Chotiwala Food And Hotels Pvt.Ltd. Vs. Nitin Jain

Delhi High Court Grants Ex Parte Interim Injunction to Chotiwala Restaurant Against Trademark Infringement

The Delhi High Court has issued an ex parte interim injunction in favor of Chotiwala Food And Hotels Pvt. Ltd., a renowned restaurant operating in Rishikesh since 1958, in its legal battle against Nitin Jain for unauthorized use of the trademark "CHOTIWALA."

Background:

Chotiwala restaurant, established in 1958, is famous for its vegetarian cuisine and distinctive logo depicting a Brahmin with a Bodhi/Choti holding a ‘thali’ in a gesture of serving satvik/shakahari (vegetarian) food. This logo, along with the name "CHOTIWALA," is registered under the Trademark and Copyright Act. Over the past 65 years, the brand has acquired secondary meaning, becoming synonymous with high-quality vegetarian food in Rishikesh.

The plaintiffs have actively protected their trademark, successfully enforcing their rights in previous cases, including CS(OS) 2456/2011 and CS(COMM) 33/2023, both heard before the Delhi High Court.

Plaintiff's Grievance:

The current grievance of the plaintiffs is directed at defendant Nitin Jain, who allegedly adopted the plaintiffs’ marks for his restaurants under the name "MASHOOR CHOTIWALA RESTAURANT." This usage, according to the plaintiffs, infringes upon their registered trademarks and misleads consumers.

Court’s Observations:

Hon’ble Judge Anish Dayal noted that the plaintiffs have made a prima facie case for the grant of an ex parte ad interim injunction. The court recognized the long-standing use and reputation of the "CHOTIWALA" trademark and acknowledged the potential for consumer confusion due to the defendant’s use of a deceptively similar mark.

Judgment:

The court held that the balance of convenience lies in favor of the plaintiffs, who are likely to suffer irreparable harm if the injunction is not granted. Consequently, the court issued an ex parte interim injunction, restraining the defendant from using the word "CHOTIWALA" as part of their trademark or tradename, or any other mark that is identical or deceptively similar to the plaintiffs’ registered "CHOTIWALA" trademark, until the next date of hearing.

Implications:

The Delhi High Court’s decision in Chotiwala Food And Hotels Pvt. Ltd. Vs. Nitin Jain reinforces the principle that longstanding and well-recognized trademarks deserve robust protection against infringement. The ruling ensures that consumers are not misled by deceptive similarities and upholds the integrity of reputable brands.

Case Title: Chotiwala Food And Hotels Pvt.Ltd. Vs. Nitin Jain

Judgment/Order Date: 28.05.2024

Case No. CS(COMM) 469/2024

Neutral Citation: NA

Name of Court: High Court of Delhi

Name of Hon'ble Judge: Anish Dayal, H.J.

Disclaimer:

Ideas, thoughts, views, information, discussions and interpretation expressed herein are being shared in the public Interest. Readers' discretion is advised as these are subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Written by:Advocate Ajay Amitabh Suman

IP Adjutor [Patent and Trademark Attorney]

United & United

Email: amitabh@unitedandunited.com

Ph No: 9990389539

Ambuja Cements Limited Vs Sudheer Sharma

High Court Grants Ex Parte Interim Injunction in Favor of Ambuja Cements Limited Against Fraudulent Use of Trademark

Delhi High Court has granted an ex parte interim injunction in favor of Ambuja Cements Limited, one of India’s leading manufacturers of cement and construction materials, against unauthorized use of its trademark by Defendants No. 1 to 12, who allegedly created fake websites to engage in phishing activities.

Background:

Ambuja Cements Limited, a prominent player in the cement industry, has been using the trademark “AMBUJA CEMENTS” since 1984. This mark is not only central to the company’s branding but also forms an integral part of its corporate identity.

The plaintiff filed a suit alleging that Defendants No. 1 to 12 had created fraudulent websites using the “AMBUJA CEMENT” trademark. These websites purportedly offered the plaintiff’s products to the public across India, despite the fact that Ambuja Cements Limited exclusively distributes its products through authorized dealers and does not sell online. This deceptive practice was intended to mislead consumers into believing they were purchasing authentic products directly from the plaintiff.

Court’s Observations:

The court examined the evidence, including screenshots and consumer accounts, which indicated that Defendants No. 1 to 12 were unlawfully using the “AMBUJA CEMENT” trademark. These defendants misrepresented themselves as officials or employees of Ambuja Cements Limited, luring unsuspecting consumers into paying significant amounts of money under the false pretense of placing orders for genuine Ambuja Cements products.

Judgment:

Hon’ble Judge Sanjeev Narula, upon considering the submissions and evidence presented, found that there was a prima facie case of trademark infringement and misrepresentation. The court noted that the defendants' actions were aimed at deceiving consumers and tarnishing the plaintiff's reputation.

Accordingly, the court granted an ex parte interim injunction, restraining Defendants No. 1 to 12 from using the “AMBUJA CEMENT” trademark or any deceptive variation thereof. This injunction aims to protect consumers from further harm and preserve the integrity of Ambuja Cements Limited’s brand.

Conclusion:

The High Court’s decision in Ambuja Cements Limited Vs Sudheer Sharma sets a critical precedent in trademark law enforcement, particularly in the digital age where fraudulent online activities are increasingly common.

Case Title: Ambuja Cements Limited Vs Sudheer Sharma

Judgment/Order Date: 29.05.2024

Case No. CS(COMM) 469/2024

Neutral Citation: NA

Name of Court: High Court of Delhi

Name of Hon'ble Judge: Sanjeev Narula, H.J.

Disclaimer:

Ideas, thoughts, views, information, discussions and interpretation expressed herein are being shared in the public Interest. Readers' discretion is advised as these are subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Written by:Advocate Ajay Amitabh Suman

IP Adjutor [Patent and Trademark Attorney]

United & United

Email: amitabh@unitedandunited.com

Ph No: 9990389539

Citizen Watch Company Limited Vs Dineshkumar Laxmanbhai Virda

Similarity of Goods is Not a Sine Qua Non in an Action of Passing Off

Introduction:

The doctrine of passing off is a fundamental aspect of intellectual property law, primarily concerned with protecting the goodwill and reputation of a trademark from misrepresentation. A pivotal issue in passing off cases is whether the goods or services involved must be similar for a claim to be successful. This article examines a recent legal case that underscores the principle that similarity of goods is not a sine qua non (an essential condition) in an action of passing off.

Case Background:

The plaintiff in this case is an internationally reputed company organized under the laws of Japan, known for its CITIZEN brand. The CITIZEN Group has been engaged in watchmaking since 1918 and expanded into the industrial precision machine tools market by 1936. The plaintiff commenced operations in India in 1960 through a collaboration with the Indian Government, managed by HMT.

The defendant, aware of the plaintiff's goodwill and reputation, dishonestly applied for the registration of the trademark "CITIZEN" in Class 07 (related to lathe machines) in 1994 and again in 2010 for the mark "C-TIZEN." The defendant argued that since the plaintiff was known primarily for watches, there could be no confusion or deception regarding lathe machines. The defendant also contended that the term "CITIZEN" is a common, laudatory word, not an invented or coined term, and hence not distinctive enough for exclusive trademark rights.

Legal Issues:

The primary legal issues revolved around:

Whether the similarity of goods is necessary for a passing off action.
Whether the term "CITIZEN" can be protected as a trademark given its common use and dictionary meaning.

Court’s Analysis and Findings:

Trademark Registration Validity:

The court first addressed the validity of the plaintiff's trademark registration. The plaintiff substantiated its claim by providing a Legal Proceeding Certificate (LPC), confirming its registration. This evidence was crucial in establishing the plaintiff's proprietary rights over the "CITIZEN" trademark.

Common Field of Activity Not Necessary:

The court firmly rejected the defendant's argument that the similarity of goods is essential for passing off. The court clarified that the fundamental issue is whether the defendant's use of the mark in relation to lathe Machine results in a likelihood of confusion or deception, causing damage to the plaintiff's goodwill and reputation. In this case, the plaintiff's trademark "CITIZEN" was found to have substantial goodwill and reputation, not just in watches but broadly due to its extensive market presence and brand recognition. This is the reason why the Court rejected this argument of the defendant that Plaintiff's activities is in relation to watches, while activities of defendant is lathe machine, which plaintiff never manufactured.

Misrepresentation and Likelihood of Confusion:

The court observed that the defendant’s marks "CITIZEN" and "C-TIZEN" were deceptively similar to the plaintiff’s mark, both visually and phonetically. This similarity was likely to cause confusion among consumers, leading them to associate the defendant's lathe machines with the plaintiff’s reputable brand. The court emphasized that the essence of passing off lies in the misrepresentation that leads to public confusion and consequent damage to the plaintiff’s goodwill, irrespective of the nature of the goods.

Plaintiff’s Goodwill and Defendant’s Intent:

The court also noted that the defendant had failed to provide any plausible reason for adopting the "CITIZEN" mark for lathe machines. Given the plaintiff's longstanding and widespread use of the trademark, the court inferred that the defendant's adoption of the mark was dishonest, aimed at capitalizing on the plaintiff’s established reputation.

Delay and Laches:

Addressing the defendant's argument regarding delay and laches, the court found that the plaintiff's delay in initiating legal action did not bar the suit. The delay did not diminish the plaintiff's rights or the potential for public confusion and deception caused by the defendant’s use of the mark.

Conclusion:

This case reaffirms that the similarity of goods is not a prerequisite for a passing off action. The primary consideration is the likelihood of confusion and misrepresentation that damages the plaintiff's goodwill. The court’s decision underscores the importance of protecting well-established trademarks from dishonest adoption, regardless of the specific goods or services involved.

Case Title: Citizen Watch Company Limited Vs Dineshkumar Laxmanbhai Virda
Judgment/Order Date: 16.05.2024
Case No. CS(COMM) 56/2015
Neutral Citation: 2024:DHC:3974
Name of Court: High Court of Delhi
Name of Hon'ble Judge: Jyoti Singh, H.J.

Disclaimer:

Ideas, thoughts, views, information, discussions and interpretation expressed herein are being shared in the public Interest. Readers' discretion is advised as these are subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Written by:Advocate Ajay Amitabh Suman
IP Adjutor [Patent and Trademark Attorney]
United & United
Email: amitabh@unitedandunited.com
Ph No: 9990389539

Casablaca Apparel Vs Polo Ralph Lauren Company

The Intersection of Trademark Rectification and Pending Litigation 

Introduction:

In a recent case , the Petitioner namely Casablanca Apparels Pvt. Ltd. filed a rectification petition seeking to alter the trademark ‘POLO’, which is registered under number 1277784 in class 25, belonging to Polo/Lauren Company L.P. This trademark application was originally filed on 8th April 2004 and granted on 18th January 2023. However, the maintainability of this rectification petition has come under scrutiny due to a related suit, CS (COMM) 523/2022, filed by Polo/Lauren Company L.P. against Casablanca Apparels Pvt. Ltd. This article delves into the legal reasoning behind the High Court's decision to dismiss the rectification petition, examining the interplay between the rectification proceedings and the pending litigation under Section 124 of the Trade Marks Act.

Background:

The case at hand involves two primary legal actions: the rectification petition filed by Casablanca Apparels Pvt. Ltd. and the infringement suit initiated by Polo/Lauren Company L.P. The rectification petition seeks to correct or cancel the registration of the trademark ‘POLO’ on grounds that may include non-use, misrepresentation, or prior use by the petitioner. Meanwhile, Polo/Lauren Company L.P.’s infringement suit aims to prevent Casablanca from using the ‘POLO’ mark, alleging that such use constitutes a violation of their trademark rights.

 Legal Framework:

The legal crux of this case lies within the provisions of the Trade Marks Act, 1999, particularly Section 124. This section deals with the stay of proceedings in cases where the validity of a trademark is questioned. Specifically, Section 124(1)(b)(ii) stipulates that if the issue of trademark validity arises during an infringement suit, the court must stay the proceedings and await the decision of the Registrar or the Appellate Board regarding the validity of the trademark.

The High Court's Decision:

In this instance, the High Court dismissed the rectification petition on the grounds that an application under Section 124 was already pending before the Trial Court. The court reasoned that allowing the rectification petition to proceed concurrently with the ongoing infringement suit would be procedurally improper and could potentially result in conflicting decisions. 

The court's decision hinges on the doctrine of judicial propriety and efficiency. By staying the rectification proceedings, the court ensures that the matter of the trademark’s validity is settled in a consistent and orderly manner. This approach prevents the possibility of contradictory rulings from different judicial bodies, which could undermine the legal process and lead to confusion.

Analysis:

The High Court's ruling underscores the importance of the principle of comity among courts, which dictates that courts should avoid interference with each other’s processes to maintain orderly and efficient adjudication. This principle is particularly pertinent in the realm of intellectual property law, where overlapping jurisdictions and concurrent proceedings are common.

Moreover, the decision aligns with the legislative intent behind Section 124 of the Trade Marks Act, which seeks to streamline the adjudication of trademark disputes. By mandating that questions of trademark validity be resolved before the specialized bodies of the Registrar or the Appellate Board, the Act aims to leverage the expertise of these bodies and ensure that the decisions are grounded in a thorough understanding of trademark law.

 Implications:

The implications of this ruling are significant for parties involved in trademark disputes. It signals to litigants that attempts to pursue rectification or cancellation of trademarks during the pendency of related infringement suits are likely to be stayed. This decision also emphasizes the necessity for parties to strategically consider the timing and forum of their legal actions to avoid procedural setbacks.

 Conclusion:

The case of Casablanca Apparels Pvt. Ltd. v. Polo/Lauren Company L.P. provides a critical insight into the procedural intricacies of trademark rectification and infringement litigation in India. The High Court’s dismissal of the rectification petition, based on the pending application under Section 124, reinforces the principle of judicial efficiency and the orderly resolution of trademark disputes.

Case Title: Casablaca Apparel Vs Polo Ralph Lauren Company

Order Date: 21.05.2024

Case No. C.O. (COMM.IPD-TM) 68/2024

Neutral Citation:NA

Name of Court: Delhi High Court 

Name of Hon'ble Judge: Anish Dayal. H.J.

Disclaimer:

Ideas, thoughts, views, information, discussions and interpretation expressed herein are being shared in the public Interest. Readers' discretion is advised as these are subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Written By: Advocate Ajay Amitabh Suman

IP Adjutor [Patent and Trademark Attorney]

United & United

Email: amitabh@unitedandunited.com

Ph No: 9990389539

The Indian Hotel Co Ltd. Vs Sagar Wadhwani

The Court issued an injunction restraining the Defendants from using the marks “GINGER TREE,” “Ginger Tree Goveia Suites,” “Ginger Tree Boutique Hotel,” or any other mark that is deceptively similar. The Court found that the use of these marks by the Defendants constituted trademark infringement and/or passing off. 

In its ruling, the Court thoroughly examined the evidence presented and determined that the Defendants' use of the aforementioned marks was likely to cause confusion among consumers. This confusion arises from the similarities between the Defendants' marks and the Plaintiff's established "GINGER" marks, which have garnered substantial recognition and goodwill in the marketplace.

Trademark infringement occurs when a party uses a mark that is identical or confusingly similar to a registered trademark owned by another party, without authorization, in a manner that is likely to confuse consumers regarding the source or origin of the goods or services. In this case, the Court concluded that the Defendants' marks were not only similar in appearance and sound but also conveyed a similar commercial impression to the Plaintiff’s “GINGER” marks.

Additionally, the Court found that the Defendants were engaged in passing off, a deceptive practice where one party misrepresents their goods or services as being associated with another party, thereby exploiting the latter’s established reputation and goodwill. The use of “GINGER TREE” and related marks by the Defendants was deemed a deliberate attempt to benefit from the Plaintiff's established brand reputation and to mislead consumers into believing there was an affiliation or endorsement by the Plaintiff.

This decision is significant as it underscores the importance of protecting trademark rights and maintaining the distinctiveness of a brand. By issuing the injunction, the Court aims to prevent any further unauthorized use of the Plaintiff's marks, thereby safeguarding the Plaintiff’s brand identity and reputation. The injunction ensures that the Plaintiff retains exclusive rights to the "GINGER" marks, preventing consumer confusion and protecting the brand from dilution and potential harm to its market position.

By enforcing the Plaintiff's exclusive rights to their "GINGER" marks, the Court's decision reinforces the integrity of trademark laws and provides a robust framework for the protection of intellectual property rights.

Case Title: The Indian Hotel Co Ltd. Vs Sagar Wadhwani

Order Date: 16.05.2024

Case No. CS(COMM) 406/2024

Neutral Citation:NA

Name of Court: Delhi High Court 

Name of Hon'ble Judge: Sanjeev Narula. H.J.

Disclaimer:

Ideas, thoughts, views, information, discussions and interpretation expressed herein are being shared in the public Interest. Readers' discretion is advised as these are subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Written By: Advocate Ajay Amitabh Suman,

IP Adjutor - Patent and Trademark Attorney,

Email: ajayamitabhsuman@gmail.com,

Ph No: 9990389539

Mahesh Gupta Vs Assistant Controller of Patent and Designs

Lack of significant technical advancement over prior arts and Rejection of Patent

The rejection of an Indian patent application for the ‘Portable Vehicle Management System’ has sparked legal contention, with the decision rendered on December 27, 2021. This article scrutinizes the rejection grounds and the subsequent appeal process, shedding light on the complexities of patent law.

Background of the Patent Application:

The appellant filed the patent application on December 6, 2016, seeking protection for a portable vehicle tracker designed for real-time monitoring of vehicle operation and conditions. The invention encompasses various functionalities, including continuous monitoring, anomaly detection, alert generation, and emergency response.

Grounds for Rejection:

The rejection primarily pivots on the argument that the invention lacks a significant technical advancement over prior art documents, particularly D4 (US2002019703A1) and D5 (US2015019266A1). These documents purportedly cover the core functionalities claimed in the present invention.

Analysis of Prior Art:

Upon scrutiny, it is contended that the invention fails to deviate from the disclosures in D4 and D5. The court underscores that a combined analysis of teachings from these prior art documents leads to the conclusion that the present invention does not signify a significant advancement.

Motivation to Combine:

The court further contends that a person skilled in the art (PSITA), equipped with knowledge of D4 and D5, would be inclined to amalgamate elements from these prior arts. Such motivation may arise from industry needs or problems, explicitly suggested within the prior art or commonly known in the field.

Inventive Step Analysis:

Based on a comprehensive comparison of the prior art and the claimed invention, the court determines that the patent application lacks an inventive step. The features claimed either exist in the prior art or can be inferred from it. Consequently, the rejection under Section 2(1)(ja) of the Patents Act, 1970, is upheld.

Outcome of the Appeal:

The court dismisses the appeal, affirming the patent office's decision to reject the application. It concludes that the claimed invention falls short of meeting the requisite standards for patentability, thus warranting the rejection.

Implications:

This case underscores the significance of demonstrating a clear inventive step and technical advancement over prior art in patent applications. It accentuates the importance of meticulous analysis and documentation of prior art references to bolster patentability claims. Moving forward, innovators must conduct thorough assessments to ensure their inventions meet the stringent criteria for patent protection.

Case Title: Mahesh Gupta Vs Assistant Controller of Patent and Designs
Judgment/Order Date: 29.05.2021
Case No. C.A.(COMM.IPD-PAT) 328/2022
Neutral Citation: 2024:DHC:4457
Name of Court: High Court of Delhi
Name of Hon'ble Judge: Sanjeev Narula H.J.

Disclaimer:

Ideas, thoughts, views, information, discussions and interpretation expressed herein are being shared in the public Interest. Readers' discretion is advised as these are subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Advocate Ajay Amitabh Suman
IP Adjutor [Patent and Trademark Attorney]
United & United
Email: amitabh@unitedandunited.com
Ph No: 9990389539

Sumil Chemical Industries P Ltd Vs Uk Crop Sciences

High Court Grants Ex Parte Injunction in Trademark Dispute: Sumil Chemical Industries P Ltd Vs Uk Crop Sciences

In a recent legal development dated May 24, 2021, Sumil Chemical Industries P Ltd, a key player in the agrochemical industry, initiated legal proceedings against Uk Crop Sciences for alleged trademark infringement and passing off.

The crux of the dispute lies in Sumil Chemical Industries P Ltd's trademarks, namely “COSAMIL,” “COSAMIL-DF,” and “COSAMIL GOLD,” which are specifically associated with their fungicide product range. The conflict arose when Sumil Chemical Industries P Ltd discovered Uk Crop Sciences' application for the mark "COSAMIN" in January 2024, prompting immediate legal action.

Presiding over the case (Case No. CS Comm 432 of 2024) at the High Court of Delhi, Hon'ble Judge Sanjeev Narula granted an ex parte injunction in favor of Sumil Chemical Industries P Ltd. The court's decision was grounded in the apparent phonetic, visual, and structural similarities between Sumil Chemical Industries P Ltd's "COSAMIL" trademarks and Uk Crop Sciences' "COSAMIN" mark. Given that both parties operate within the fungicide production sector, the court recognized the potential for consumer confusion.

The injunction, issued under Section 29(1) and (2)(b) of the Trademarks Act, acknowledges the likelihood of consumers mistakenly purchasing Uk Crop Sciences' fungicides under the assumption that they are associated with Sumil Chemical Industries P Ltd. Consequently, this finding lays the groundwork for both trademark infringement and passing off claims against Uk Crop Sciences.

Case Title: Sumil Chemical Industries P Ltd Vs Uk Crop Sciences
Judgement/Order Date: 24.05.2021
Case No. CS Comm 432 of 2024
Neutral Citation: NA
Name of Court: High Court of Delhi
Name of Hon'ble Judge: Sanjeev Narula H.J.

Disclaimer:

Ideas, thoughts, views, information, discussions and interpretation expressed herein are being shared in the public Interest. Readers' discretion is advised as these are subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Advocate Ajay Amitabh Suman
IP Adjutor [Patent and Trademark Attorney]
United & United
Email: amitabh@unitedandunited.com
Ph No: 9990389539

Singh and Singh Law Firm Vs Singh and Singh Attorneys

Can you covert this into detailed legal news?

Singh & Singh Law Firm LLP Files Lawsuit Against Singh and Singh Attorneys

Singh & Singh Law Firm LLP, a renowned legal entity established in 1997 under the trademark “Singh & Singh”, has taken legal action against Singh and Singh Attorneys, a law firm based in South Africa. The dispute centers around the similarity in their trademarks and services.

Singh & Singh Law Firm LLP, subsequently in 2005, adopted another trademark “Singh & Singh Advocates”. On the other hand, Singh and Singh Attorneys, based in South Africa, operate under the trademark/name “Singh and Singh Attorneys” and maintain an active website accessible in India via "https://singhlaw.co.za/," registered in the name of Defendant No. 1 on October 15, 2021. Defendant No. 2 is the owner/founder of Singh and Singh Attorneys.

In a recent ruling dated May 29, 2021, by the High Court of Delhi, presided over by Hon'ble Judge Sanjeev Narula, a preliminary assessment has been made regarding the case (Case No. CS Comm 466 of 2024). The court has observed that the marks used by both parties are identical and are being employed for similar services, targeting the same consumer base.

The court noted the extensive digital presence and global reputation of Singh & Singh Law Firm LLP, highlighting its clientele not only in India but also in South Africa. This assessment suggests that Singh & Singh Law Firm LLP's legal practice transcends geographical boundaries, indicating potential overlap with Singh and Singh Attorneys' operations.

The ruling implies that Singh & Singh Law Firm LLP has a strong prima facie case due to the substantial digital footprint and global reputation it enjoys.

Case Title: Singh and Singh Law Firm Vs Singh and Singh Attorneys

Judgement/Order Date: 29.05.2021

Case No. CS Comm 466 of 2024

Neutral Citation: NA

Name of Court: High Court of Delhi

Name of Hon'ble Judge: Sanjeev Narula H.J.

Disclaimer:

Ideas, thoughts, views, information, discussions and interpretation expressed herein are being shared in the public Interest. Readers' discretion is advised as these are subject to my subjectivity and may contain human errors in perception, interpretation and presentation of the fact and issue involved herein.

Advocate Ajay Amitabh Suman

IP Adjutor [Patent and Trademark Attorney]

United & United

Email: amitabh@unitedandunited.com

Ph No: 9990389539