META PLATFORMS, INC. v. NOUFEL MALOL & ANR

Delhi High Court · 06 Jul 2022 · 2022:DHC:2524
Navin Chawla
CS(COMM.) 499/2020
2022:DHC:2524
civil appeal_allowed Significant

AI Summary

The Delhi High Court granted permanent injunction against defendants using the deceptively similar 'Facebake' mark, recognizing the plaintiff's 'Facebook' marks as well-known trademarks and awarding nominal damages for infringement.

Full Text
Translation output
CS(COMM.) 499/2020
HIGH COURT OF DELHI
Date of Decision: 06.07.2022
CS(COMM) 499/2020 & IA 8765/2021
META PLATFORMS, INC. ..... Plaintiff
Through: Mr.Pravin Anand, Ms.Vaishali Mittal, Mr.Siddhant Chamola, Mr.Shivang Sharma, Advs.
(Mobile-9999052646)
VERSUS
NOUFEL MALOL & ANR ..... Defendants
Through: None
CORAM:
HON'BLE MR. JUSTICE NAVIN CHAWLA NAVIN CHAWLA, J. (Oral)
JUDGMENT

1. This suit has been filed by the plaintiff praying inter-alia for a decree of permanent injunction restraining the defendants from using the mark „Facebake‟ and/or the domain name www.facebake.in; the email IDs facebake.mail@gmail.com; facebake649@gmail.com, as also for seeking rendition of accounts.

2. This Court, vide order dated 12.11.2020 was pleased to pass the following ad-interim order:

“6. In the meanwhile, the defendant, his agents and employees are restrained from using the mark "FACEBAKE" or any other mark, which is deceptively similar to the plaintiff’s trademark.
2022:DHC:2524 6.[1] The injunction will also operate vis-avis the logo(s) represented by the letter 'f’ i.e. 6.[2] Furthermore, the defendant is also restrained from operating his website i.e. www.facebake.in.”

3. As none appeared for the defendant no.1, (who was the sole defendant till that date), this Court confirmed the ad-interim order dated 12.11.2020, vide the order of this Court dated 21.01.2021, and further passed the following directions:

“3. The interim order dated 12th November, 2020 is confirmed. The Registrar of the domain name www.facebake.in namely Crazy Domains FZ-LLC is directed to suspend the domain and transfer the domain name owned and registered by the Defendant comprising of the marks/designation FACEBAKE, FACEBOOK or any other mark/designation similar thereto to the plaintiff within four weeks.”

4. The plaintiff thereafter filed an application under Order XXXIX Rule 2A of the Code of Civil Procedure, 1908 (in short, the „CPC‟), being IA No.8765 of 2021, alleging therein that despite the above orders being passed by this Court, the defendant no.1 incorporated a company by the name of „Ehrlich Foods and Beverages Pvt. Ltd’ on 27.01.2021, and is one of its directors. The said company has preferred a trade mark application bearing no. 4926784 under Class 30, seeking the registration of a deceptively-similar mark dated 30.03.2021.

5. The plaintiff also filed another application, being IA No. 10045 of 2021, under Order I Rule 10 of the CPC praying to implead the said company as defendant no.2 in the suit.

6. The said company was then impleaded as the defendant no.2 in the suit vide the order of the learned Joint Registrar (Judicial) dated 11.08.2021.

7. None appeared for the defendant no.2 in spite of service, thus, even the defendant no.2 was proceeded ex-parte vide an order of this Court dated 10.11.2021.

8. It is the case of the plaintiff that the plaintiff-company has been incorporated in the United States of America and adopted Facebook, which is a world-famous, social networking service. It also launched a mobile application and website under the mark „Facebook‟ in 2004. Some key products/features of the plaintiff under the mark „Facebook‟ include, for example, Facebook Profile, Facebook News Feed, Facebook Messenger, Facebook Groups, Facebook Events, Facebook Video, Facebook Photos, Facebook Pages, Facebook Shops (launched in May, 2020) and Facebook Marketplace (launched in October, 2016).

9. The plaintiff has given details of registrations obtained by it in its marks (hereinafter referred to as „Facebook marks‟) as under:

┌────────────────────────────────────────────────────────────────────────────────────────────────┐
│ Sl. No.   Trademark         Class            Reg. No.   Reg. Date       Valid upto             │
├────────────────────────────────────────────────────────────────────────────────────────────────┤
│ 1.        FACEBOOK          35 & 38          1436663    22 March        22 March               │
│                                                         2006            2026                   │
│ 2.        THE FACEBOOK      35 & 38          1436949    23 March        23 March               │
│                                                         2006            2026                   │
│ 3.        FACEBOOK          25               1535619    28 February     28 February            │
│                                                         2007            2027                   │
│ 4.        FACEBOOK          9, 38 & 42       1622925    20 November     20 November            │
│                                                         2007            2027                   │
│ 5.                          9,35, 36, 38,    1971560    26 May 2010     26 May 2030            │
│                             41 & 42                                                            │
│ 6.        FACEBOOK          16, 35, 40 &     2309997    3 April, 2012   3 April, 2022          │
│ 7.                          16, 35, 40 &     2309996    3 April, 2012   3 April, 2022          │
│ 8.        FACEBOOK          16               2399531    20 September    20 September           │
│                                                         2012            2022                   │
│ 9.                          43               3296117    28 June 2016    28 June 2026           │
│ 10.       FACEBOOK          36               3552373    19 May 2017     19 May 2027            │
│ 11.       FACEBOOK          43               3552374    19 May 2017     19 May 2027            │
│ 12.                         9,38, 41, 42     3749225    9 February      9 February             │
│                             & 45                        2018            2028                   │
│ 13.       FACEBOOK          41               3913396    10 August       10 August              │
│                                                         2018            2028                   │
│ 14.       FACEBOOK          45               4029140    17 December     17 December            │
│                                                         2018            2028                   │
│ 15.       FACEBOOK          9, 35,38, 41,    1855761    27 August       27 August              │
│           DEVELOPER         42 & 45                     2009            2029                   │
│           GARAGE                                                                               │
│ 16.       FACEBOOK          41               2433338    26 November     26 November            │
│           STUDIO EDGE                                   2012            2022                   │
│ 17.       FACEBOOK          35               2433337    26 November     26 November            │
│           STUDIO EDGE                                   2012            2022                   │
│ 18.       FACEBOOK          9, 35, 38, 41,   2585835    26 August       26 August              │
│           HOME              42 & 45                     2013            2023                   │
│ 19.       FACEBOOK GO       35               3032256    13 August       13 August              │
│                                                         2015            2025                   │
│ 20.       WORKPLACE BY      9, 38,42 & 45    3520314    5 April 2017    5 April, 2027          │
│           FACEBOOK                                                                             │
│ 21.       FACEBOOK          9 & 38           3911866    9 August        9 August               │
│           EXPRESS WIFI                                  2018            2028                   │
│ 22.                         9, 35, 36, 38,   3714920    29 December,    29th                   │
│                             41, 42, 45                  2017            December,              │
│                                                                         2027                   │
│       CS(COMM.) 499/2020                                                Page 4 of 18           │
│                                                                                2022:DHC:2524   │
│ 23.                        9, 35, 36, 38,   4007876   26 November    26 November               │
│                            41, 42, 45                 2018           2028                      │
│ 24.                        9, 35, 36, 38,   1969520   21 May, 2010   21 May, 2030              │
│                            41, 42                                                              │
│ 25.                        9, 35, 36, 38,   1656325   20 February,   20 February,              │
│                            41, 42                     2008           2028                      │
│ 10.     The trade dress of the plaintiff‟s „Facebook‟ marks, of its social                     │
└────────────────────────────────────────────────────────────────────────────────────────────────┘

26. Section 29 of the Act also provides a special status to a „wellknown trade mark‟ in Sub-section (4) of Section 29, which reads as under:

“29. Infringement of registered
15,428 characters total
trademarks.—
xxxx
(4) A registered trade mark is infringed by a
person who, not being a registered proprietor
or a person using by way of permitted use,
uses in the course of trade, a mark which—
(a) is identical with or similar to the registered trade mark; and
(b) is used in relation to goods or services which are not similar to those for which the trade mark is registered; and
(c) the registered trade mark has a reputation in India and the use of the
mark without due cause takes unfair advantage of or is detrimental to, the distinctive character or repute of the registered trade mark.”

27. This Court in Tata Sons Ltd. (supra) has held that a wellknown trade mark is a mark which is widely known to the relevant general public and enjoys a comparatively high reputation amongst them. It further held that when a person uses another person‟s „wellknown trade mark‟, he tries to take advantage of the goodwill that such a „well-known trade mark‟ enjoys. Such an act constitutes as unfair competition. It also causes dilution of a „well-known trade mark’ as it loses its ability to be unique and distinctively identified and distinguish as one source and consequent change in perception which reduces the market value or selling power of the product bearing the well-known mark. The Court further laid down the factors that a Court needs to consider for determining whether the trade mark is a „well-known trade mark‟ or not, as under:

“13. Trademarks Act, 1999 does not specify the factors which the Court needs to consider while determining whether a mark is a well known mark or not, though it does contain factors which the Registrar has to consider whether a trademark is a well known mark or not. In determining whether a trademark is a well known mark or not, the Court needs to consider a number of factors including (i) the extent of knowledge of the mark to, and its recognition by the relevant public; (ii) the duration of the use of the mark; (iii) the extent of the products and services in relation to which the mark is being used; (iv) the method, frequency, extent and duration of advertising and promotion of the mark; (v) the geographical extent of the trading area in
which the mark is used; (vi) the state of registration of the mark; (vii) the volume of business of the goods or services sold under that mark; (viii) the nature and extent of the use of same or similar mark by other parties;
(ix) the extent to which the rights claimed in the mark have been successfully enforced, particularly before the Courts of law and trademark registry and (x) actual or potential number of persons consuming goods or availing services being sold under that brand. A trademark being well known in one country is not necessarily determinative of its being well known and famous in other countries, the controlling requirement being the reputation in the local jurisdiction.”

28. Applying the above test and parameters to the facts of the present case, it cannot seriously be disputed that the marks of the plaintiff are well-known in India. Its user base and its reach are evident from the documents that have been filed by the plaintiff. The plaintiff also has obtained registrations of its marks for various classes of goods and the use of a similar mark without due cause would certainly amount to unfair competition, which is detrimental to the distinct character and reputation of the plaintiff‟s „Facebook‟ marks.

29. The plaintiff therefore, has been able to make the test as set out in Section 11(6) and Section 11(7) of the Act as also by this Court in Tata Sons (supra) for it to be declared as a „well-known trade mark‟, as defined under Section 2(1)(zg) of the Act.

30. Section 29(4) of the Act, which has been reproduced hereinabove, states that a registered mark is infringed by a proprietor or a person who uses the same or a similar mark without the permission of the registered proprietor in relation to goods or services which may not be similar to those for which the trade mark is registered, however, because of such mark being a well-known mark, obtains an unfair advantage as the use of such mark is detrimental to the distinct character or reputation of the registered trade mark.

31. In the present case, though there is some distinction between the marks of the plaintiff and of the defendants, the overall visual representation adopted by the defendants, clearly depicts the mala fide intent of the defendants in obtaining unfair advantage by the use of the mark similar to that of the plaintiff and also leads to the dilution of the mark of the plaintiff. It can lead to an unwary consumer being at least interested in taking note of the defendants as having some kind of connection with the plaintiff. The mala fide intent of the defendants is also evident from the fact that upon the knowledge of the ad-interim injunction passed by this Court, the defendants changed the mark from „facebake‟ to „facecake‟ thereby changing only one alphabet, however, chose not to appear before this Court to defend the suit in spite of service.

32. In view of the above, the suit is decreed as under:

(i) The defendants, its directors, proprietors, subsidiaries, affiliates, franchisees, officers, servants, agents, distributors, representatives and anyone acting for or on its behalf are permanently restrained from using the Facebake marks; the domain name www.facebake.in; the email ids facebake.mail@gmail.com; facebake649@gmail.com; the mark Facecake; the Facebook marks, the Facebook Visual Presentation, and any other „Facebook‟ formative trade marks of the plaintiff, or any other mark deceptively similar thereto in relation to products and services related to confectionary items, or any other goods or services, in any manner, including on social media; and

(ii) For a decree of delivery up of all finished and unfinished materials including locks, signage, cards, stationary, accessories, packaging, labels, and other material bearing the Facebake marks or any mark deceptively similar to the plaintiff‟s Facebook marks, by the defendants to the plaintiff for the purpose of erasure or destruction.

(iii) As far as the prayer for rendition of accounts of profits and damages is concerned, though the plaintiff has not led any substantial evidence for the said relief, nominal damages of Rs.50,000/- (Rupees Fifty Thousand only) are awarded in favour of the plaintiff and against the defendants.

(iv) The defendants shall also pay cost of the suit to the plaintiff.

33. Let a decree sheet be drawn accordingly.

NAVIN CHAWLA, J JULY 6, 2022 RN/AB