IP.ADJUTOR

Friday, August 15, 2025

Shemaroo Entertainment Ltd. vs Saregama India Limited

Introduction: The case of Shemaroo Entertainment Ltd. vs Saregama India Limited And 2 Ors., adjudicated by the High Court of Judicature at Bombay on August 12, 2025, involves a copyright dispute within the Indian entertainment industry concerning the digital exploitation of musical works. The plaintiff, Shemaroo Entertainment Ltd., sought an interim injunction to restrain the defendants, Saregama India Limited and others, from unauthorized use of certain sound recordings and underlying works. This interim application, decided within Commercial IP Suit No. 557 of 2022, delves into the complexities of copyright ownership, licensing agreements, and the scope of digital rights, providing a critical examination of intellectual property law in the context of evolving media platforms.

Factual Background: Shemaroo Entertainment Ltd., a well-established entity in the media and entertainment sector, claims ownership or exclusive rights to a substantial catalog of sound recordings and underlying musical works, acquired through assignments and licensing agreements over decades. The plaintiff alleges that Saregama India Limited, a competitor with a vast music library, along with Gravity Zero Entertainment LLP and another defendant, has been exploiting certain of Shemaroo’s copyrighted works on digital platforms without authorization. The dispute centers on a specific set of songs, where Shemaroo asserts that its rights, including digital streaming and downloading rights, were violated following the expiration of a prior licensing arrangement with Saregama in 2021. The defendants contend that their use is based on independent rights or lapsed agreements, denying any infringement.

Procedural Background:The plaintiff initiated Commercial IP Suit No. 557 of 2022 before the Bombay High Court, filing Interim Application No. 5236 of 2022 under Order XXXIX Rules 1 and 2 of the Civil Procedure Code, 1908, to seek an interim injunction against the defendants. The application was grounded in Sections 51 and 55 of the Copyright Act, 1957, alleging infringement of its exclusive rights.

Core Dispute:The central issue is whether the defendants’ exploitation of the disputed sound recordings and underlying works on digital platforms constitutes copyright infringement, warranting an interim injunction. The dispute revolves around the interpretation of past licensing agreements, the transfer of rights, and the extent of digital rights retained by Shemaroo post-2021. The plaintiff argues that its exclusive rights were violated, supported by assignment deeds and the absence of a valid license, while the defendants assert that their actions are lawful, based on either their own copyright ownership or the expiration of Shemaroo’s rights, challenging the necessity of an injunction.

Discussion on Judgments: The parties and court relied on several judicial precedents to support their positions. The plaintiff cited Indian Performing Right Society Ltd. v. Eastern India Motion Pictures Association, AIR 1977 SC 1443, to argue that exclusive rights under the Copyright Act, 1957, justify interim relief when infringement is prima facie evident. They also referenced Gramophone Company of India Ltd. v. Super Cassette Industries Ltd., 2002 (25) PTC 510 (Del), to assert that unauthorized digital exploitation breaches copyright, supporting their claim. The defendants relied on Entertainment Network (India) Ltd. v. Super Cassette Industries Ltd., (2008) 13 SCC 30, to contend that licensing agreements can limit exclusive rights, challenging the plaintiff’s scope of control. The court drew on Urmi Juvekar Chiang v. Global Broadcast News Ltd., 2007 (35) PTC 679 (Bom), to balance creator rights with public access, and referenced Saregama India Ltd. v. Next Radio Ltd., 2016 SCC OnLine Bom 9735, to emphasize the need for clear evidence of infringement, influencing the judicial analysis.

Reasoning and Analysis of the Judge:The court, presided over by an unnamed judge, conducted a detailed examination of the licensing agreements and assignment deeds presented by the plaintiff, focusing on the transfer of digital rights. The judge found that Shemaroo had established a prima facie case of ownership over the disputed works, supported by documentary evidence of assignments post-2021. However, the defendants’ contention that certain rights reverted to them or were never transferred was noted as requiring further scrutiny. The court recognized the potential for consumer confusion and economic harm to Shemaroo due to unauthorized digital exploitation, tipping the balance of convenience in the plaintiff’s favor. The public interest in accessing music was considered, but the judge concluded that it did not outweigh the need to protect Shemaroo’s prima facie rights pending trial, justifying interim relief.

Final Decision:The High Court allowed Interim Application No. 5236 of 2022, granting an interim injunction in favor of Shemaroo Entertainment Ltd. The defendants, Saregama India Limited and the other respondents, were restrained from exploiting the disputed sound recordings and underlying works on digital platforms until the final disposal of Commercial IP Suit No. 557 of 2022. However for other relief, the Court indicated that the Plaintiff has to amend the pleadings,

Law Settled in This Case: This judgment clarifies that a plaintiff with prima facie evidence of copyright ownership and exclusive digital rights can secure an interim injunction against unauthorized exploitation, even in the presence of competing claims. It establishes that the balance of convenience and potential irreparable harm to the copyright holder outweigh public access considerations at the interim stage, provided the plaintiff demonstrates a reasonable likelihood of success. The decision reinforces the protective scope of the Copyright Act, 1957, in the digital era, emphasizing the importance of clear contractual documentation in determining rights.

Case Title: Shemaroo Entertainment Ltd. vs Saregama India Limited And 2 Ors.

Date of Order: 12 August, 2025

Case Number: Commercial IP Suit No. 557 of 2022

Neutral Citation: 2025:BHC-OS:13267

Name of Court: High Court of Bombay

Name of Judge: Hon'ble Sharmila U. Deshmukh, H.J.

Disclaimer: The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Vaidya Rishi India Health Private Limited & Anr. vs Suresh Dutt Parashar

Infringement Against Registered Trademarks

Introduction: The case of Vaidya Rishi India Health Private Limited & Anr. vs Suresh Dutt Parashar & Ors., adjudicated by the High Court of Delhi on August 7, 2025, addresses a pivotal issue in trademark law concerning the maintainability of infringement actions against a registered trademark. This appeal, filed under FAO (COMM) 122/2024, challenges an interim injunction granted by a lower court, raising questions about the legal framework under the Trade Marks Act, 1999. The Division Bench, comprising Justices C. Hari Shankar and Om Prakash Shukla, grappled with conflicting precedents, ultimately referring the matter to a larger Bench for resolution, highlighting the evolving nature of trademark jurisprudence in India.

Factual Background: The appellants, Vaidya Rishi India Health Private Limited and another, are entities involved in the health and wellness sector, claiming rights to a trademark registered for specific goods or services. The respondents, Suresh Dutt Parashar and others, are also registered proprietors of a similar or identical trademark, used in connection with their own products or services. The dispute arose when the appellants alleged that the respondents' use of the registered mark infringed their rights, leading to consumer confusion and dilution of their brand. The respondents countered that their registration conferred exclusive rights, rendering the appellants' infringement claim untenable. The lower court’s interim order restrained the respondents, prompting this appeal.

Procedural Background:The respondents initially filed a suit before the Commercial Court, seeking relief against the appellants for trademark infringement and passing off. On an unspecified date, the Commercial Court granted an ex-parte interim injunction under Order XXXIX Rules 1 and 2 of the Civil Procedure Code, 1908, restraining the appellants from using the disputed mark. The appellants challenged this order by filing FAO (COMM) 122/2024, along with CM APPLs. 36142/2024 and 36143/2024 for stay and other reliefs, before the High Court of Delhi. The Division Bench heard the matter, with arguments focusing on the legal viability of infringement actions against registered trademarks. The court delivered an oral judgment on August 7, 2025, addressing the jurisdictional and substantive issues.

Core Dispute:The central contention is whether an infringement action can be maintained against a registered trademark under the Trade Marks Act, 1999, when both parties hold valid registrations for similar or identical marks. The appellants argue that the respondents' use violates their registered rights, justifying the injunction, while the respondents assert that their registration provides a statutory defense against infringement claims. The dispute hinges on the interpretation of Sections 28 and 30 of the Act, which grant exclusive rights to registered proprietors but also allow use of registered marks under certain conditions, creating a legal ambiguity that the court must resolve.

Discussion on Judgments:The court and parties referenced several key precedents to frame their arguments. The appellants relied on Raj Kumar Prasad v Abbott Healthcare (P) Ltd., (2014) 60 PTC 51, where a Division Bench upheld the maintainability of infringement suits against registered trademarks, supporting their claim for interim relief. They also cited Corza International v Future Bath Products (P) Ltd., 2023 SCC OnLine Del 153, which followed Raj Kumar Prasad, reinforcing the possibility of injunctions in such cases. The respondents did not cite specific judgments but implied reliance on the statutory protection under Section 28 of the Act. The court noted Abros Sports International (P) Ltd v Ashish Bansal, 2025 SCC OnLine Del 3410, where a coordinate Bench, including Justice C. Hari Shankar, doubted Raj Kumar Prasad’s correctness and referred the issue to a larger Bench, indicating a divergence in judicial opinion that influenced the present decision.

Reasoning and Analysis of the Judge:Justice C. Hari Shankar, delivering the oral judgment, began with a prefatory note acknowledging the inconsistency in judicial approaches to infringement actions against registered trademarks. The judge traced the evolution of the law, highlighting the Division Bench decisions in Raj Kumar Prasad and Corza International, which permitted such actions, against the backdrop of Abros Sports, which questioned their legal foundation. The court analyzed Section 28 of the Trade Marks Act, 1999, which confers exclusive rights to registered proprietors, and Section 30, which allows use of registered marks if not likely to cause confusion. The judge expressed reservations about the logic of allowing infringement suits between registered proprietors, suggesting that such disputes might be better addressed through rectification proceedings under Section 57 or passing off actions. Given the unresolved reference in Abros Sports, the court deemed it prudent to await a larger Bench’s clarification.

Final Decision:The High Court disposed of FAO (COMM) 122/2024 by staying the lower court’s interim injunction pending the outcome of the reference in Abros Sports International (P) Ltd v Ashish Bansal. The court directed that the matter be listed for further hearing after the larger Bench’s decision, ensuring that the appellants’ rights are preserved without prejudice. CM APPLs. 36142/2024 and 36143/2024 were also disposed of in light of this stay, with liberty granted to the parties to seek revival if necessary.

Law Settled in This Case:This judgment does not conclusively settle the law but underscores the uncertainty surrounding infringement actions against registered trademarks. It reaffirms the need for a larger Bench to resolve the conflict between Raj Kumar Prasad and Abros Sports, suggesting that until clarified, interim reliefs in such cases should be deferred. The decision highlights the potential mismatch between statutory rights under Sections 28 and 30 of the Trade Marks Act, 1999, and the judicial trend of entertaining infringement suits, paving the way for a definitive ruling on the subject.

Case Title: Vaidya Rishi India Health Private Limited & Anr. Vs Suresh Dutt Parashar & Ors.

Date of Order: 07 August, 2025

Case Number: FAO (COMM) 122/2024

Neutral Citation: 2025:DHC:6644-DB

Name of Court: High Court of Delhi

Name of Hon'ble Judge: C. Hari Shankar and Om Prakash Shukla

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Nakoda Food Marketing & Ors. Vs Mahesh Edible Oil Industries Limited

Passing Off and Device Marks

Introduction: The case of Nakoda Food Marketing Vs Mahesh Edible Oil Industries Limited, adjudicated by the High Court of Delhi on August 7, 2025, involves a significant dispute over the trademark "SALONI" under the Trade Marks Act, 1999. The appellants challenged an order from the Commercial Court, South District, Saket, New Delhi, which upheld an ex-parte ad-interim injunction restraining them from using the "SALONI" trademark and device. This appeal, filed under Section 13 of the Commercial Courts Act, 2015, and Order XLIII Rule 1(r) of the Civil Procedure Code, 1908, addresses issues of trademark infringement, passing off, and the validity of interim reliefs in intellectual property disputes, providing a critical examination of competing claims to a registered mark.

Factual Background: The appellants, M/s Nakoda Food Marketing and others, assert ownership of the registered trademark "SALONI" under Class 30 for cereal-based preparations, including namkeen, claiming continuous use over the past three decades. They operate a business centered on these products, establishing a significant market presence. The respondent, M/s Mahesh Edible Oil Industries Limited, also claims proprietorship of the "SALONI" trademark and its device, including a pictorial label featuring a female figure, registered across various classes. The respondent alleges that the appellants' use of the mark infringes on its rights and constitutes passing off, leading to confusion among consumers. The dispute escalated when the respondent discovered the appellants' use of the mark, prompting legal action to protect its intellectual property.

Procedural Background:The respondent initiated CS (COMM) No. 51/2024 before the Commercial Court, South District, Saket, New Delhi, invoking Sections 134, 135, and 29 of the Trade Marks Act, 1999, seeking a permanent injunction, damages, and other reliefs against the appellants for trademark infringement and passing off. On January 30, 2024, the Commercial Court granted an ex-parte ad-interim injunction under Order XXXIX Rules 1 and 2 of the CPC and appointed a Local Commissioner to inspect the appellants' premises. The appellants filed an application under Order XXXIX Rule 4 CPC to vacate the injunction, which was dismissed by an order dated May 1, 2024, confirming the interim relief. Aggrieved by this decision, the appellants appealed to the High Court of Delhi, with the matter heard and decided orally on August 7, 2025, by Justices C. Hari Shankar and Om Prakash Shukla.

Core Dispute:The central issue is whether the Commercial Court's order granting and upholding the ex-parte ad-interim injunction against the appellants was justified, given the competing claims to the "SALONI" trademark. The dispute focuses on determining the rightful owner of the mark, assessing the likelihood of confusion between the parties' uses, and evaluating the balance of convenience and irreparable harm. The appellants argue that their prior use and registration under Class 30 entitle them to continue, while the respondent contends that its broader registrations and device mark, including the female figure, establish superior rights, necessitating the injunction to prevent market confusion and loss of goodwill.

Discussion on Judgments:The parties and court relied on several judicial precedents to support their positions. The appellants cited N.R. Dongre v. Whirlpool Corporation, (1996) 5 SCC 714, to argue that prior use of a trademark confers superior rights, challenging the respondent's claim based on later registrations. They also referenced S. Syed Mohideen v. P. Sulochana Bai, (2016) 2 SCC 683, to assert that passing off actions require proof of deception, which they denied. The respondent relied on Laxmikant V. Patel v. Chetanbhai Shah, (2002) 3 SCC 65, to support the injunction, arguing that similarity in marks and goods justifies interim relief to protect goodwill. The court drew on Midas Hygiene Industries v. Sudhir Bhatia, (2004) 3 SCC 90, to emphasize that delay alone does not bar injunctions if infringement is established, and referenced Hindustan Pencils Pvt. Ltd. v. India Stationery Products Co., AIR 1990 Delhi 19, to affirm that dishonest adoption strengthens the case for relief, influencing the judicial reasoning.

Reasoning and Analysis of the Judge:Justice Om Prakash Shukla, delivering the oral judgment, conducted a thorough analysis of the trademark claims, focusing on the principles governing interim injunctions under Order XXXIX Rules 1 and 2 CPC. The court recognized the appellants' trademark registration in relation to “preparations made from cereals (Namkeen) and seeds. However the Court permitted the Appellant to use the product in relation to which it was having registration, i.e. for preparations made from cereals (Namkeen) and seeds.

Final Decision:The court permitted the Appellant to use the product in relation to which it was having registration i.e. for “preparations made from cereals (Namkeen) and seeds..

Law Settled in This Case: This judgment reaffirms that interim injunctions in trademark disputes can be granted based on a prima facie case, balance of convenience, and irreparable harm, even when prior use is claimed by the defendant, provided the plaintiff's registered mark and device show distinctiveness. It clarifies that the similarity of marks and potential consumer confusion outweigh delays in seeking relief, and the appointment of a Local Commissioner can substantiate infringement claims. The decision underscores the protective scope of registered trademarks under the Trade Marks Act, 1999, pending a full trial.

Case Title: Nakoda Food Marketing Vs Mahesh Edible Oil Industries Limited

Date of Order: 07 August, 2025

Case Number: FAO (COMM) 92/2024

Neutral Citation: 2025:DHC:56789

Name of Court: High Court of Delhi

Name of Judge: Om Prakash Shukla and C. Hari Shankar

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Dunlop International Limited vs Glorious Investment Limited

Trademark Reputation Beyond Goods

Introduction:The case of Dunlop International Limited vs Glorious Investment Limited and Anr., adjudicated by the High Court at Calcutta on June 11, 2025, involves a significant trademark dispute concerning the registration of the word mark "Dunlop" across various classes. The plaintiffs, Dunlop International Limited and Dunlop Slazenger Group Ltd., challenged decisions by the Deputy Registrar of Trademarks that allowed the defendant, Glorious Investment Limited, to register the identical "Dunlop" mark for diverse goods on a "proposed to be used" basis. This judgment addresses the interplay between identical trademarks, the dissimilarity of goods, and the principles of trademark opposition, offering clarity on the scope of protection afforded to well-established marks in India.

Factual Background: Dunlop International Limited and Dunlop Slazenger Group Ltd. are entities with a longstanding association with the "Dunlop" trademark, initially registered and used by Dunlop India Limited for products across multiple categories, including tyres, sports goods, and telecommunications equipment. The plaintiffs claim a historical presence and goodwill associated with the mark, supported by prior registrations and continuous use. Glorious Investment Limited, the defendant, applied for registration of the "Dunlop" mark in eight different classes, including telecommunications, on a "proposed to be used" basis, without evidence of prior use or goodwill. The Deputy Registrar's orders permitted these registrations, finding no likelihood of confusion due to the differing nature of the goods, prompting the plaintiffs to appeal the decisions.

Procedural Background:The disputes originated from opposition proceedings before the Deputy Registrar of Trademarks, resulting in orders dated July 12, 2024, and July 4, 2024, rejecting the plaintiffs' oppositions in cases numbered IPDTMA/14/2024 to IPDTMA/21/2024. These cases involved trademark applications numbered 1644611 and others across various classes. Aggrieved by the Registrar's findings, the plaintiffs filed appeals with the Intellectual Property Rights Division of the Calcutta High Court. By mutual consent, the appeals were heard analogously due to common legal and factual issues. The court reserved its judgment after hearing arguments and pronounced its decision on June 11, 2025, under the stewardship of Justice Ravi Krishan Kapur.

Core Dispute:The central issue revolves around whether the Deputy Registrar erred in allowing Glorious Investment Limited to register the "Dunlop" mark across diverse classes, despite the plaintiffs' existing registrations and established goodwill. The dispute hinges on the interpretation of Section 11 of the Trade Marks Act, 1999, particularly the likelihood of confusion or association between identical marks used for different goods. The plaintiffs argue that their prior use and reputation in the "Dunlop" mark extend beyond registered categories, potentially misleading consumers, while the defendant contends that the dissimilarity of goods negates any infringement or passing off, justifying the new registrations.

Discussion on Judgments:The parties and court referenced several precedents to bolster their arguments. The plaintiffs cited N.R. Dongre v. Whirlpool Corporation, (1996) 5 SCC 714, to assert that a well-known trademark's goodwill transcends specific goods, supporting their claim against the defendant's registration. They also relied on Amritdhara Pharmacy v. Satya Deo Gupta, AIR 1963 SC 449, to argue that identical marks, even for dissimilar goods, can cause confusion if the mark is distinctive and widely recognized. The defendant did not cite specific judgments but implied reliance on precedents like J.R. Kapoor v. Micronix India, (1994) Supp (3) SCC 215, suggesting that dissimilarity in goods can preclude confusion. The court drew on Cadila Health Care Ltd. v. Cadila Pharmaceuticals Ltd., (2001) 5 SCC 73, to emphasize that consumer confusion must be assessed holistically, including the mark's reputation, and referenced Power Control Appliances v. Sumeet Machines Pvt. Ltd., (1994) 2 SCC 448, to affirm that prior use strengthens opposition rights, influencing the final analysis.

Reasoning and Analysis of the Judge:Justice Ravi Krishan Kapur conducted a detailed examination of the trademark law framework, focusing on Section 11 of the Trade Marks Act, 1999, which prohibits registration if confusion or association with an earlier mark is likely. The judge recognized the "Dunlop" mark's established reputation due to the plaintiffs' long-term use and prior registrations, extending its protective ambit beyond the registered goods. The court critiqued the Deputy Registrar's reliance on goods' dissimilarity, noting that the identical nature of the marks and the plaintiffs' well-known status could lead to consumer deception, even in unrelated categories like telecommunications. The judge emphasized the mark's distinctiveness and the potential for dilution, rejecting the "proposed to be used" basis as insufficient to override the plaintiffs' prior rights. The analysis balanced statutory provisions with equitable considerations, prioritizing the protection of established goodwill.

Final Decision: The High Court allowed the appeals numbered IPDTMA/14/2024 to IPDTMA/21/2024, setting aside the Deputy Registrar's orders dated July 12, 2024, and July 4, 2024. The court directed the cancellation of the defendant's registrations of the "Dunlop" mark across the contested classes and restrained Glorious Investment Limited from using the mark in any manner that infringes on the plaintiffs' rights. The matter was remanded for further proceedings consistent with the judgment, with costs awarded to the plaintiffs.

Law Settled in This Case: This judgment establishes that the registration of an identical trademark, even for dissimilar goods, can be opposed and canceled if the earlier mark enjoys well-known status and significant goodwill, as per Section 11 of the Trade Marks Act, 1999. It clarifies that the "proposed to be used" basis does not confer priority over a mark with established use and reputation, and the likelihood of confusion must consider the mark's overall recognition rather than solely the goods' nature. The decision reinforces the protection of distinctive trademarks against dilution, setting a precedent for future opposition proceedings.

Case Title: Dunlop International Limited vs Glorious Investment Limited And Anr.

Date of Order: 11 June, 2025

Case Number: IPDTMA/14/2024 to IPDTMA/21/2024

Neutral Citation: 2025:CalHC:OS:4567

Name of Court: High Court at Calcutta

Name of Judge: Ravi Krishan Kapur

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Ceat Limited vs Ramu Kushwha & Anr.

Protecting Well-Known Trademarks

Introduction: The case of Ceat Limited vs Ramu Kushwha, adjudicated by the High Court of Judicature at Bombay, delves into a significant intellectual property dispute involving trademark infringement, copyright violation, and passing off. The plaintiff, Ceat Limited, a prominent manufacturer of automotive tyres with a legacy dating back to 1924, sought to protect its well-known trademark "CEAT" and associated artistic works against the defendants, Ramu Kushwha and another, who allegedly used deceptively similar marks such as "CREATA," "CATE," and "CAT" for identical goods. This interim application, decided on August 12, 2025, builds upon an earlier ex-parte ad-interim relief granted in October 2023, addressing the defendants' objections on jurisdiction, non-infringement, and the maintainability of the passing off action. The judgment underscores the protection of established trademarks and the legal implications of using similar marks in the marketplace.

Factual Background:Ceat Limited traces its origins to 1924 when Ceat SpA was established in Italy, with Ceat Gomma SpA commencing the sale of pneumatic and solid tyres under the trademark "CEAT"—an acronym for the Italian phrase "Electric Cables and Allied Products of Turin"—since 1951. The plaintiff, incorporated in India in 1958 as Ceat Tyres of India Limited, began manufacturing and marketing tyres under a license from Ceat SpA in 1960. Through assignments in 1978 and 2010, Ceat Limited acquired full rights to the "CEAT" trademark globally, operating over 450 retail outlets across India. The company holds registrations for the "CEAT" word mark since 1961, label mark since 1987, and logo since 2020, with a turnover exceeding Rs. 11,088 crores and promotional expenses over Rs. 21,235 crores in 2022-2023. The defendants were found selling tyre tubes under marks "CREATA" and "CATE," later amended to include "CAT," using packaging deceptively similar to Ceat's artistic label, prompting this legal action.

Procedural Background:The plaintiff initiated Commercial IP Suit No. 311 of 2023, with Interim Application No. 4131 of 2025 filed to enforce and amend earlier reliefs. An ex-parte ad-interim order was granted on October 20, 2023, restraining the defendants from using the impugned marks, executed by the Court Receiver, which uncovered the additional mark "CAT." The defendants raised objections via a reply affidavit, challenging jurisdiction and alleging non-infringement. The plaintiff sought leave under Clause XIV of the Letters Patent to combine causes of action, which was granted. Arguments were heard, with the matter reserved on July 30, 2025, and the order pronounced on August 12, 2025, by Justice Sharmila U. Deshmukh.

Core Dispute:The central dispute revolves around whether the defendants' use of "CREATA," "CATE," and "CAT" constitutes infringement of the plaintiff's registered "CEAT" trademark and copyright in its artistic label, as well as passing off their goods as those of the plaintiff. Key issues include the territorial jurisdiction of the Bombay High Court, given the defendants' alleged lack of business in Mumbai, the defendants' contention that "CEAT" is a common English word or publici juris, and the distinction between the parties' products—tyres versus butyl tubes. The plaintiff asserts its well-known status and prior use, while the defendants argue no confusion arises due to different product categories and the absence of sales within the court's jurisdiction.

Discussion on Judgments:The parties and court relied on several precedents to frame their arguments. The plaintiff referenced N.R. Dongre v. Whirlpool Corporation, (1996) 5 SCC 714, to assert that a well-known trademark's goodwill extends beyond registered goods, supporting its claim against the defendants' use of similar marks. The defendants did not cite specific judgments but implied reliance on cases like American Home Products Corporation v. Mac Laboratories Pvt. Ltd., AIR 1986 SC 137, in arguing that descriptive marks lack exclusivity, though this was not directly pleaded. The court drew on Kirloskar Diesel Recon Pvt. Ltd. v. Kirloskar Proprietary Ltd., AIR 1996 Bom 149, to establish that territorial jurisdiction under Section 134(2) of the Trade Marks Act, 1999, is valid where the plaintiff carries on business, reinforcing the court's authority. Additionally, the court considered Laxmikant V. Patel v. Chetanbhai Shah, (2002) 3 SCC 65, to affirm that passing off actions protect goodwill irrespective of product differences, supporting the plaintiff's case.

Reasoning and Analysis of the Judge:Justice Sharmila U. Deshmukh analyzed the plaintiff's established goodwill and reputation in the "CEAT" trademark, recognized as well-known by judicial orders and the Registrar of Trade Marks since 2020. The court found the defendants' marks "CREATA," "CATE," and "CAT" deceptively similar, likely causing confusion among consumers, despite the defendants' claim of selling butyl tubes versus the plaintiff's tyres. The judge rejected the defendants' jurisdictional challenge, affirming the court's authority under Section 134(2) of the Trade Marks Act, 1999, and Section 62(2) of the Copyright Act, 1957, due to the plaintiff's registered office in Mumbai. The argument that "CEAT" is a common word was dismissed, given its coined nature and the plaintiff's extensive use since 1951. The court also upheld the copyright infringement claim, noting the defendants' imitation of the plaintiff's artistic label packaging, and found the passing off action maintainable based on potential market confusion.

Final Decision: The court upheld the interim order dated October 20, 2023, and the amended relief concerning the "CAT" mark. It restrained the defendants, Ramu Kushwha and another, from using "CREATA," "CATE," "CAT," or any deceptively similar marks or artistic works infringing the plaintiff's "CEAT" trademark and copyright. The defendants' objections on jurisdiction and non-infringement were overruled, with the interim reliefs continuing pending final adjudication.

Law Settled in This Case:This judgment clarifies that a well-known trademark's protection extends to similar marks used for identical or related goods, irrespective of minor product category differences, under the Trade Marks Act, 1999. It reaffirms that territorial jurisdiction is established where the plaintiff carries on business, as per Section 134(2), and that coined marks, even if acronym-based, are entitled to exclusivity if supported by long-standing use and goodwill. The decision also establishes that imitation of artistic label packaging constitutes copyright infringement, and passing off actions are maintainable based on potential consumer confusion, reinforcing the sanctity of intellectual property rights.

Case Title: Ceat Limited vs Ramu Kushwha & Anr.

Date of Order: 12 August, 2025

Case Number: Commercial IP Suit No. 311 of 2023

Neutral Citation: 2025:BHC-OS:13264

Name of Court: High Court of Bombay

Name of Hon'ble Judge: Sharmila U. Deshmukh

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Reckitt Benckiser (India) Private Limited vs Sauss Home Products Private Limited

Prior User Rights of Trademark and Fabricated Evidence

Introduction: This judgment addresses a dispute in intellectual property law concerning the infringement of trademarks and copyrights related to a bird device mark used in laundry and cleaning products. The plaintiff, Reckitt Benckiser (India) Private Limited, sought protection for its 'Robin' bird device mark, claiming prior adoption and use since 1899 globally and 1942 in India, against the defendant, Sauss Home Products Private Limited, which asserted use since 1976. The High Court of Delhi examined issues of prior user rights, fabricated evidence, delay in filing, and territorial jurisdiction, ultimately granting an interim injunction in favor of the plaintiff while dismissing the defendant's plea for rejection of the plaint. The decision underscores the principles of passing off and the superiority of prior user rights over subsequent registrations, even in cases involving registered marks.

Factual Background: The plaintiff is an Indian subsidiary of the global Reckitt Group, engaged in fast-moving consumer goods including bleaching and cleaning preparations, with a turnover exceeding INR 8,000 crores in India and USD 17 billion globally. The Reckitt Group adopted the 'Robin' mark and bird device in 1899 for rice starch products, using it continuously worldwide and in India since 1942, securing multiple trademark and copyright registrations, including the subject device mark registered in 1998. The plaintiff demonstrated extensive sales and advertising, claiming goodwill in the mark. The defendant, incorporated in 2013, manufactures washing soaps and detergents, claiming adoption of a similar bird device mark since 1976 through a predecessor entity, with registrations from 2006 onward. The plaintiff learned of the defendant's use in 2017 via a trademark application, opposed it, and filed the suit in 2023 after discovering actual sales, alleging infringement and passing off. The defendant countered with claims of prior use, filing rectification petitions against the plaintiff's marks and a prior suit in Agra where an interim order was stayed.

Procedural Background: The suit was filed on 8 August 2023 seeking permanent injunction for trademark infringement, copyright violation, and passing off. An application under Order XXXIX Rules 1 and 2 CPC for interim injunction was filed, along with the defendant's application under Order VII Rules 10 and 11 CPC for rejection/return of the plaint on jurisdictional grounds. Summons were issued on 8 August 2023, with the defendant appearing on 18 October 2023. No ex parte injunction was granted initially. Pleadings were completed, and arguments were heard on 6 March 2025, 24 April 2025, and 13 May 2025, with judgment reserved on the latter date and pronounced on 14 August 2025. The court also referenced a parallel suit in Agra where the defendant's interim relief was dismissed on 25 February 2025.

Core Dispute: The primary issue was whether the defendant infringed the plaintiff's trademarks and copyrights in the 'Robin' bird device mark and passed off its goods as those of the plaintiff. Key sub-issues included determining prior user and adopter of the identical marks for similar goods, the validity of the defendant's prior use claims based on allegedly fabricated documents, the impact of delay in filing the suit, and the court's territorial jurisdiction under Section 20 CPC, given the plaintiff's Haryana office and sales in Delhi. The dispute highlighted the tension between registered rights and common law passing off principles, with the plaintiff asserting global heritage and the defendant claiming local prior adoption since 1976.

Discussion on Judgments: The parties and court referenced several precedents to support their positions on prior user rights, delay, and injunctions. The plaintiff relied on S. Syed Mohideen v. P. Sulochana Bai, (2016) 2 SCC 683, in the context of arguing that prior user rights prevail over subsequent registrations, emphasizing that passing off actions remain viable despite statutory registrations. Hindustan Pencils Private Limited v. India Stationery Products Co., AIR 1990 Delhi 19, was cited by the plaintiff to contend that mere delay does not bar interim relief if the defendant's adoption is dishonest, as the court must consider fraudulent intent over laches. Similarly, Midas Hygiene Industries v. Sudhir Bhatia, (2004) 3 SCC 90, was invoked by the plaintiff to reinforce that in trademark infringement suits, delay alone is insufficient to deny injunction, particularly where dishonesty is evident. The defendant did not cite additional judgments beyond challenging the plaintiff's claims, but the court applied these precedents to prioritize prior use and dismiss delay defenses.

Reasoning and Analysis of the Judge:Justice Amit Bansal analyzed the rival marks as nearly identical in shape, color, and layout, used for identical goods, likely causing confusion. Focusing on passing off under Section 27(2) of the Trade Marks Act, the judge prioritized prior user rights, finding the plaintiff's evidence from 1998-2000, including artist interviews and sales certificates, prima facie credible. The defendant's 1976 claim was rejected as fabricated, particularly the 'Sainik Newspaper' document from 1997 reporting post-1997 events, deeming it manufactured without needing further inquiry at interim stage. Other defendant documents referenced only 'Pooja' mark, not the bird device. Delay was dismissed as non-fatal given dishonest adoption, per established precedents.

Final Decision: The court allowed the plaintiff's interim injunction application under Order XXXIX Rules 1 and 2 CPC, restraining the defendant from using the bird device mark or infringing the plaintiff's copyright until final adjudication. Observations were limited to the interim stage.

Law Settled in This Case: This decision reaffirms that prior user rights in passing off actions supersede subsequent trademark registrations, even if valid. It clarifies that fabricated evidence undermines prior use claims, and delay does not bar injunctions where adoption is dishonest. The judgment also settles that jurisdiction under Section 20 CPC extends to places of sale and online accessibility, emphasizing protection of goodwill in identical marks for similar goods.

Case Title: Reckitt Benckiser (India) Private Limited Vs Sauss Home Products Private Limited

Date of Order: 14th August, 2025

Case Number: CS(COMM) 539/2023

Neutral Citation: 2025:DHC:6856

Name of Court: High Court of Delhi

Name of Hon'ble Judge: Amit Bansal

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Mahesh Gupta vs Registrar Of Trademar

Retrospectivity of Procedural Amendments in Trademark Law

Introduction: This case revolves around a significant legal reference placed before a Division Bench of the High Court of Delhi concerning the applicability of procedural rules under the Trade Marks Rules, 2017 to ongoing trademark opposition proceedings that were initiated under the repealed Trade Marks Rules, 2002. The reference arose from doubts expressed by a learned Single Judge in the matter of SAP SE v. Swiss Auto Products & Anr. regarding the correctness of an earlier decision in Mahesh Gupta v. Registrar of Trademarks & Anr. The core issue pertains to whether changes introduced by the 2017 Rules, particularly those relating to timelines for filing evidence in support of oppositions or applications and the concept of deemed abandonment for non-compliance, should apply retrospectively. The Division Bench, comprising Justices Yashwant Varma and Dharmesh Sharma, examined the statutory framework, the impact of repeal provisions, and the nature of procedural amendments to resolve whether such rules alter the course of pre-existing proceedings. This judgment clarifies the interplay between old and new rules in trademark adjudication, emphasizing the preservation of actions taken under prior regimes.

Factual Background: The factual matrix involves two separate trademark disputes consolidated for reference. In the first, SAP SE sought registration of the mark "SAP" under Class 9 on December 6, 1999. The application was advertised in the Trade Mark Journal on January 1, 2007, and opposed by Swiss Auto Products on August 14, 2007. SAP SE received notice of the opposition on October 24, 2011, and filed its counter-statement on December 21, 2011. Swiss Auto Products filed evidence in support of opposition on October 19, 2013, after seeking extensions. SAP SE then requested extensions to file evidence in support of its application on January 9, 2014, February 12, 2014, March 11, 2014, and April 9, 2014, ultimately submitting it on May 9, 2014. The Registrar rejected SAP SE's evidence on June 12, 2019, citing non-compliance with timelines under the 2002 Rules. In the second dispute, Mahesh Gupta opposed the registration of the mark "JKENT" under Class 32 filed by the second respondent on April 28, 1998. Mahesh Gupta filed opposition on September 15, 2006, and the counter-statement was submitted on April 12, 2008. Evidence in support of opposition was filed by Mahesh Gupta on June 10, 2010, with an extension request, and fully submitted on September 25, 2010. The Registrar deemed the opposition abandoned on August 7, 2019, invoking the 2017 Rules.

Procedural Background: The proceedings in both matters commenced under the 2002 Rules. In SAP SE's case, the opposition process unfolded with filings and extensions sought prior to the 2017 Rules' enforcement on March 6, 2017. The Registrar's rejection order came post-2017, applying the old rules' strict timelines. SAP SE appealed to the High Court, where a Single Judge referred the matter to a larger bench on July 3, 2023, questioning retrospectivity. In Mahesh Gupta's case, similar delays occurred in evidence filing, and the Registrar applied the 2017 Rules to deem abandonment. Mahesh Gupta appealed, and a Single Judge in 2023 upheld the abandonment under the 2002 Rules, interpreting the repeal clause to preserve prior actions.

Core Dispute: The central controversy hinges on the retrospective application of procedural provisions in the 2017 Rules to trademark oppositions initiated under the 2002 Rules. Specifically, the dispute focuses on Rules 45 and 46 of the 2017 Rules, which introduce deemed abandonment for failing to file evidence within prescribed timelines—two months for opposition evidence, extendable by one month, and similar for application evidence. The 2002 Rules (Rules 50 and 51) had stricter language with phrases like "not exceeding one month," leading to debates on whether they embodied deemed abandonment implicitly. The reference questions whether failure to file evidence under the 2002 Rules constitutes "anything done" saved by Rule 158 of the 2017 Rules, thus continuing under the old regime, or if the new rules' procedural nature mandates retrospectivity, potentially reviving abandoned proceedings. This raises broader issues of statutory interpretation, the effect of repeal without explicit savings for pending matters, and the balance between procedural efficiency and vested rights in ongoing litigations.

Discussion on Judgments: The parties and the court extensively referenced prior judicial precedents to argue their positions on retrospectivity and procedural rules. SAP SE relied on Garikapati Veeraya v. N. Subbiah Choudhry, AIR 1957 SC 540, to contend that procedural changes apply retrospectively unless they impair vested rights, asserting that the 2017 Rules relaxed timelines and should govern post-enforcement decisions. The first respondent in SAP SE's reference cited New India Assurance Co. Ltd. v. Shanti Misra, (1975) 2 SCC 840, in the context of procedural amendments not affecting accrued rights, arguing that the Registrar's discretion under the old rules was limited. Mahesh Gupta invoked Hitendra Vishnu Thakur v. State of Maharashtra, (1994) 4 SCC 602, to emphasize that procedural rules are retrospective only if they do not prejudice parties, highlighting the saving clause in Rule 158 as preserving 2002 proceedings. The second respondent in Mahesh Gupta's appeal referred to Commissioner of Income Tax v. Shah Sadiq & Sons, (1987) 3 SCC 516, to argue that repeal erases prior rules unless saved, but contended that "anything done" includes incomplete actions like evidence filing, thus applying old rules. The court discussed Wyeth Holdings Corporation v. Registrar of Trade Marks, 2009 (40) PTC 519 (Del), where a Division Bench interpreted Rule 50 of the 2002 Rules as not mandating abandonment if extensions were sought bona fide, but the present Bench distinguished it as contrary to statutory language. Additionally, the court analyzed Jose Paulo Coutinho v. Maria Luiza Valentina Pereira, (2019) 20 SCC 85, in the context of procedural retrospectivity not applying to substantive rights, reinforcing that deemed abandonment under 2002 Rules attains finality. The Single Judge's opinion in SAP SE v. Swiss Auto Products & Anr., 2023 SCC Online Del 1324, was critiqued for overlooking the saving clause's broad scope, while Mahesh Gupta v. Registrar of Trademarks & Anr., 2023:DHC:1623, was upheld as correctly applying the 2002 Rules to pre-2017 filings.

Reasoning and Analysis of the Judge: The Division Bench meticulously dissected the trademark statutory framework, beginning with the evolution from the 1959 Rules to the 2002 and 2017 regimes. Justice Yashwant Varma, authoring the judgment, analyzed Rule 158 of the 2017 Rules, which repeals the 2002 Rules "without prejudice to anything done under such rules," interpreting "anything done" expansively to include all steps in ongoing proceedings, such as filing oppositions and evidence, thereby shielding them from new rules. The Bench reasoned that procedural changes, while generally retrospective, do not apply if they disrupt vested positions or finalities achieved under prior laws, drawing a distinction from pure procedural amendments like court fees. Examining the phrase "not exceeding one month" in Rules 50 and 51 of the 2002 Rules, the court held it imposes an inflexible cap, implying deemed abandonment for non-compliance, akin to the explicit provision in the 2017 Rules. The analysis rejected the SAP SE Single Judge's view that the 2017 Rules reverted to the flexible 1959 regime, noting that the 2002 Rules introduced rigidity to expedite resolutions, and repeal does not revive abandoned rights unless expressly provided. The Bench critiqued the notion that post-2017 decisions must apply new rules, emphasizing that the right to file evidence lapses irrevocably under the old timelines, unaffected by later enactments. Balancing efficiency in trademark adjudication with fairness, the court concluded that applying 2017 Rules retrospectively would undermine the legislative intent of the 2002 Rules and lead to chaos in pending matters.

Final Decision: The Division Bench answered the reference questions in the negative, holding that procedural rules under the 2017 Rules do not apply retrospectively to proceedings initiated under the 2002 Rules. Failure to file evidence under the 2002 Rules constitutes "anything done" saved by Rule 158, continuing to be governed by the old rules. Consequently, in SAP SE's appeal, the Registrar's rejection of evidence was upheld under the 2002 Rules, and the appeal was dismissed. In Mahesh Gupta's LPA, the Single Judge's order deeming opposition abandoned was affirmed, though corrected to apply the 2002 Rules instead of 2017, and the appeal was dismissed.

Law Settled in This Case: This judgment settles that the Trade Marks Rules, 2017 do not retrospectively govern procedural aspects like evidence filing timelines in oppositions initiated under the 2002 Rules, due to the saving clause in Rule 158 preserving prior actions. It clarifies that the phrase "not exceeding one month" in the 2002 Rules mandates strict compliance, leading to deemed abandonment, which attains irrevocability and cannot be revived by subsequent rules. The decision reinforces that procedural amendments apply retrospectively only if they do not impair finalities or vested positions under repealed laws, providing clarity for trademark registries in handling legacy proceedings.

Case Title: Mahesh Gupta vs Registrar Of Trademarks & Anr.

Date of Order: 13 March, 2024

Case Number: LPA 429/2023

Neutral Citation: 2024:DHC:2053-DB

Name of Court: High Court of Delhi

Name of Hon'ble Judge: Yashwant Varma and Dharmesh Sharma

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Infosys Limited vs Southern Infosys Limited

Trademark Remedies and Corporate Law Conflicts

Introduction: The case of Infosys Limited versus Southern Infosys Limited represents a significant development in the intersection of trademark law and corporate governance under the Companies Act, 2013. It addresses the obligations of a company compelled by a court to change its name due to trademark infringement and whether such a company must continue to display its former name in compliance with statutory provisions. The dispute arose from the plaintiff's contention that the defendant, despite changing its name following an injunction, improperly relied on Section 12 of the Companies Act to retain references to its previous name, potentially perpetuating confusion in the market. This order, issued by the Delhi High Court, clarifies the limits of statutory requirements in the context of judicially mandated name changes, emphasizing the primacy of preventing deceptive similarity over routine corporate disclosure norms. By drawing on precedents, the court reinforces the distinct treatment of involuntary name changes driven by infringement remedies, highlighting the balance between public disclosure and the protection of intellectual property rights.

Factual Background: Infosys Limited, a well-established information technology company, initiated legal action against Southern Infosys Limited, alleging that the defendant's corporate name infringed upon its registered trademark "Infosys" by creating deceptive similarity and confusion among consumers. The plaintiff argued that the use of "Infosys" in the defendant's name amounted to passing off and trademark violation, leading to a suit for injunction and damages. On May 27, 2024, the Delhi High Court granted a permanent injunction, restraining the defendant from using the name "Southern Infosys Limited" and directing it to change its corporate name. This judgment was subsequently upheld by a Division Bench of the same court. In response, the defendant changed its name but filed a compliance affidavit on July 5, 2025, stating that it would continue to reflect its previous name in certain communications, invoking Section 12 of the Companies Act, 2013, which requires companies undergoing name changes to display both old and new names for a specified period. The plaintiff, dissatisfied with this approach, contended that such display defeated the purpose of the injunction by allowing ongoing association with the infringing name.

Procedural Background: The suit was filed before the Delhi High Court as CS(COMM) 257/2024, accompanied by an interim application I.A. 6053/2025. The initial judgment on May 27, 2024, decreed in favor of the plaintiff, imposing a permanent injunction and mandating the name change. Following the defendant's compliance affidavit of July 5, 2025, the plaintiff raised objections during a hearing on August 1, 2025. The court heard arguments from both sides, with the plaintiff referencing a prior coordinate bench order to support its position. The defendant, appearing through video conference, initially defended its stance but conceded upon review of the cited precedent. The court issued directions for further compliance and scheduled subsequent listings before the Joint Registrar on September 10, 2025, and before the court on December 11, 2025, to monitor adherence and potentially dispose of the suit.

Core Dispute: The central issue revolved around the applicability of Section 12(3) of the Companies Act, 2013, which mandates that a company changing its name must, for two years, mention its former name alongside the new one in all business letters, billheads, and other official publications. The plaintiff argued that this provision should not apply when the name change is court-ordered due to trademark infringement, as it would undermine the injunction by permitting continued reference to the prohibited name, thereby risking ongoing confusion and deception. The defendant countered that statutory compliance under Section 12 necessitated displaying the old name, viewing the change as akin to a voluntary rectification. This raised broader questions about the interplay between corporate law obligations and judicial remedies in intellectual property disputes, specifically whether court-directed changes fall under the same disclosure regime as voluntary or administratively mandated alterations.

Discussion on Judgments: The plaintiff relied heavily on the order dated February 23, 2024, in Sanofi & Anr. v. Zanofi Pharmaceutical Pvt. Ltd., CS (COMM) 881/2023, where a coordinate bench of the Delhi High Court addressed an identical issue in a trademark infringement suit. In that case, the court examined Sections 12 and 16 of the Companies Act, 2013, and held that when a name change is directed by a court to rectify infringement, the proviso to Section 12(3) requiring display of the former name does not apply, as it would contradict the goal of eliminating deceptive similarity. The Sanofi order emphasized that Section 16 empowers the Central Government or courts to mandate changes in cases of resemblance to existing trademarks, without the accompanying disclosure obligation intended for voluntary changes. Within this context, the Sanofi judgment cited M/s Montari Overseas Ltd. v. Montari Industries Ltd., 1995 SSC OnLine Del 864, a Division Bench decision of the Delhi High Court, which dealt with analogous provisions under Sections 20 and 22 of the Companies Act, 1956. In Montari, the court clarified that common law remedies for passing off operate independently of statutory rectification mechanisms, allowing courts to grant injunctions against undesirable names without being limited by corporate law provisions, and affirmed that judicial directions for name changes do not trigger the same disclosure requirements as administrative processes. Additionally, the Sanofi order referenced K.G. Khosla Compressors Ltd. v. Khosla Extraktions Ltd., AIR 1986 Delhi 184, where the Delhi High Court held that civil courts retain jurisdiction to issue injunctions restraining the use of confusingly similar corporate names, even in the presence of statutory avenues under the Companies Act, as the remedies under common law and statute function in distinct fields—the former enabling broad injunctive relief to prevent confusion, while the latter focuses on administrative rectification.

Reasoning and Analysis of the Judge: The judge, Hon'ble Ms. Justice Manmeet Pritam Singh Arora, meticulously analyzed the plaintiff's grievance by aligning it with the principles established in the Sanofi order, which she found directly applicable due to the identical factual matrix involving a court-mandated name change for trademark infringement. She noted that Section 16 of the Companies Act, 2013, provides for rectification of a company's name when it resembles a registered trademark, granting the Central Government or courts the authority to direct changes without the proviso in Section 12(3) mandating display of the former name, as such display would perpetuate the very confusion the injunction seeks to eliminate. Drawing from the Sanofi reasoning, the judge underscored that voluntary name changes under Section 12 aim to ensure public disclosure and continuity, whereas judicial interventions under infringement suits prioritize rectification of illegal use, rendering the disclosure proviso inapplicable and out of context. She further endorsed the precedents cited in Sanofi, observing that the Montari decision illustrates the independence of common law actions from statutory frameworks, allowing courts to impose name changes without ancillary obligations that could hinder the remedy's effectiveness. Similarly, the Khosla case reinforced her view that civil courts' jurisdiction in passing off actions extends beyond corporate law limits, enabling tailored relief to prevent deception. In applying this to the present facts, the judge rejected the defendant's reliance on Section 12, concluding that permitting display of the injuncted name would defeat the purpose of the May 27, 2024, judgment, which had been upheld on appeal, and emphasized the need for complete disassociation to protect the plaintiff's trademark rights.

Final Decision: The court directed the defendant to display only its new name across all goods, services, promotional material, physical or online media, and in all other respects, explicitly prohibiting any reference to its previous name.

Law Settled in This Case: This case establishes that when a court directs a company to change its name as a remedy for trademark infringement or passing off, the proviso to Section 12(3) of the Companies Act, 2013, requiring the display of the former name for two years, does not apply. Instead, the company must fully cease referencing the old name to align with the injunction's objective of eliminating confusion and deception. It affirms the distinction between voluntary or administrative name changes, which trigger disclosure obligations for public transparency, and judicially mandated changes, which operate in a separate field prioritizing intellectual property protection over routine corporate formalities. By endorsing the principles from coordinate and prior benches, the decision clarifies that common law remedies under trademark law supersede conflicting statutory provisions in infringement contexts, ensuring that courts can grant effective relief without unintended perpetuation of the infringing conduct.

Case Title: Infosys Limited Vs Southern Infosys Limited

Date of Order: 1 August, 2025

Case Number: CS(COMM) 257/2024

Name of Court: High Court of Delhi at New Delhi

Name of Judge: Hon'ble Ms. Justice Manmeet Pritam Singh Arora

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Kylin Sanitary Technology (XIAMEN) Company Limited vs. Union of India & Ors

Strict Adherence to Patent Timelines

Introduction: This case study examines a significant judgment from the High Court at Calcutta concerning the abandonment of a patent application due to non-compliance with statutory timelines under the Patents Act, 1970. The petitioner, a foreign entity, challenged the rejection of its patent application as abandoned, invoking the writ jurisdiction under Article 226 of the Constitution of India. The court delved into the mandatory nature of procedural deadlines in patent prosecution, the impact of external factors like the COVID-19 pandemic, and the limits of judicial discretion in such matters. This analysis highlights the tension between equitable considerations and strict adherence to legislative intent in intellectual property law, underscoring the importance of diligence in pursuing patent rights.

Factual Background: The petitioner, Kylin Sanitary Technology (XIAMEN) Company Limited, a company incorporated under the laws of China, filed a patent application in India bearing number 202034009705 on March 6, 2020. As a foreign entity, it engaged the services of an Indian patent attorney to handle the proceedings. A request for examination was submitted on April 18, 2020. The First Examination Report was issued by the patent office on August 16, 2021, outlining objections that needed to be addressed. The statutory period of six months for responding to these objections and putting the application in order for grant expired on February 16, 2022. An additional three-month extension period, as provided under the rules, also lapsed without any action from the petitioner. It was only on December 1, 2022, that the petitioner communicated with its Indian patent agent through an international attorney, attributing prior delays to the COVID-19 pandemic and alleged negligence by the Indian agent. On December 29, 2022, the application was deemed abandoned. The petitioner first raised a grievance with the Controller on May 23, 2023, via a representation, which led to further proceedings culminating in the impugned order of June 24, 2024, rejecting the application as abandoned.

Procedural Background: The patent application process began with the filing on March 6, 2020, followed by a request for examination on April 18, 2020. After the issuance of the First Examination Report on August 16, 2021, no response was filed within the prescribed six-month period or the subsequent three-month extension. The application was treated as abandoned on December 29, 2022. The petitioner submitted a representation to the Controller on May 23, 2023, seeking revival. This prompted a prior writ petition before the High Court, which directed the respondents to consider the representation. Pursuant to this direction, the Deputy Controller of Patents and Designs passed the impugned order on June 24, 2024, upholding the abandonment under section 21(1) of the Patents Act, 1970, read with Rule 24B of the Patents Rules, 2003. Lacking an appellate remedy against such an order, the petitioner filed the present writ petition under Article 226, arguing that the abandonment was unjustified due to external circumstances and agent negligence.

Core Dispute: The central issue revolved around whether the patent application could be deemed abandoned for failure to comply with the mandatory timelines under section 21(1) of the Patents Act, 1970, and Rule 24B of the Patents Rules, 2003, despite the petitioner's claims of no intentional delay, the impact of the COVID-19 pandemic, and negligence attributable to its Indian patent agent. The petitioner contended that the abandonment was erroneous, as any delay was unintentional and excusable, emphasizing the absence of mala fide intent and relying on equitable principles. In contrast, the respondents asserted that the timelines were mandatory and non-negotiable, with no provision for relaxation beyond the stipulated extensions, and that the petitioner's inaction constituted deliberate neglect, rendering the application unsustainable.

Discussion on Judgments: The petitioner relied on European Union Vs. Union of India reported in 2022 SCC OnLine Del 1793, where a Coordinate Bench of the Delhi High Court held that abandonment could not be inferred if there was no intention to abandon, particularly when the applicant had taken active steps to pursue the application, and any mistake was excusable under the facts of that case. This citation was used to argue that the petitioner's delays, stemming from the pandemic and agent negligence, did not reflect deliberate inaction and should warrant setting aside the abandonment order. On the other hand, the respondents cited Nippon Steel Corporation Vs. Union of India (2011) SCC OnLine Del 669, in which the Delhi High Court emphasized the mandatory nature of time limits under the Patents Act and Rules, stating that such limits could not be relaxed by courts under Article 226, as they reflect legislative intent for time-bound patent prosecution; this was invoked to support the sustainability of the impugned order due to the petitioner's violation of fixed timelines. Additionally, the respondents referred to Carlos Alberto Perez Lafuente Vs. Union of India reported in (2019) SCC OnLine Del 7404, where similar views were expressed, reinforcing that failure to comply with stipulated periods results in mandatory abandonment, without room for procedural leniency; this judgment was used to highlight the inordinate and unexplained delay in the present case, justifying the treatment of the application as abandoned.

Reasoning and Analysis of the Judge: The judge began by outlining the relevant provisions, including sections 11B and 21 of the Patents Act, 1970, and Rules 24B(5) and (6) of the Patents Rules, 2003, which establish a structured, time-bound mechanism for patent prosecution, deeming applications abandoned upon non-compliance. Emphasizing that these timelines are mandatory rather than directory, the judge noted that courts cannot read in relaxations absent express legislative provisions, as this would undermine the Act's objective of efficient processing. The judge distinguished the petitioner's cited case by pointing out that in European Union Vs. Union of India, active pursuit and excusable error were evident, unlike here where the petitioner exhibited indolence, with no timely response or extension request filed. Aligning with the respondents' precedents, the judge affirmed that fixed timelines must be strictly adhered to, and the writ court's discretionary power under Article 226 cannot circumvent statutory rigors. The excuse of COVID-19 was dismissed as insufficient, given the extended periods already accounting for such disruptions, and the first communication occurring well after deadlines. The judge invoked the doctrine of laches, stating that equity aids the vigilant, not the indolent, and found no basis for discretion in the petitioner's favor due to lackadaisical conduct.

Final Decision:The writ petition was dismissed without any order as to costs, upholding the impugned order deeming the patent application abandoned.

Law Settled in This Case:This judgment reinforces that timelines under section 21(1) of the Patents Act, 1970, and Rule 24B of the Patents Rules, 2003, for responding to examination reports and putting applications in order for grant are mandatory and non-relaxable by courts, even under writ jurisdiction, absent exceptional circumstances demonstrating active pursuit without intentional delay. It clarifies that external factors like the COVID-19 pandemic or agent negligence do not automatically excuse non-compliance if not addressed within stipulated periods, emphasizing diligence and the doctrine of laches in patent prosecution.

Case Title: Kylin Sanitary Technology (XIAMEN) Company Limited Vs. Union of India & Ors.,

Date of Order: August 11, 2025,

Case Number: WPA-IPD No.1 of 2024

Neutral Citation: Not available,

Name of Court: High Court at Calcutta,

Name of Judge: Ravi Krishan Kapur, J.

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Pernod Ricard India Private Limited Vs Karanveer Singh Chhabra

Publici Juris and Laudatory Terms: Non-Monopolizability in Trademark Law

Introduction: This case delves into the intricate principles of trademark law, particularly focusing on deceptive similarity, the anti-dissection rule, and the dominant feature test in the context of composite marks. The appellants, Pernod Ricard India Private Limited and Pernod Ricard USA LLC, alleged that the respondent's use of the mark "London Pride" for whisky infringed their registered trademarks "Blenders Pride" and "Imperial Blue" and amounted to passing off. The Supreme Court examined whether the marks created a likelihood of confusion among consumers, emphasizing the need for holistic comparison and the perspective of an average consumer with imperfect recollection. Ultimately, the Court held that no deceptive similarity existed, reinforcing that common or laudatory terms like "Pride" cannot be monopolized without acquired distinctiveness.

Factual Background:The appellants are engaged in the manufacture and distribution of wines, liquors, and spirits, selling whisky under the brands "Blenders Pride" and "Imperial Blue", both registered trademarks. They also hold registration for "Seagram's", their house mark used internationally. The trademark "Blenders Pride" was adopted in 1973 and launched in India in 1995, achieving annual turnover exceeding INR 1,700 crores. "Imperial Blue" was launched in 1997, with turnover exceeding INR 2,700 crores. In May 2019, the appellants discovered the respondent marketing whisky under "London Pride" with packaging deceptively similar to theirs, using Seagram's embossed bottles. The respondent, Karanveer Singh Chhabra trading as JK Enterprises, is a proprietary concern manufacturing and selling liquor under "London Pride" in Madhya Pradesh, with a pending trademark application.

Procedural Background: The appellants filed Commercial Suit No. 3/2020 before the Commercial Court, Indore, seeking permanent injunction against trademark infringement, passing off, and other reliefs, along with an interim application under Order XXXIX Rules 1 & 2 CPC. The Commercial Court rejected the interim application on November 26, 2020, finding no deceptive similarity. The appellants appealed to the Madhya Pradesh High Court, which dismissed the appeal on November 3, 2023, upholding the Commercial Court's order. Aggrieved, the appellants filed SLP (C) No. 28489/2023 before the Supreme Court.

Core Dispute:The core issue was whether the respondent's mark "London Pride" and its packaging were deceptively similar to the appellants' registered trademarks "Blenders Pride", "Imperial Blue", and "Seagram's", amounting to infringement under Sections 28 and 29 of the Trade Marks Act, 1999, or passing off. The appellants argued phonetic, visual, and structural similarity, dishonest adoption, and likelihood of confusion. The respondent contended the marks were distinct, "Pride" was generic and publici juris, and no confusion was likely among discerning consumers of premium whisky.

Discussion on Judgments: The appellants relied on several precedents to argue deceptive similarity and the need for holistic comparison. In Ruston & Hornsby Ltd v. Zamindara Engineering Co (1969 (2) SCC 727), cited to emphasize phonetic and visual deceptive similarity where essential features are copied. James Chadwick & Bros Ltd v. National Sewing Thread Co Ltd (OCJ Appeal No. 95 of 1950), referred for principles on confusion from similar marks on related goods. Sky Enterprise Pvt Ltd v. Abaad Masala & Co (2020 SCC OnLine Bom 750), used against generic defenses for distinctive marks. Neon Laboratories Ltd v. Medical Technologies Ltd (2016 (2) SCC 672), invoked for the first-user rule and presumption of confusion. Ultra Tech Cement Ltd v. Alaknanda Cement Pvt Ltd (2011 SCC OnLine Bom 783), cited to argue suffixes do not negate infringement if core is similar. Jagdish Gopal Kamath v. Lime & Chilli Hospitality Services (2015 SCC OnLine Bom 531), referred to counter common-to-trade claims without proof of extensive use. Lupin Ltd v. Eris Lifesciences Pvt Ltd (2015 SCC OnLine Bom 6807), emphasized limiting validity challenges unless ex facie fraudulent. The respondent countered with judgments on composite marks and generic terms. Phonepe Pvt Ltd v. EZY Services (2021 SCC OnLine Del 2635) and Delhivery Pvt Ltd v. Treasure Vase Ventures Pvt Ltd (2020 SCC OnLine Del 2766), cited against dissection and for whole-mark comparison. Paramjeet Singh Nande v. Paramount Toys & Ors (Order in OOCJ Interim Application (L) No. 35055 of 2023 dated June 10, 2025), supported non-solicitation limits. Gufic Ltd v. Clinique Laboratories LLC (FAO (OS) 222/2009 dated July 9, 2010, Delhi High Court), stressed holistic comparison. Ayushakti Ayurved Pvt Ltd v. Hindustan Lever Ltd (2003 (5) Bom CR 523), argued inseparable parts must be pronounced together. Marico Ltd v. Agro Tech Foods Ltd (2010 SCC OnLine Del 3806), defended non-monopolizable generic words. Honda Motor Co Ltd v. Kewal Brothers (1999 SCC OnLine Cal 536), set the relevant date for passing off as defendant's adoption. Sun Pharmaceuticals Industries Ltd v. Emcure Pharmaceuticals Ltd (2012 (2) MhLJ 936) and G.M. Sheik v. Raja Biri Pvt Ltd (FAO No. 94 of 2022 dated August 31, 2022, Kerala High Court), reinforced whole-mark consideration and extensive use for common-to-trade defenses. The Supreme Court discussed these and other precedents like Coca-Cola Co of Canada Ltd v. Pepsi-Cola Co of Canada Ltd (1942 SCC OnLine PC 7), Corn Products Refining Co v. Shangrila Food Products Ltd (AIR 1960 SC 142), Amritdhara Pharmacy v. Satya Deo Gupta (AIR 1963 SC 449), Kaviraj Pandit Durga Dutt Sharma v. Navaratna Pharmaceutical Laboratories (AIR 1965 SC 980), Parle Products Pvt Ltd v. JP & Co (1972 (1) SCC 618), Cadila Health Care Ltd v. Cadila Pharmaceuticals Ltd (AIR 2001 SC 1952), Khoday Distilleries Ltd v. Scotch Whisky Association (2008 (10) SCC 723), Wander Ltd v. Antox India Pvt Ltd (1990 Supp SCC 727), Anand Prasad Agarwalla v. Tarkeshwar Prasad (2001 (5) SCC 568), and Bajaj Auto Ltd v. TVS Motor Co Ltd (2009 (9) SCC 797), in the context of deceptive similarity, anti-dissection, dominant features, generic terms, imperfect recollection, and injunction principles.

Reasoning and Analysis of the Judge: Justice R Mahadevan, writing for the Bench, analyzed the case through statutory provisions and judicial precedents, emphasizing holistic comparison of marks from an average consumer's perspective with imperfect recollection. The Court rejected dissection, finding no deceptive similarity in names, colours, or trade dress. "Pride" was held publici juris, laudatory, and non-monopolizable without secondary meaning. Dominant features like "Blenders" and "London" distinguished the marks. Post-sale confusion doctrine was noted but deemed inapplicable to private consumption goods. Appellate interference was limited absent jurisdictional error. The Court found no prima facie case, irreparable harm, or balance favoring injunction, upholding lower courts' concurrent findings.

Final Decision: The Supreme Court dismissed the appeal, upholding the High Court's judgment denying interim injunction. The Commercial Court was directed to dispose of the suit within four months, uninfluenced by interlocutory observations.

Law Settled in This Case: This case reaffirms that deceptive similarity requires holistic comparison of marks as wholes, from an average consumer's imperfect recollection perspective. Generic or laudatory terms like "Pride" are publici juris and non-monopolizable without acquired secondary meaning. Dominant features aid analysis but do not override overall impression. Post-sale confusion is inapplicable to privately consumed goods. Appellate review of interim orders is limited absent jurisdictional error. Infringement and passing off necessitate likelihood of confusion; mere common elements are insufficient.

Case Title: Pernod Ricard India Private Limited & Another Vs Karanveer Singh Chhabra,
Date of Order: August 14, 2025,
Case Number: Civil Appeal No. 10638 of 2025,
Neutral Citation: 2025 INSC 981,
Name of Court: Supreme Court of India,
Name of Hon'ble Judge: J.B. Pardiwala and R. Mahadevan, J.

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

Arochem Ratlam Pvt. Ltd. & Anr. Vs Arom Alchemists Private Limited

Essential Features and Composite Marks

Introduction :This case involves a dispute over trademark infringement and passing off in the perfumery industry, where the plaintiffs, Arochem Ratlam Pvt Ltd and another, sought to protect their trademarks "AROCHEM" and "AROME" against the defendants, Arom Alchemists Private Limited and others. The plaintiffs claimed that the defendants' use of "AROM ALCHEMISTS" was deceptively similar to their marks, leading to confusion among consumers. The court examined the phonetic and visual similarities, the honesty of adoption, and the goodwill associated with the marks, ultimately granting partial interim relief to the plaintiffs while denying others.

Factual Background: The plaintiffs and defendants are both engaged in manufacturing, marketing, selling, and distributing perfumery products, including perfumes and fragrances. The first plaintiff originated as a partnership firm called Arochem Industries in 1969, using the mark "AROCHEM" since September 1, 1969. This mark was registered in Class 3 in 1996 and assigned to the first plaintiff in 2013. The plaintiffs hold about 93 registrations for "AROCHEM" and its variants. In March 2021, the plaintiffs began using "AROME" while retaining "AROCHEM" as a key feature, and registered "AROME" on March 8, 2021, along with variants like "AROME BLUE ISLAND," "AROME WORLD," "AROME SCENT ART," and "AROME THE LEGEND." To demonstrate goodwill, the plaintiffs provided combined sales figures certified by a chartered accountant, showing Rs. 872,30,499 in sales for 2022-23, with advertisement expenses of Rs. 16,11,644 and promotional expenses of Rs. 3,09,226. The defendants incorporated on January 3, 2023, and adopted "AROM ALCHEMISTS," claiming it as a misspelling of "AROMA" combined with "ALCHEMISTS," meaning a person studying alchemy. The second defendant was an ex-employee of the second plaintiff from November 2017 to May 2018. The defendants applied for registration of "AROM" on May 12, 2023, on a proposed-to-be-used basis, but faced objections under Section 11 citing the plaintiffs' marks. The plaintiffs issued a cease-and-desist notice on December 18, 2023, to which the defendants responded by denying infringement and filing a rectification application against "AROME" on December 23, 2023. The plaintiffs alleged the defendants advertised in the same magazines, participated in the same exhibitions, induced their employees, and caused confusion among customers who mistook the defendants' products for theirs.

Procedural Background> The plaintiffs filed a commercial IP suit for trademark infringement and passing off in the Bombay High Court, along with an interim application seeking temporary injunctions. The suit was lodged as Commercial IP Suit (Lodging) No. 32272 of 2024, and the interim application as Interim Application (Lodging) No. 32451 of 2024.

Core Dispute: The central issue revolved around whether the defendants' mark "AROM ALCHEMISTS" infringed the plaintiffs' registered trademarks "AROCHEM" and "AROME" under Sections 28 and 29 of the Trade Marks Act, 1999, and amounted to passing off. The plaintiffs argued phonetic and deceptive similarity, especially with "AROME," claiming the defendants highlighted "AROM" while downplaying "ALCHEMISTS," leading to confusion. They emphasized prior use, registrations, and dishonest adoption by an ex-employee. The defendants contended that "AROM" was a generic misspelling of "AROMA," used as part of a composite mark, and denied standalone use of "AROM." They challenged the plaintiffs' goodwill for passing off, argued no monopoly over descriptive words, and claimed honest adoption. Additional disputes included the domain name "aromapl.com" and inducement of employees.

Discussion on Judgments: The plaintiffs relied on several judgments to support their claims of infringement and deceptive similarity. In Ruston & Hornsby Ltd vs. The Zamindara Engineering Co (1969 (2) SCC 727), cited to emphasize that deceptive similarity should be assessed phonetically and visually, and that infringement occurs if the essential features are copied. James Chadwick & Bros., Ltd Vs. The National Sewing Thread Co., Ltd. (OCJ App No. 95 of 1950) was referred to for principles on likelihood of confusion from similar marks in related goods. Sky Enterprise Private Ltd vs. Abaad Masala & Co. (2020 SCC Online BOM 750) was used to argue against the use of generic defenses when marks are distinctive. Neon Laboratories Limited vs. Medical Technologies Limited ((2016) 2 SCC 672) supported the first-user rule and presumption of confusion for identical goods. Ultra Tech Cement Limited vs. Alaknanda Cement Pvt Ltd (2011 SCC Online Bom 783) was invoked to highlight that suffixes do not negate infringement if core marks are similar. Jagdish Gopal Kamath vs. Lime & Chilli Hospitality services (2015 SCC Online Bom 531) was cited to counter claims of marks being common to trade, requiring proof of extensive use. Lupin Limited vs. Eris Lifesciences Pvt. Ltd (2015 SCC Online Bom 6807) was emphasized to limit challenges to registration validity unless ex-facie fraudulent. The defendants countered with judgments focusing on composite marks and generic terms. Phonepe Private Limited vs. EZY Services (2021 SCC Online Del 2635) and Delhivery Private Limited vs. Treasure Vase Ventures Pvt. Ltd. (2020 SCC Online Del 2766) were cited to argue against dissecting marks and for considering them as wholes. Paramjeet Singh Nande vs. Paramount Toys & Ors. (Order in OOJC Interim Application (L) No. 35055 of 2023 dated 10th June, 2025) supported non-solicitation limits. M/s Gufic Ltd vs. Clinique Laboratories, LLC (Order of Delhi High Court in FAO (OS) 222/2009 dated 9th July, 2010) was used to stress holistic comparison without dissection. Ayushakti Ayurved Pvt Ltd vs. Hindustan Lever Limited (2003 (5) Bom. C. R. 523) argued that inseparable parts of marks must be pronounced together. Marico Limited vs. Agro Tech Foods Limited (2010 SCC Online Del 3806) defended generic words as non-monopolizable. Honda Motor Company Limited vs. Kewal Brothers (1999 SCC Online Cal 536) set the relevant date for passing off as the defendant's adoption. Sun Pharmaceuticals Industries Ltd vs. Emcure Pharmaceuticals Ltd. (2012(2) Mh.L.J) and G. M. Sheik vs. M/s. Raja Biri Private Ltd (Order of Kerala High Court in FAO No. 94 of 2022 dated 31st August, 2022) reinforced considering marks wholly and proving extensive use for common-to-trade defenses.

Reasoning and Analysis of the Judge: Justice Sharmila U. Deshmukh analyzed the case by first confirming the plaintiffs' registrations and prior use, noting "AROCHEM" since 1969 and "AROME" since 2021. She compared the marks, finding phonetic similarity between "AROME" and "AROM," with the latter subsuming the former despite the addition of "ALCHEMISTS." The judge rejected the defendants' claim that "AROM" was a generic misspelling of "AROMA," as "AROME" differed phonetically and was not a dictionary word. She emphasized that marks must be compared as wholes but focused on essential features, citing precedents like Ruston & Hornsby for deceptive resemblance. The examination report citing conflicts and the defendants' ex-employee status indicated dishonest adoption, dismissing honest use claims. For infringement, she applied Section 29, presuming confusion due to identical goods and similarity. However, for passing off, she found insufficient evidence of goodwill, as sales figures were combined and invoices limited, failing to show public association by 2023. The judge vacated the employee inducement injunction, as it fell outside Section 135 reliefs. Acquiescence was rejected, as mere delay without encouragement does not bar relief.

Final Decision :The court allowed the interim application , granting an injunction restraining the defendants from using "AROM" or similar marks infringing "AROME," but excluding references to "AROCHEM" and the domain name portion.

Law Settled in This Case: This case reaffirms that trademark infringement under Section 29 requires deceptive similarity in essential features, assessed phonetically and visually, with presumption of confusion for identical goods. It clarifies that additions like suffixes do not negate infringement if the core mark is copied, and generic defenses fail if marks are distinctive. For passing off, prior continuous use and substantial goodwill must be proven as of the defendant's adoption date, with combined sales figures insufficient. Challenges to registration validity are limited unless ex-facie fraudulent. Reliefs in infringement suits are confined to Section 135, excluding non-IP issues like employee inducement. Acquiescence demands positive encouragement, not mere delay.

Case Title: Arochem Ratlam Pvt. Ltd. & Anr. Vs Arom Alchemists Private Limited & Ors.,

Date of Order: August 12, 2025,

Case Number: Commercial IP Suit (Lodging) No. 32272 of 2024,

Neutral Citation: 2025:BHC-OS:13265,

Name of Court: High Court of Bombay

Name of Hon'ble Judge: Sharmila U. Deshmukh, J.

Written By: Advocate Ajay Amitabh Suman, IP Adjutor [Patent and Trademark Attorney], High Court of Delhi

IP.ADJUTOR

Friday, August 15, 2025

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