wild Card

China is tricky. It's massive—over 800 million smartphone users—but it operates differently from Western markets. You can't access Google Play Store there, so you're looking at local app stores like those run by Huawei, Xiaomi, and others. The IP landscape is complex too; you'll need local expertise to navigate it properly. But here's the thing—if your app takes off in China, the revenue potential is enormous. Just be prepared for a completely different approach to marketing, user behaviour, and yes, IP protection.

These three regions represent roughly 70% of global app revenue. Miss any of them, and you're leaving serious money on the table.

Emerging Markets Worth Considering

Right, so you've sorted your big three markets—that's brilliant. But here's where things get interesting. Some of the fastest-growing app markets aren't where you'd expect them to be. I'm talking about countries where mobile-first adoption is absolutely mental, and the competition hasn't caught up yet.

India's probably the most obvious one, isn't it? With over 600 million smartphone users and growing, it's become impossible to ignore. The thing is, their IP laws have been tightening up considerably, which means filing there actually gives you proper protection now. Same goes for Brazil—massive market, increasingly tech-savvy population, and their patent system has been getting more reliable.

Southeast Asia's Hidden Gems

Vietnam and Indonesia are where I'm seeing loads of opportunity lately. Vietnam especially—their middle class is exploding, smartphone penetration is through the roof, and honestly? Most Western app developers are still sleeping on it. Filing IP protection there costs a fraction of what you'd pay in Europe, but the market potential is huge.

The markets that seem risky today often become tomorrow's goldmines, but only if you've protected your IP early enough to capitalise on the growth

Indonesia's trickier because it's so fragmented—loads of islands, different languages, complex regulations. But with 270 million people and rapidly improving internet infrastructure, you can't really ignore it if you're thinking long-term. The key with these emerging markets is timing; file your international IP protection before everyone else wakes up to the opportunity, because once they do, the competition gets fierce and the legal landscape gets more complicated.

Regional Filing Strategies

Right, let's talk about the smart way to approach different regions—because filing everywhere at once is basically financial suicide, and filing nowhere is just asking for trouble. After eight years of helping clients navigate this maze, I've seen too many brilliant apps get knocked off simply because the founders didn't think strategically about their IP protection.

The key thing to remember is that IP protection isn't global—it's a patchwork of individual country systems. So when you're planning your regional strategy, think about it like building defences around your most valuable territories first. Start with where you're making money now, then expand to where you plan to make money next.

Timing Your Regional Rollout

Here's something most people get wrong; they think they need to file everywhere within that 12-month priority period. Actually, you don't. You can stagger your filings based on your business timeline and budget. File in your home market first, then use that priority date to buy yourself time while you figure out which other markets genuinely matter for your app.

I always tell clients to look at their user analytics—where are your downloads coming from? Where are people actually paying for premium features? Those countries should be your priority, not just the obvious big markets everyone talks about.

Regional Considerations

Different regions have different strengths too. Europe's great for design protection, the US is obviously huge for utility patents, and if you're doing anything with fintech or social features, you'll want to consider China early on. But here's the thing—don't just follow what everyone else is doing. Your app's specific features and target market should drive your regional strategy, not generic advice from legal blogs.

When it comes to international IP protection for your app, there's one harsh reality I've learned after years in this business—you can't protect everything everywhere without breaking the bank. It's a balancing act that keeps most app developers up at night, and honestly, there isn't a perfect answer that works for everyone.

The maths are pretty straightforward but painful. Filing a trademark in just ten countries can easily cost £15,000-25,000 when you factor in attorney fees, translation costs, and government filing fees. Add patent protection into the mix? You're looking at six figures without breaking a sweat. And that's before you even consider the ongoing maintenance costs that kick in every few years.

Strategic Budget Allocation

Here's what I tell my clients: start with your revenue reality, not your global dreams. If 80% of your users come from the US and UK, that's where your protection budget should focus first. You can always expand later—but you cant easily recover from spreading yourself too thin initially.

Always reserve at least 30% of your IP budget for unexpected opportunities or defensive actions. The mobile app world moves fast, and having flexibility can make all the difference.

Consider this approach: file in your top three revenue-generating markets first, then evaluate regional options like the Madrid Protocol for trademarks or the Patent Cooperation Treaty for patents. These can give you broader coverage at lower per-country costs, though they come with their own complications.

Remember, perfect protection doesn't exist—but smart, targeted protection absolutely does. Focus on where your business lives today and where it's realistically heading tomorrow.

Timeline and Priority Filing

Right, let's talk timing—because when it comes to IP protection, timing isn't just important, its everything. I've seen brilliant apps lose their competitive edge simply because the developers waited too long to file their applications. The mobile app world moves fast, and your IP protection needs to move faster.

Here's the thing about priority filing: once you file in your first country, you get what's called a priority date. This gives you 12 months for most IP types to file in other countries while keeping that original date. It's like reserving your spot in the queue globally. But—and this is important—you can't just file anywhere and expect the same protection everywhere else.

The 18-Month Reality Check

Most patent applications get published 18 months after filing. That means your competitors will see exactly what you're protecting, so you need to have your key markets locked down before then. I usually tell clients to identify their top three markets within the first six months of their priority filing. Don't leave it until month 11 and then panic about costs.

Staggered Filing Strategy

You don't need to file everywhere at once—that would bankrupt most startups! Start with your home market and your biggest revenue opportunity. Then add markets as your app gains traction and generates income. Many successful apps I've worked on started with just US and EU protection, then expanded to Asia-Pacific markets once they had proven product-market fit.

The key is having a plan from day one. Know which markets you'll file in and when, based on your app's rollout strategy and budget. Because once that 12-month priority window closes, you lose the advantage of your original filing date forever.

Conclusion

Right, we've covered a lot of ground here—from understanding the basics of app IP to navigating the complexities of filing across different territories. But here's the thing: there isn't a one-size-fits-all answer to which countries you should file in. It really comes down to your specific situation, your budget, and where you see your app making the biggest impact.

I've seen too many app developers make the mistake of either going too broad too early (and burning through their budget) or being too conservative and missing out on key markets. The sweet spot? Start with your core markets—the places where you know your app will generate revenue—then expand strategically as your business grows. The US, EU, and China remain the big three for good reason, but don't overlook emerging markets if thats where your users are.

Actually, one of the most important things I've learned over the years is that IP protection isn't just about filing patents and trademarks everywhere. It's about building a strategy that supports your business goals. If you're planning to expand into Southeast Asia in two years, start thinking about those filings now. If you're focused purely on the UK market for the foreseeable future, dont feel pressured to file globally just because everyone else is doing it.

The timeline matters too—use those priority filing periods wisely. And remember, you can always add more territories later as your app proves itself in the market. Sometimes its better to file in three countries properly than in ten countries half-heartedly. Your IP strategy should grow with your business, not constrain it.