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Delhi High Court

Beiersdorf Ag vs Hindustan Unilever Limited on 9 May, 2024

                 *       IN THE HIGH COURT OF DELHI AT NEW DELHI

                 %                                         Reserved on      :   15th April, 2024
                                                           Pronounced on    :   09th May, 2024

                 +       I.A. 7636/2021 in CS(COMM) 300/2021

                         BEIERSDORF AG                                            ..... Plaintiff
                                                  Through:      Mr. M.S. Bharath, Mr. V.S. Krishna, Mr.
                                                                Ayush Sharma and Mr. Ashish Sharma,
                                                                Advocates.

                                                  versus


                         HINDUSTAN UNILEVER LIMITED                               ..... Defendant
                                                  Through:      Mr. Chander M. Lall, Sr. Advocate
                                                                along with Ms. Pragya Mishra, Mr.
                                                                Shashwat Rakshit and Mr. Ankur
                                                                Sangal, Advocates.
                         CORAM:
                         HON'BLE MR. JUSTICE ANISH DAYAL
                 %                                ORDER

                 I.A. No. 7636/2021 (under Order XXXIX Rules 1 & 2 of CPC)


                 1.      This application has been filed by plaintiff as part of suit seeking
                 permanent injunction restraining infringement of trademark, unfair trade
                 practice, disparagement, dilution and damages against defendant alleging


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By:MANISH KUMAR
Signing Date:13.05.2024
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                  dishonest conduct by using the signature elements of the distinctive look trade
                 dress of plaintiff's 'NIVEA' products.

                 2.      The crux of the matter relates to the highly distinctive trade dress claimed
                 by plaintiff for its 'NIVEA' brand of products written over a distinctive blue
                 background ('Pantone 280C'), created and developed for plaintiff's products
                 'NIVEA Crème' in 1925. Around 2021, plaintiff became aware that defendant
                 had been undertaking marketing activities involving their sales representatives
                 being present in various malls in Delhi and Gurgaon showing a comparison of
                 a cream in a blue tub identical to plaintiff's 'NIVEA Crème blue tub' (used
                 without the sticker) and defendant's product 'Ponds Superlight Gel'
                 ("impugned activity"). As per the plaintiff, sales representatives of defendant
                 would apply cream from the "blue tub" on the skin of the walk-in customers on
                 one hand and defendant's product on the other hand. Thereafter, the
                 representatives would use a magnifying glass in an attempt to assure the
                 customers that blue tub product left an oily residue on their skin as compared to
                 defendant's product 'Ponds Super Light Gel'. This, claimed by plaintiff, was
                 disparaging of their product and a cease-and-desist notice was issued on 19th
                 June, 2021 to defendant. Thereafter, the instant suit was filed and summons
                 were issued on 5th July, 2021. However, notice was issued in the application
                 and thereafter, the matter has remained on Board.

                 3.      Subsequently, under the impression that defendant was not pursuing the
                 impugned activity, plaintiff had filed an affidavit for withdrawal of the suit.

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                  However, as noted in order dated 23rd January, 2024, Senior Counsel for
                 defendant stated that they have not withdrawn from any such activity and
                 therefore, plaintiff withdrew the said affidavit of withdrawal and this
                 application was contested and argued.

                 Submissions on behalf of Plaintiff

                 4.      Plaintiff claims that one of its most famous and recognizable product
                 packaging is under the brand 'NIVEA' in a flat can of cream with a distinctive




                 blue colour design                                and brand 'NIVEA' written in white. The
                 distinctive blue colour is identified as 'Pantone 280C', and used as a source
                 identifier. Subsequently plaintiff's 'NIVEA' mark was adopted, used and
                 promoted            extensively              in        other       forms        such       as




                                                                                and various others.

                 5.      Plaintiff applied and obtained registrations for 'NIVEA' trademark and
                 variants in more than 175 countries in various classes. 'NIVEA' was first
                 registered in 1943 in India in class 3 and subsequently was registered in various
                 other classes.
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                  6.      List of marks / trademark registrations claimed by plaintiff for brand
                 'NIVEA' are provided in a tabulation as under:




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                  7.      For the purposes of this suit, aside from the word mark, which was not in
                 picture in the impugned promotional activity, stress was laid on distinctive blue
                 colour in the device/logo, especially under registration Nos. 1329991, 2232698,
                 2856286 and 3263712, all being in class 3.

                 8.      While this colour was not protected under registration in India, it was
                 given protection by German Patent and Trademark Office under registration
                 No. 30571072 in class 3. Plaintiff claimed that the distinctive blue colour and
                 the unique trade dress have been extensively used for their product 'NIVEA'
                 and been extensively advertised all over the world through print and digital
                 media and a huge amount of promotional expenses have been spent. The recall
                 therefore, in mind of general consumer relatable to the 'NIVEA' product is of
                 the distinctive blue colour used along with trade dress. Annual worldwide sales
                 turnover, as claimed by plaintiff, for year 2016 was Euro 4.2 billion and
                 promotional expenditure was in the range of Euro 1.5 million. Their specific
                 sales and promotional figures for 'NIVEA' products for the year 2018 were
                 claimed by plaintiff to be Euro 119 million and Euro 30 million respectively.
                 Figures were given for both worldwide and Indian territories from the year 1999
                 onwards. It is claimed that the brand 'NIVEA' features amongst global top 500
                 super brands and has received various other awards, nationally and
                 internationally.




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By:MANISH KUMAR
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                  9.      'NIVEA' was declared a well-known trademark by this Court in CS(OS)
                 No. 1164/2001 titled as Beiersdorf A.G. v. Ajay Sukhwani & Anr.,
                 2008:DHC:3037 vide order dated 14th November, 2008.

                 10.     Counsel for plaintiff drew attention to order dated 28th January, 2021 in
                 CS(COMM) 48/2021 titled as Beiersdorf A.G. v. RSH Global Private Limited
                 & Anr., where the unique trade dress having dark blue background of plaintiff
                 had been protected and an ad interim injunction had been passed against
                 defendant for infringement of the artistic work, label, trade dress and passing
                 off. Attention was drawn to para 4 of the said order dated 28 th January, 2021
                 where the Court noted that the distinguishing features of the trade dress of
                 plaintiff, as apparent from their products, included the brand name of plaintiff,
                 written in white font on a dark blue background and the distinctive blue colour
                 of container, registered by German Patent & Trademark Office in class 3. In
                 this context was the ad interim injunction granted. This, plaintiff's counsel
                 asserted, afforded some recognition by this Court of the distinctive blue colour
                 of plaintiff's product.

                 11.     Grievance was against the impugned promotional campaign of defendant
                 through their sales representatives. Screenshots of the same were provided by
                 plaintiff, which are extracted as under:




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                  12.      The basic grievance was regarding inherently wrong comparison being
                 done by defendant between two different categories of creams. Plaintiff has
                 provided a tabulation for products of plaintiff and defendant focusing on
                 percentage of fatty matter, which are relevant for said assessment, extracted as
                 under:




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                  13.     It was pointed out that there were three categories of products in this
                 cream segment of plaintiff and defendant. The first category being the 'heavy
                 category' (plaintiff's product being 'NIVEA CRÈME' and defendant's product
                 being 'PONDS COLD CREAM'). This heavy product, as apparent from the
                 tabulation above, had 25-28% of fatty matter. The second category was the
                 'light category' (plaintiff's product being 'NIVEA SOFT' and defendant's
                 product being 'POND'S LIGHT MOISTURISER'). As apparent from the table

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                  above, total fatty matter in these products was in range of 10-15%. The third
                 category was the 'gel category' (plaintiff's product being 'NIVEA MEN FRESH
                 GEL' and defendant's product being 'POND'S SUPERLIGHT GEL'). As
                 apparent from the table above, total fatty matter in these products was in the
                 range of 1-8%.

                 14.     What was stressed by plaintiff's counsel was that the impugned
                 promotional campaign was comparing plaintiff's product from heavy category
                 (category 1 above) with defendant's product from gel category (category 3
                 above). Therefore, not only was the use of the blue tub, a clear reference to
                 plaintiff's product, but also the comparison made between two different
                 categories in order to convince a customer that plaintiff's product left oily
                 residue while defendant's product did not, was misleading. Counsel for plaintiff
                 stated that if defendant had done a category-wise comparison between plaintiff
                 and defendant's products, it could potentially still have been a fair comparison,
                 but to use plaintiff's product from the heavy category containing about 25%
                 fatty matter and comparing it with defendant's product having 10% fatty matter,
                 would obviously show a difference in its application and residue. This, it was
                 argued, was unfair, dishonest, mala fide and misleading.

                 15.     Attention was drawn to para 2(ix) of defendant's written statement where
                 they had averred that they also sell other moisture variants including heavy
                 moisturisers. Plaintiff's counsel stated that this amounted to an admission on



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                  defendant's part that they also had other categories of products, including heavy
                 moisturisers and creams.

                 16.     What was heavily focused on by plaintiff's counsel are ten different
                 instances in which the same or similar disparagement issues arose, of plaintiff's
                 products by defendant, in particular the 'NIVEA' brand in distinctive blue
                 packaging. It was pointed out that plaintiff is the parent company which owns
                 the product 'NIVEA' worldwide and is responsible for agitating this issue in
                 various jurisdictions. In fact, in two of these instances, plaintiff's subsidiary
                 'NIVEA India Private Limited' had made complaints with Indian regulators.
                 These ten instances were further elaborated as under:

                 (i)     A letter was addressed on 19th January, 2004 by plaintiff to 'Unilever'
                 (the parent company of defendant Company) regarding a TV Commercial
                 (TVC) comparing 'NIVEA' products of plaintiff against 'DOVE' product of
                 defendant. The TVC had sought to compare 'NIVEA Crème' to a 'DOVE Silk'
                 product. In response, communication dated 1st March, 2004 was received by
                 plaintiff's Middle East office from defendant's parent company, 'Unilever',
                 stating that they had taken necessary measures to ensure that this particular TVC
                 will not go on Air again.

                 (ii)    An order of District Court, Hamburg, Germany, dated 16 th
                 September, 2003 between plaintiff and 'Lever Faberge GmbH' (part of
                 Unilever Group) injuncting an advertisement between plaintiff's 'NIVEA
                 Crème' and 'DOVE' product regarding "no greasy coating on your skin".
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                  (iii)   A complaint made to 'Advertising Standards Council of India'
                 (hereinafter referred to as "ASCI") dated 25th October, 2012, regarding TVC
                 for launch of 'Fair & Lovely Moisture Plus', which had shown a hand pushing
                 a blue jar off the screen and introducing the 'Fair & Lovely' product (which is
                 sold by defendant company). A part of the complaint had asserted the
                 importance of 'NIVEA' blue colour tone and distinctive shape of the jar which
                 has been identified with plaintiff's product in several countries. The ASCI
                 rendered a decision/ recommendation on 2nd November, 2012 upholding the
                 complaint and advising the defendant to withdraw or modify the said TVC.

                 (iv)    A communication dated 17th March, 2013 addressed by plaintiff's Middle
                 East Office ('Beiersdorf Middle East') to Mr. Sanjiv Mehta of 'Unilever Gulf
                 FZE', in relation to campaign of comparative advertisements for 'DOVE
                 Essential Nourishment Lotion', displaying plaintiff's brand as a dark blue tub
                 with white print and describing it as "greasy". This complaint was regarding in-
                 mall activations with promoters inviting participants to compare 'DOVE
                 Essential Nourishment Lotion' with the lotion in the blue tub.

                 (v)     A decision dated 12th May, 2016 of 'Ethics Council of São Paulo' under
                 'CONAR (National Council of Advertising Self-Regulation)' regarding a
                 complaint by plaintiff ('BDF NIVEA LTDA') against 'Unilever Brasil LTDA'
                 of 'DOVE ORIGINAL' campaign marketed on TV for comparison with
                 'NIVEA' product whereby the Ethics Council agreed to recommend alteration
                 of the said advertisement.

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                  (vi)    A complaint dated 16th December, 2016 by 'Hindustan Unilever Ltd.'
                 against plaintiff to the ASCI with regard to 'NIVEA crème' advertisement.

                 (vii) A communication dated 5th June, 2018 from 'NIVEA India Pvt. Ltd.', the
                 Indian subsidiary of plaintiff, to defendant regarding 'Ponds Light Moisturiser'
                 advertisement on digital and social media platforms. This was also related to
                 'NIVEA' product in colour blue where the 'Ponds Light Moisturiser' had been
                 compared with an unnamed moisturising product. Comparison was made
                 between a heavy moisturiser and 'Ponds Light Moisturiser'. Pursuant to the said
                 notice, said advertisement was withdrawn in a "gesture of goodwill" as per
                 communication dated 12th June, 2018 from Unilever.

                 (viii) A communication dated 25th October, 2019 from 'NIVEA India Pvt. Ltd.'
                 to defendant regarding 'Lakme Peach Milk Soft crème' advertisement. A
                 comparison was made with the product having the iconic blue colour packaging
                 and the font style of 'crème'. In the communication dated 5th November, 2019
                 from defendant, it was stated that the said Instagram story was published for
                 temporary period and not re-posted or used in any other creative nor in any form
                 of media advertisements and the matter was requested to be closed.

                 (ix)    Decision of Federal Patent Court of Munich, Germany, dated 14 th
                 October, 2019 in relation to a cancellation petition by 'Unilever Deutschland
                 Holding GmbH' against the blue colour ('Pantone 280C') registration. The said
                 cancellation request by 'Unilever' was withdrawn subsequently.


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                  (x)     In settlement arrived at between plaintiff and 'Unilever Hamburg,
                 Germany', relating to use by 'Unilever' of various products under 'DOVE'
                 trademark in iconic blue packaging which was agreed not to be offered /
                 advertised or placed in the market. The parties had further agreed that it did not
                 restrict 'Unilever' from using a colour mark blue other than colour 'Pantone
                 280C'.

                 17.     Plaintiff's counsel also drew attention to portions of reply filed by
                 defendant to this application being I.A. 7636/2021 under Order XXXIX Rules
                 1 & 2 of CPC, in particular the following:

                 (i)     Firstly, that the application of an unidentified 'heavy moisturiser' in a
                 dark blue container and application of a light 'gel-based moisturiser' upon
                 hands of a consumer was to provide them a feel of products and was not
                 disparaging. Defendant had stated the colours of the container only with a view
                 to stress on whether the moisturiser being used was heavy or a light one. This,
                 plaintiff's counsel asserted, was enough of an admission that the specific
                 container colour was used in order to point to the heavy cream of plaintiff.

                 (ii)    Secondly, a table was provided in the said reply by defendant which also
                 noted the difference in the fatty matter between plaintiff's product 'NIVEA
                 crème' and defendant's 'Ponds Gel Moisturiser' product which was being used
                 for comparison. The said table as provided by defendant is reproduced below:




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By:MANISH KUMAR
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                  (iii)   Thirdly, defendant stated that it was a true statement that defendant's
                 cream was less sticky and therefore cannot be construed as disparagement. To
                 this, plaintiff's counsel asserted that this could only be used as a defence when
                 compared to a similar product, rather than to different products.

                 (iv)    Fourthly, defendant stated that there were other parties using the colour
                 blue for their products and therefore, plaintiff could not have monopoly over
                 the same, and the said promotional activity could not possibly refer to just
                 plaintiff's products. A tabulation had been given of various such products by
                 defendant. To this, plaintiff adverted to in their rejoinder and responded that all
                 these products with colour blue, shown by defendant, were actually not
                 available in India. The said table is provided as under for ease of reference:




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                  18.     Plaintiff's counsel placed reliance inter alia upon the following
                 decisions:




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                  18.1 George V. Records, SARL v. Kiran Jogani & Anr., 2004 SCC OnLine
                 Del 186, where reliance was placed inter alia on para 12 of the decision of the
                 High Court of Delhi, on the issue of single economic entity.

                 18.2 Su-Kam Power Systems Ltd. v. Kunwer Sachdev and Anr., 2019 SCC
                 OnLine Del 10764 in CS (COMM) 1155/2018, decided on 30th October, 2019,
                 where reliance was placed on para 81 of the said decision to state that defendant
                 would be estopped from claiming that they had no knowledge of the existence
                 of plaintiff's product since it would have to be presumed from prior facts and
                 circumstances. Reliance in these paragraphs has been made to Supreme Court's
                 decision in B.L. Sreedhar and Ors. v. K.M. Munireddy (Dead) and Ors.,
                 (2003) 2 SCC 355. This was in the context that defendant cannot claim
                 ignorance of existence of blue tub product of plaintiff considering there have
                 been at least ten prior instances where same situation had arisen worldwide
                 including in India.

                 18.3 Gillette India Limited v. Reckitt Benckiser (India) Private Limited,
                 2018 SCC OnLine Mad 1126, a decision rendered by High Court of Madras
                 decided on19th April, 2018 wherein reliance was placed to state that even if
                 there was no specific reference to the brand of plaintiff, overall impression
                 created by advertisement would end up being disparaging of plaintiff's product
                 because of dominance of plaintiff in that particular category.

                 18.4 Reckitt Benckiser (India) Ltd. v. Hindustan Lever Limited, 2013 SCC
                 OnLine Del 6377 titled as CS(OS) No. 375/2013 decided on 14th May, 2013, to
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                  submit that at the stage of injunction, only a prima facie opinion is taken, and
                 market surveys/lab reports relied upon by defendant may not be relevant at that
                 stage. Plaintiff's counsel contended that even they had carried out market
                 surveys after the filing of the suit where the brand of plaintiff's products were
                 peeled off, however, the customers even then recognised that as the 'NIVEA'
                 product of plaintiff.

                 18.5 Reckitt Benckiser (India) Ltd. v. Hindustan Lever Limited, 2008 SCC
                 OnLine Del 1731 in CS(OS) No. 1359/2007 decided on 7th July, 2008, where
                 injunction was granted in relation to advertisement which had shown an orange-
                 coloured soap as being harmful. Even though the brand was not shown, it was
                 held by the Court that from the standpoint of a reasonable person, the
                 advertisement will amount to disparagement of and denigrating plaintiff's
                 product, and relief was granted.

                 18.6 Plaintiff's counsel also filed the following decisions - Reckitt & Colman
                 of India Ltd v. KIWI T.T.K, 1996 (16) PTC 393 (Del); Pepsi Co. Inc and Ors.
                 v. Hindustan Coca Cola Ltd., 2003 (27) PTC 305 (Del) (DB); Dabur India
                 Limited v. Colgate Palmolive India Ltd., 2004 (29) PTC 401 (Del); Eureka
                 Forbes Ltd. vs. Pentair Water India Pvt. Ltd., 2007 (35) PTC 556 (Karn);
                 Unibic Biscuits India Pvt. Ltd. v. Britannia Industries Limited, MIPR 2008
                 (3) 347; S.C. Johnson and son Inc. and Anr. v. Buchanan Group Pvt. Ltd.
                 and Ors., 2010 (42) PTC 77 (Del); Anheuser Bushch Llc v. Rishav Sharma &
                 Ors., 2020 (83) PTC 217 (Del); Vikram Roller Flour Mills Ltd. v. KRBL Ltd.,

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                  CS (COMM) 587/2018; Columbia Sportswear Company v Harish Footwear
                 & Anr., CS (COMM) 1611/2016; Sudhir Kumar @ S. Baliyan v. Vinay
                 Kumar, CA No. 5620 of 2021; Annamalayar Agencies v. VVS & Sons, Pvt.
                 Ltd & Ors., 2008 (38) PTC 37 (Mad); ITC Limited v Reckitt Benckiser (India)
                 Pvt. Ltd., C.S. No. 55 of 2021; Hindustan Unilever Ltd. v. Reckitt Benckiser
                 (India) Ltd., 2014 (57) PTC 78 (Cal); Hindustan Unilever Limited v Reckitt
                 Benckiser India Limited, 2014 (57) PTC 495 (Del); Reckitt Benckiser (India)
                 Ltd. v. Hindustan Unilever Ltd., 2014 (3) CHN (Cal) 527 & Reckitt Benckiser
                 (India) Ltd. v. Hindustan Unilever Ltd., 2020 (82) PTC 329 (Del) & Reckitt
                 Benckiser India Pvt. Ltd. v. Hindustan Unilever Ltd., 2021 (88) PTC 584
                 (Del).

                 Submissions on behalf of Defendant

                 19.      Mr. Chander M Lall, Senior Advocate placed his submissions on behalf
                 of defendant in response. First, he drew attention to the impugned activity which
                 had been alleged by plaintiff as disparaging. The video depicting the activity
                 was shown to the Court where it could be seen that individuals in malls, who
                 were field marketing force of defendant, were applying defendant's product
                 'Ponds Super Light Gel' on one hand of the consumers and cream from a blue
                 container on the other hand and asking the consumers to look from a magnifying
                 glass to ascertain which product leaves oily residue.

                 20.      The said video did not have any audio recording, and it was admitted by
                 the parties that there was no verbal communication in the impugned activity.
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                  For this the statement made in para 4 (xi) in the written statement was pointed
                 out, where lack of verbal communication is mentioned, which has not been
                 denied by plaintiff in its replication.

                 21.     Senior counsel for defendant set the stage for his arguments on the basis
                 that it was settled law that comparative advertising was permitted, though
                 disparagement was not. Any marketing exercise involving comparison of one
                 brand with the other was permitted, but to put another brand in a negative light
                 amounting to disparaging was not. In this, he stated that no brand was shown
                 of other cream which was being compared and just another cream was used in
                 blue tub by the marketing executive in the impugned activity. Without prejudice,
                 he stated that even if presuming 'NIVEA' brand was shown in the compared
                 product, it would still not amount to disparagement, since it was merely a
                 comparison between two sets of creams, as to their relative merits on oily
                 residue.

                 22.     Disparagement, according to him, could be either for a specific brand or
                 for a category of products. He contended that even assuming that 'NIVEA'
                 brand was shown, at best the impugned activity would show that 'NIVEA'
                 brand was oilier, which could, for a particular user, be more useful and
                 preferable for use in winter depending on the skin type.

                 23.     Moreover, he pointed out that, in any event plaintiff could not have any
                 exclusive right on the blue colour bottle or in colour blue as several other
                 moisturisers are being sold in blue container. For this, he pointed out to screen
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                  shots showing 3rd party moisturisers in dark blue packaging. Also, plaintiff had
                 supressed the fact that they were marketing distinct creams including
                 moisturising creams in different colour packaging. For this, he pointed out to
                 range of products from video portfolio, screenshot of which is extracted under
                 for ready reference:




                 24.     Plaintiff did not have any trademark registration over the colour blue in
                 'Pantone 280C' in India. Trademark rights were territorial and registration in
                 any other jurisdiction will not inure to plaintiff's benefit.

                 25.     It was argued that even if the product in the impugned activity is
                 plaintiff's product, no conclusion was being reached that which product was
                 better or should be used by the consumer. The products were also not
                 completely different as plaintiff's product was promoted as 'NIVEA crème' as
                 an all-season moisturiser, suitable for all skin types and not as a heavy

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                  moisturiser. The products were intended for the same purpose i.e. a moisturising
                 cream and they were being compared in relation to a verifiable and material
                 feature i.e. their effect on the skin of the consumer. Therefore, plaintiff's
                 contention that they were dissimilar products, could not be accepted.

                 26.     Regards the plaintiff's contention that there was a history of litigation
                 between the parties on the basis of use of colour blue, senior counsel for
                 defendant contended that adjudication has to be on merits of the case and not
                 past disputes. The impugned activity, which is alleged to be disparaging, has to
                 be looked on its own merits.

                 27.     Defendant's counsel placed reliance inter alia upon the following
                 decisions:

                 27.1 Britannia Industries Ltd. v. ITC Ltd., (2017) SCC OnLine Del 7391,
                 where ITC had filed a suit seeking injunction against Britannia from using a
                 deceptively confusing similar trade dress for its 'Nutri Choice' product, copying
                 that of ITC's 'Sunfeast' product.

                 27.2 Colgate Palmolive Company & Anr. v. Hindustan Unilever Ltd., 2013
                 SCC OnLine Del 4986, where the issue before the Division Bench of this Court
                 was relatable to an advertisement campaign pursued by a party selling its
                 toothpaste through print advertisements as well as television commercials
                 (TVCs). The advertisement sought to convey that 'Pepsodent Germicheck
                 Super Power' was a 130% better product, than the opposing party's product

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                  'Colgate Dental Cream Strong Teeth'. The suit for disparagement had been
                 filed and injunction was not granted by the Single Judge.

                 27.3 Dabur India Ltd. v. M/s. Colortek Meghalaya Pvt. Ltd., 2010 SCC
                 OnLine Del 391, wherein Division Bench of this Court was dealing with telecast
                 of an advertisement of 'Good Knight Naturals' mosquito repellent cream, which
                 was considered disparaging by plaintiff / appellant who manufactured
                 'Odomos'. The court traversed the law regarding disparagement.

                 27.4 Horlicks Ltd. & Anr v Heinz India (Pvt.) Ltd., 2018 SCC Online Del
                 12975, where the Single Judge of this Court was dealing with an issue of
                 disparagement against plaintiff's brand 'Horlicks' being compared by
                 defendant's product 'Complan'. The disparagement was that one cup of
                 'Complan' has same amount of protein as two cups of 'Horlicks'. The court
                 traversed law regarding disparagement and reached the conclusion that the
                 impugned advertisement compared a material element verifiable and
                 represented feature of the goods in question. It further stated that defendant was
                 not obliged to compare all parameters, and it was open to advertiser to highlight
                 a special feature or characteristic of his product, which sets its product apart
                 from that of its competitors.

                 27.5 Havells India Ltd. & Anr. v. Amritanshu Khaitan & Ors., 2015 SCC
                 OnLine Del 8115, wherein Single Judge of this Court was dealing with plaintiff
                 suit alleging disparagement by the defendants by comparing their product
                 'Eveready LED Bulb' with plaintiff's product 'Havells LED Bulb' exhorting the
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                  customers to 'check lumens and price before you buy' before purchase. The
                 Court opined that comparative advertising was legal and permissible being in
                 the interest of vigorous competition and public entitlement and can be resorted
                 only with regard to like products.

                 27.6 Dabur India Ltd. v. Emami Ltd., 2019 SCC OnLine Del 9022, where the
                 Single Judge of this court was dealing with plaintiff's application for seeking
                 restraint of advertisements by defendant which was comparing its sugar free
                 variant 'Chyavanprashad' with 'Chyawanprash' which contains sugar.

                 27.7 Reckitt Benckiser (India) Pvt. Ltd. & Anr. v. Wipro Enterprises (P)
                 Limited, 2023 SCC OnLine Del 2958. Single Judge of this Court was dealing
                 with issue of disparagement of plaintiff's 'Dettol' hand wash with 'Santoor'
                 hand wash product of defendant.

                 27.8 Counsel for defendant has also filed decisions of Novartis A.G. & Ors.
                 v. Mehar Pharma & Ors., 2005 (30) PTC 160 (Bom) & Reckitt Benckiser
                 (India) Limited v. Gillete India Ltd., (2016) 68 PTC 67 (DB), Reckitt
                 Benckiser (India) Ltd. v. Hindustan Unilever Ltd., 2014 (57) PTC 78 (Cal) &
                 Gillette India Limited v. Reckitt Benckiser (India) Pvt. Ltd., 2018 SCC OnLine
                 Mad 1126.

                 Submissions in Rejoinder

                 28.     Counsel for plaintiff responded to defendant's submissions essentially
                 reiterating that defendant was not alien to plaintiff's blue colour product and
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                  had surprisingly insisted in using a blue colour jar for cream comparison. This
                 is despite that defendant had been stopped from using this colour in ten other
                 instances which had already been cited. Attention was drawn in particular to the
                 written statement filed by defendant in para (xv) stating that plaintiff's 'NIVEA
                 crème' was a cream-based product whereas defendant's 'Ponds Superlight Gel'
                 is a gel-based product. It was stated in the written statement that cream-based
                 moisturisers are usually heavy, making the skin sticky and not suitable for all
                 skin types irrespective of the season or geographical location of the consumer.
                 On the other hand, gel-based moisturisers are of light texture, oil free, suitable
                 for all skin types, non-sticky and provide hydration to the skin without clogging
                 pores. It is reiterated in para (xvi) of defendant's written statement that
                 defendant's product, being a gel-based moisturiser, is a superlight weight gel
                 providing hydration without getting one's skin sticky and leaves lesser oily
                 residue as compared to other cream-based moisturisers and this was truthful
                 statement by defendant.

                 29.     Counsel for plaintiff stated that impugned activity was comparing the
                 heaviest cream of plaintiff with the lightest gel of defendant, and not even the
                 intermediate products which are sold by both parties.

                 30.     Plaintiff's counsel used a different benchmark to state that senior counsel
                 for defendant was trying to compare a 'running shoe' with a 'trekking shoe' or
                 'chywanprash' with a 'herbal paste'. He further submitted that defendant
                 lacked the courage to compare correct and similar versions of the moisturisers

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                  / creams. Plaintiff's counsel stated that there was no reason as to why defendant
                 was simply comparing a heavier cream to their light gel, had to use a blue
                 coloured distinct tub which was indicative and suggestive of plaintiff's product
                 rather than using any other colour. It was just a matter of proving the lighter
                 consistency of their product.

                 Analysis

                 31.     The jurisprudence on comparative advertising developed in India through
                 various Court decisions, which are, most usefully and comprehensively,
                 traversed and documented in a recent judgement of a learned Single Judge of
                 this Court in Wipro Enterprises (supra). No purpose would be served in
                 reinventing the wheel and it would be best to advert to the final elucidation and
                 enumeration of principles, set out in para 111 of the said judgement (parts that
                 may have relevance to the discussion which follows, are underscored, for ease
                 of reference):

                                    "111. The overall legal position that emerges from
                                    these decisions is, therefore, the following:
                                    (i) Where the advertisement does not directly or
                                    indirectly refer to the plaintiff's product, the
                                    plaintiff could not claim that its product was being
                                    targeted merely because it enjoyed a lion's share of
                                    the market. Targeting of the plaintiffs product is the
                                    sine qua non, whether expressly or by necessary
                                    implication. That implication cannot, however, be
                                    premised merely on the market share of the
                                    plaintiff's product.
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                                     (ii) At the same time, even if the rival product was
                                    not      specifically   targeted,     an     indirect
                                    representation, which was sufficient to identify the
                                    product, was as good as direct targeting.

                                    (iii) Within the limits of permissible assertions,
                                    comparative advertising is protected under Article
                                    19(l)(a) as commercial speech. In comparative
                                    advertising, a certain amount of disparagement is
                                    implicit.
                                    (iv) Subject to the exception in (v) infra, an
                                    advertisement must not be false, misleading, unfair
                                    or deceptive, irrespective of whether it is extolling
                                    the advertised product or criticising its rival.
                                    Misrepresentation and untruth in advertisements is
                                    impermissible. An advertisement has necessarily to
                                    be honest. It was not only, thereby, required to be
                                    accurate and true, but could also not convey an
                                    overall misleading message, seen from the stand
                                    point of the customer.

                                    (v) Puffery is the only exception, as puffery, by its
                                    very nature, involves exaggeration and
                                    embellishment, and an element of untruth is bound
                                    to exist in it. Untruth in puffery is permissible only
                                    because puffery is inherently not taken seriously by
                                    the average consumer. Puffery is not, therefore, to
                                    be tested on the anvil of truth. Some element of
                                    hyperbole and untruth is inherent in puffery.

                                    (vi) Mere puffery is not actionable. One can claim
                                    one's goods to be better than others. Extolling the
                                    virtues of the plaintiffs product as containing
                                    natural ingredients, absent in other products, was

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                                     not disparaging. Extolling of one's positive
                                    features is permissible.

                                    (vii) However, denigration of a rival's or a
                                    competitor's product is completely impermissible.
                                    While it is permissible, therefore, to state that the
                                    advertised product is superior to the competitor's,
                                    it is not permissible to attribute this superiority to
                                    some failing, or fault, in the product of the
                                    competitor. An advertisement cannot claim that a
                                    competitor's goods are bad, undesirable or
                                    inferior. The subtle distinction between claiming
                                    one's goods to be superior to the others', and the
                                    other's goods to be inferior to one's, has to be
                                    borne in mind.
                                    (viii) Serious statements of facts cannot, however,
                                    be untrue. The truthfulness of such assertions or
                                    statements of fact is to be strictly tested.

                                    (ix) What matters is the impression that the
                                    advertisement or commercial registers in the
                                    viewer's mind. The hidden subtext, so long as it is
                                    apparent to the average consumer, therefore,
                                    matters. The impact could be conveyed by clever
                                    advertising or innuendo instead of conveying of a
                                    direct message.

                                    (x) The reasonable man, from whose point of view
                                    the advertisement is to be assessed, is a right
                                    thinking member of the general public, and not a
                                    member of any particular class or section. He

                                    (a) is not naive,
                                    (b) can read between the lines,

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                                     (c) can read in implication into the advertisement,

                                    (d) may indulge in some amount of loose thinking,

                                    (e) is not avid for scandal and
                                    (f) does not select a derogatory, or bad, meaning
                                    to be attributed to an advertisement where
                                    alternative, non-derogatory meanings are also
                                    available.
                                    (xi) While examining whether a commercial is
                                    disparaging, the Court is required to see
                                    (a) the intent of the commercial

                                    (b) the manner of the commercial and
                                    (c) the story line of the commercial, and the
                                    message that it seeks to convey.
                                    What has to be seen is the overall effect of the
                                    advertisement, i.e. as to whether the advertisement
                                    is promoting the advertised product or disparaging
                                    the rival product. The advertisement has to be seen
                                    as a whole, not frame by frame. While promoting
                                    his product, an advertiser might make an
                                    unfavourable comparison, but that may not
                                    necessarily affect the story line or message or have
                                    an unfavourable comparison as its overall effect.

                                    (xii) The Court should neither undertake an over-
                                    elaborate analysis, nor be too literal in its
                                    approach.

                                    (xiii) The advertisement was to be viewed as a
                                    normal viewer would view it, and not with the

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                                     specific aim of catching disparagement. Words
                                    used in the advertisement are meant to be
                                    understood in their natural, general and usual
                                    sense and as per common understanding.

                                    (xiv) The time spent in showing the product was
                                    irrelevant; what was relevant was the context in
                                    which the product was shown.

                                    (xv) A plaintiff cannot afford to be hypersensitive,
                                    as the choice of the article which a consumer would
                                    select would depend on various factors including
                                    market forces, economic climate and nature and
                                    quality of the product.

                                    (xvi) It is necessary to provide a fair amount of
                                    latitude to the advertiser as well."
                                                                     (emphasis added)

                 32.     While these principles serve as useful guideposts in any assessment of
                 comparative advertising, each case in unique, with its own facts and context.
                 Therefore, a specific assessment is necessary. In this context it would be useful
                 to appreciate submissions by counsels, as noted above. Our analysis revolves
                 around the following principal aspects: first, the association of the blue cream
                 tub presented as part of the impugned activity, to that of plaintiff's 'NIVEA
                 Crème'; second, the knowledge of the defendant of the distinctiveness in the
                 blue colour of the plaintiff for 'NIVEA Crème'; third, the intent and objective
                 of using only the blue cream tub as part of the impugned activity; fourth, the
                 comparative presented to the consumer during the impugned activity; and fifth,
                 whether it was mere puffery or disparagement.
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                  The Colour Blue

                 33.     The distinctive blue colour of plaintiff's 'NIVEA Crème' is identified as
                 'Pantone 280C' and is used as a 'source identifier', by plaintiff. This, as stated
                 by plaintiff, was first created and developed in 1925. The word 'NIVEA' was
                 first registered in 1943 in Class 3 in India and later, in other classes as well. The
                 trademark registrations, as extracted in para 6 above show that a predominant
                 set of marks, particularly the device marks, adopted the 'Pantone 280C' colour
                 and in particular the registration numbers i.e. 1329991, 2232698, 2856286 and
                 3263712, all in Class 3.

                 34.     The distinctive blue colour ('Pantone 280C') was also given protection
                 by the German Patent and Trademark Office since 2007. It is prima facie
                 evident from the documentation filed, that the colour is not used by plaintiff for
                 a decorative purpose but functions as a 'source identifier' and it has been used
                 extensively by plaintiff for its product, in particular the cream tub. The adoption
                 of the distinctive colour, about a century back and consistent use of the same by
                 plaintiff would certainly lead to a prima facie conclusion that plaintiff's cream
                 product, in this distinctive blue colour tub, will be associated with plaintiff.

                 35.     Plaintiff's counsel had also drawn attention to a decision of this Court
                 dated 14th November, 2008 in RSH Global (supra) noted in para 10 above,
                 where this Court passed an injunction inter alia restraining defendant from
                 selling products infringing the plaintiff's distinctive trade dress. The
                 distinguishing features of the trade dress included plaintiff's brand name
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                  'NIVEA' written in white font on a dark blue background in a distinctive blue
                 colour. While defendant seeks to distinguish by stating that this is only relating
                 to an overall trade dress, the distinctive blue colour does get associated with
                 plaintiff's product. The assertion by defendant that plaintiff sells other products
                 as well in different colour packaging besides the colour blue, would be
                 irrelevant considering that their flagship product 'NIVEA Crème' and other
                 associated products are sold in packaging, which use a distinctive blue colour.

                 36.     The distinctiveness in the blue colour is also borne out from the various
                 instances which plaintiff's counsel relied upon and which are enumerated in
                 para 16 above. It is not denied that defendant is part of the 'Unilever Group'
                 worldwide and basis the 'single economic entity principle' [reliance has been
                 placed on George V. Records (supra)], it cannot deny that it does not have
                 knowledge of the association of the distinctive blue colour with plaintiff's
                 product. Unilever's cancellation petition in Germany was withdrawn;
                 withdrawals and settlements have been made by associate companies under the
                 'Unilever' umbrella in various countries in relation to comparative
                 advertisement issues which arose and the same is evident from para 16(i), (vii),
                 (viii) and (x) above. A previous complaint had been made to the ASCI where a
                 recommendation was made that defendant withdraw the TVC which showed a
                 hand pushing a blue jar off the screen, as evident from para 16(iii) above. These
                 and other instances, as cited in para 16 above, persuade this Court in favour of
                 plaintiff, in that defendant cannot plead ignorance regarding the distinctive blue
                 colour association with plaintiff's product. In fact, from these situations, it
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                  seems that repeated attempts have been made in order to adopt aggressive
                 comparative advertising by defendant, which has not succeeded in other regions
                 of the world as well.

                 37.     Prima facie, the colour blue, in particular 'Pantone 280C', is certainly
                 associated for years with plaintiff's product 'NIVEA', which has achieved
                 distinctiveness for plaintiff's product and has become popular. Plaintiff
                 claiming exclusivity in this colour is not the issue, however, the use by
                 defendant in the impugned activity of a blue colour tub is too much of a
                 coincidence to ignore. The allusion seems to be to the distinctive blue colour
                 used by plaintiff.

                 38.     The propensity to compare with plaintiff presumably arises on plaintiff
                 being possibly the market leader in this category of personal care products,
                 namely, creams and lotions, or at the very least a dominant competitor to the
                 defendant. The instances in para 16 above also bear this out. Plaintiff company
                 is over 130 years old and claims to be one of the leading skin care and personal
                 care companies in the world, as evident from para 3 of the plaint, and has more
                 than 150 affiliates worldwide. It is natural in situations of comparative
                 advertising that the target of the advertiser is usually a competitor and more so,
                 a competitor with a better market share. This is natural, since market warfare
                 involves strategies to dilute a competitor's brand, reduce their sales, in order that
                 a larger market share is procured by the advertiser.



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                  39.     The use by defendant of a blue tub cream, in exactly the same distinctive
                 colour, seems prima facie to have the objective to make a consumer draw
                 association to plaintiff's product. Why defendant chose not to use a cream in
                 any other colour tub, begs an answer which was not available during arguments,
                 if indeed the attempt was not to disparage plaintiff's product.

                 40.     Even though it cannot be taken as proof in isolation, market survey
                 conducted by plaintiffs after filing the suit with peeled off labels from various
                 products also noted that the dark blue tub was associated generally with
                 'NIVEA' by the consumers.

                 41.     The significance of colour has been the focus of decisions of Courts in
                 India and reference may be made inter alia to Parle Products (P) Ltd. v. J.P.
                 and Co., (1972) 1 SCC 618 and Colgate Palmolive Co. & Anr. v. Anchor
                 Health and Beauty Care (P) Ltd., 2003 SCC OnLine Del 1005.

                 Defendant's knowledge

                 42.     The knowledge of defendant about Pantone blue colour being associated
                 with plaintiff is evident from various instances cited by counsel for plaintiff in
                 India and abroad. Having been locked in litigation, suffered injunctions, and
                 received complaints on this very issue in other countries, there was no reason
                 why defendant had to choose a similar blue colour tub for comparison in order
                 to promote their own product.



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                  43.     Reliance by plaintiff's counsel in Su-Kam (supra), on estoppel, is
                 therefore apposite.

                 Intent and objective

                 44.     Defendant could have easily used a different colour tub and written
                 'heavy cream' on top. By using an 'unlabelled' distinctive blue colour jar/tub
                 for the cream, defendant has uncategorized the product, leaving the consumer
                 with absolutely no information as to the consistency of the cream being used
                 for comparison. Comparison by its very nature ought to be with another
                 identified product and cannot be a comparison to an abstract unidentified
                 product. By using a 'non-labelled' blue tub, the question that needs to be
                 considered is what comparison is the defendant trying to make and with what;
                 which cream is it trying to compare its cream to?

                 45.     There were no answers available on behalf of the defendant for these
                 questions. By choosing to use a distinctively blue color tub without a label,
                 defendant has ventured into the area of deception, misstatement and by
                 implication, into the area of disparagement.

                 46.     Defendant's contention that a comparison with a 'generic category'
                 (where the disparaged product is a reference to a general category of products
                 and not to a specific 'labelled' product of plaintiff) will not amount to
                 disparagement, is not acceptable in light of the decisions by various courts in
                 the country. Reference may be made to Reckitt and Colman of India Ltd. v.

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                  M.P. Ramchandran & Anr., 1998 SCC Online Cal 422 (Single Judge of the
                 Calcutta HC) (the product category being a clothes whitener, which was blue
                 in colour); Eureka Forbes Ltd. v Pentair Water India Pvt. Ltd., 2006 SCC
                 OnLine Kar 753 (Single Judge of Calcutta HC) (category of goods being water
                 purifiers of UV technology); and Dabur India Ltd. v. Colgate Palmolive Ltd.,
                 2004 SCC OnLine Del 718 (Single Judge of this Court) (category of goods
                 being red tooth powder products). In all these decisions, despite the comparison
                 made by defendant with a generic product without any specific brand, relief was
                 granted to plaintiff, particularly on the basis that generic disparagement without
                 specifically identifying or pin-pointing the rival product, was equally
                 objectionable. This aspect has also been crystallized in para 111(ii) of Wipro
                 Enterprises (supra).

                 47.     In Dabur India Ltd. v. Colgate Palmolive Ltd., 2004 SCC OnLine Del
                 718 (supra), it was stated:

                                    "19. I am further of the view that generic
                                    disparagement of a rival product without
                                    specifically identifying or pin pointing the rival
                                    product is equally objectionable. Clever
                                    advertising can indeed hit a rival product without
                                    specifically referring to it. No one can disparage
                                    a class or genre of a produce within which a
                                    complaining plaintiff falls and raise a defence
                                    that the plaintiff has not been specifically
                                    identified..."

                                                                   (emphasis added)

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                  48.     Certain other decisions where there was an indirect or no identification
                 to plaintiff's product, also held the advertisement as objectionable. Reference is
                 made to Reckitt & Colman of India Ltd. v. Kiwi T.T.K. Ltd., 1996 SCC Online
                 Del 335 (Single Judge of this Court) where the comparative was done with a
                 shoe polish bottle identical in shape and configuration to plaintiff's bottle with
                 a red blob on it, driving an association with 'Cherry' being the plaintiff's
                 product; Annamalayar Agencies v. WS & Sons Pvt. Ltd. & Ors., 2007 SCC
                 OnLine Mad 1645 (Single Judge of the Madras HC) where a blue bottle without
                 labelling was shown and was identified with the 'Parachute coconut oil' bottle
                 of plaintiff; Reckitt Benckiser (India) Ltd. v. Hindustan Lever Limited, 2008
                 SCC OnLine Del 1731 (Single Judge of this Court) where an orange coloured
                 soap was shown as being harmful, drawing association to 'Dettol' soap of
                 plaintiff. This decision was confirmed by the Division Bench in Hindustan
                 Unilever Limited v. Reckitt Benckiser India Ltd., 2014 SCC OnLine Del 490
                 where the Court proceeded inter alia on the basis that the plaintiff held a major
                 share of the market and therefore, it could not be said that there was no attempt
                 to disparage the product of plaintiff. If the message conveyed through the
                 advertisement is loud and clear it would amount to a deliberate act by defendant
                 to reduce sales of plaintiff.

                 49.     In Reckitt & Colman of India Ltd. v Kiwi T.T.K. Ltd., 1996 SCC Online
                 Del 335 (supra) it was stated:

                                    "13. The advertisement appears on the electronic
                                    media for a few seconds and it shows a bottle of
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                                     KIWI from which the "KIWI" is written on the
                                    white surface which does not drip as against
                                    another bottle described as "OTHERS" which
                                    drips. The bottle of "OTHERS" is shown as
                                    "Brand X". The allegations are that this "Brand
                                    X" looks similar to the bottle of the liquid shoe
                                    polish of the plaintiff for which the plaintiff
                                    allegedly has a design registered in its name.
                                    There is a red blob on the surface of this bottle
                                    which allegedly represents "CHERRY" which
                                    also appears on the bottle of the product of the
                                    plaintiff ........ I am, in any case, not going into
                                    the question as to what is the effect of the issue of
                                    other advertisements of the similar nature by the
                                    manufacturer of other products. Prima-facie, I
                                    am of the opinion that after the removal of the red
                                    blob from the bottle of "Brand X", the same
                                    cannot be linked to the product of the plaintiff and
                                    consequently, in my opinion, there will not be any
                                    question of disparaging or defaming the product
                                    of the plaintiff."
                                                                      (emphasis added)

                 50.     In Reckitt Benckiser (India) Ltd. v. Hindustan Lever Limited, 2008 SCC
                 OnLine Del 1731 (supra), it was stated:
                                    "47. From this discussion, it is apparent that the
                                    advertisement disparages the plaintiffs soap and
                                    it is not an advertisement which seeks merely or
                                    only to promote the superiority of the defendant's
                                    LIFEBUOY soap over an ordinary antiseptic
                                    soap. As I have already pointed out, if it were a
                                    case of mere promotion of superiority of the
                                    defendant's product, alone, the plaintiff would
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                                     not have had a case as that would have only
                                    entailed a permissible "better" or "best"
                                    statement. The advertisement comprises of two
                                    part; one which denigrates and disparages the
                                    product of the plaintiff and the other which
                                    promotes the purported superiority of defendant's
                                    LIFEBUOY soap. The part that disparages does
                                    so because it indulges in the "good versus bad"
                                    comparison. The "good" being the defendant's
                                    LIFEBUOY Skinguard and the "bad" being the
                                    orange coloured bar of soap which has been
                                    identified, as discussed under Issue No. 1, as the
                                    plaintiffs DETTOL Original soap."

                                                                    (emphasis added)

                 51.     In Gillette India Limited v. Reckitt Benckiser (India) Private Limited,
                 2018 SCC OnLine Mad 1126, the Division Bench of the Madras High Court
                 stated:
                                    "96. The meaning of the expression "disparage"
                                    as given in the commonly used dictionaries is,
                                    inter alia, to speak slightingly, to undervalue, to
                                    bring discredit or dishonour, to deprecate, to
                                    degrade, to derogate, to denigrate, to defame, to
                                    reproach, to disgrace, or to unjustly class.
                                    Disparagement is, inter alia, the act of speaking
                                    slightingly, of undervaluing, of bringing discredit
                                    or dishonour, of deprecating or degrading or
                                    disgracing or unjust classing. It also means
                                    derogation or denigration or defamation or
                                    reproachment.


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                                     97. Whether an advertisement is disparaging or
                                    not would depend on several factors, for which
                                    each advertisement would have to be judged on
                                    its own merits, on consideration of the overall
                                    impact of the picture that is portrayed, the
                                    language used, the histrionics, the gesticulations,
                                    the movements, acrobatics, catch phrases,
                                    hilarity or other catchy screen shots. While
                                    humour, hilarity or even ridiculing to highlight
                                    the advantages of one's own product may be
                                    permissible, ridiculing services and products of
                                    another would amount to disparagement.

                                    98. To decide whether an advertisement is
                                    disparaging, the Court has to consider (i) the
                                    intent of the commercial advertisement; (ii) the
                                    message sought to be conveyed; and (iii) the
                                    mode and manner of conveying the message.
                                    Condemning the goods and services of a
                                    competitor or ridiculing the same or showing the
                                    same as substandard would amount to
                                    disparagement.

                                    xxx                       xxx               xxx

                                    108. In a disparagement suit, the Court would
                                    have to examine whether the object of the
                                    advertisement is to highlight the benefits of the
                                    products of the advertiser in comparison to those
                                    of others or to denigrate the products of others,
                                    which would amount to defamation.

                                    xxx                       xxx               xxx


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                                     116. It is true, as argued by Mr. Raman, that
                                    there is no specific reference to "VEET" in the
                                    advertisement. However, admittedly, the
                                    respondent plaintiff dominates 80% of the market
                                    in depilatory creams. As observed above, the
                                    overall impression created by the advertisement
                                    by way of video clip is that all hair removal
                                    creams, which would include the hair removal
                                    creams of the respondent plaintiff, are harmful,
                                    having strong chemicals which are as strong as
                                    bathroom cleaners. Prima facie, there is
                                    disparagement of the depilatory cream of the
                                    respondent plaintiff."
                                                                  (emphasis added)

                 52.     Defendant's contention that since they have not identified any brand of
                 the heavy cream that they were using to compare with (but were using a label-
                 less tub), it would not be a case of disparagement, is therefore not acceptable.

                 The comparative as presented

                 53.     It is an admitted position that both plaintiff and defendant have different
                 categories of creams, essentially three categories, each of which have a different
                 percentage of fatty matter. Defendant chose to compare their lightest product
                 ('Ponds Superlight Gel') to the heaviest product ('NIVEA Crème') of plaintiff,
                 is inherently misleading. A comparative may be made between similar products,
                 if the distinguishing feature relates to a parameter which would be different for
                 a different category.


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                  54.     Defendant admits in its written statement that 'Ponds Superlight Gel'
                 being a gel-based moisturizer provides hydration without giving a sticky feel or
                 leaving oily residue, as compared to other cream-based moisturizers. It is further
                 admitted that cream-based moisturizers are usually heavy making the skin
                 sticky. The relevant averment is extracted as under:

                                    "..cream-based moisturisers are usually heavy,
                                    make the skin sticky and may not be suitable for all
                                    skin types, irrespective of the season or
                                    geographical location of the consumer. On the
                                    other hand, gel-based moisturisers are light in
                                    texture, oil-free, suitable for all skin types, non-
                                    sticky and provide hydration to the skin without
                                    clogging pores."
                                                                     (emphasis added)

                 55.     The comparison by defendant of dissimilar product particularly relating
                 to material feature which was ought to be compared, is in the opinion of this
                 Court, misleading. Even though there was no verbal communication in the
                 impugned activity, the impression being given to a consumer was that
                 defendant's product was lighter and better in the material feature of 'stickiness'
                 and cream in the blue tub was not. It would naturally lead to a consumer being
                 extremely watchful when faced with a choice of buying plaintiff's product
                 (which would have same dimensions and same distinctive colour).

                 56.     If defendant was promoting its lighter gel, there was no reason why they
                 could not have promoted all their products showing that each of the products

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                  have different consistencies in heavy, medium and light gel and there is a range
                 for a consumer to choose from. To compare it with a specific distinctive blue
                 tub cream, to show that their gel was lighter without full knowledge being given
                 to the consumer, is in opinion of this Court, misleading.

                 57.     There is no reason why defendants couldn't have used a heavy cream in
                 a different colour tub in order to compare, and there was no explanation
                 forthcoming from defendant's side on this issue.

                 58.     The impugned activity critically does not present any audio. This does
                 not bode well for defendant's case, since it is up to imagination, as to what was
                 being communicated either by gestures or verbal communication during the
                 impugned activity. Silence, it is said, speaks volumes and in this case, also
                 amounts to an omission to clarify to the consumer that different categories of
                 products are being compared.

                 59.     As evident from para 111(iv) of the Wipro Enterprises (supra)
                 guidelines, advertisement should not be false, misleading, unfair or deceptive.
                 The use of a comparative between a lighter hydrating gel to a heavy
                 moisturizing cream, is itself misleading for a consumer and does not give full
                 information, while extolling its own product.

                 60.     In fact, even in the ASCI CODE FOR SELF-REGULATION OF
                 ADVERTISING CONTENT IN INDIA, Chapter IV, Clause 4.1(a), it stated
                 that comparative advertisements are permissible provided, "it is clear what

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                  aspects of the advertiser's product are being compared to what aspects of the
                 competitor's product"; and in clause 4.1(d) that "there is no likelihood of the
                 consumer being misled as result of the comparison, whether about the product
                 advertised or that with which it is compared".

                 61.     Comparison of dissimilar products arose in a case, in USA, in Bernard
                 Food Industries, Inc. v. Dietene Company, 415 F.2d 1279 (7th Cir. 1969). In
                 this case, both plaintiff and defendant had produced instant custard mix, the
                 plaintiff, an eggless one, while the defendant, with egg solids. The defendant,
                 'Dietene', made a comparison of their product with the eggless mix product of
                 the plaintiff being 'Bernard', showing that the 'Bernard Custard', to be inferior
                 in flavour, texture, nutrition and cost to that of 'Dietene's Delmar Quick Egg
                 Custard'. Even though, the decision was not in the favour of plaintiff on the
                 basis of the scope and purview of section 43 (a) of the Lanham Act, the
                 commentators have criticized the decision, in that defendant had both
                 misrepresented plaintiff's product by giving a false description or representation
                 and put its own product in commerce, in order to reap the benefit of that
                 misrepresentation and that plaintiff therefore, lost sales and further, the public
                 was misled. Further, it was also noticed by the U.S Court in Skil Corp. v.
                 Rockwell Int'l Corp., 375 F. Supp. 777 (N.D.III.1974) that a misrepresentation
                 was made by defendant in a disparagement action in the case of Bernard
                 (supra).




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                  62.     Disparagement actions are likely to include misleading advertisements as
                 well, where there is civil liability or damage by false description or
                 representation of goods or services. This in the USA, has been considered as,
                 "comparative advertising abuses". False representation can be either
                 affirmatively misleading statements, or partially correct statements of failure to
                 disclose material facts.

                 Puffery or disparagement

                 63.     Black's Law Dictionary defines disparagement as, "A derogatory
                 comparison of one thing with another; or a false and injurious statement that
                 discredits or detracts from the reputation of another's character, property,
                 product or business."

                 64.     Defendant's contention that nothing negative was being said about
                 plaintiff's product, in that it was denigrating or rubbishing plaintiff's product,
                 is a submission, difficult to accept. The clear impression to the consumer was
                 that the product being compared with, left a heavy oily residue was certainly
                 misleading as dissimilar products were being compared. The Courts have held
                 that even though advertisements may not be disparaging, misleading elements
                 would have to be excised out. Comparison has to be of like products, not unlike
                 products; 'apples to apples, oranges to oranges', as is the commonly used
                 phrase.




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                  65.     'Stickiness' in the realm of creams, may be considered as a negative
                 attribute. In any event, by pointing out that a non-sticky product was 'better',
                 the clear message was that 'stickiness' is a negative attribute. The suggestion
                 by Senior Counsel for defendant that 'stickiness' may be a useful positive
                 feature in a given circumstance was not supported by any document. Consumer
                 of creams is typically not seeing 'stickiness' but 'hydration' in 'moisturisation',
                 certainly not 'stickiness'.

                 66.     Therefore, for defendant to contend that stickiness or oily residue was not
                 necessarily denigrating or disparaging, cannot be accepted. The very basis of
                 the comparison was that the blue tub cream left an oily residue. 'Stickiness' is
                 used as a pejorative in this context.

                 67.     It is the "overall effect" and the "message conveyed" which needs to be
                 seen for assessing disparagement. The court in Colgate Palmolive (supra)
                 reached a conclusion that impugned TVC cannot be stated to be per se
                 disparaging but the voice over at the end of the TVC was misleading and
                 inaccurate. The statement in the voice over was directed to be deleted from the
                 TVC and to be suitably modified to refer only to 'Colgate ST (Colgate Strong
                 Teeth)'. The court said that what is to be considered, is whether the essential
                 message conveyed by the impugned TVC is prima facie truthful or misleading.

                 68.     This Court in Dabur India v Colortek (supra) has specifically held that
                 Supreme Court in Tata Press Ltd. v. MTNL, (1995) 5 SCC 139 has laid down
                 that false, misleading, unfair or deceptive advertising is not protected
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                  commercial speech. Hyped-up advertising may be permissible but it cannot
                 transgress the grey areas of permissible assertion. The test of untruthfulness has
                 therefore, been propounded and therefore cannot be tolerated even though
                 commercial speech is largely permitted, as part of rights granted under the
                 Constitution.

                 69.     While counsels seem to state that there were no judgments on in-mall
                 marketing campaigns, this Court is of the opinion that the law relating to
                 advertisements in any form whether print, digital, TVC will extend to such
                 campaigns as well, since ultimately it is a method of promotion and marketing
                 of company's product to a consumer, and in fact in a much more personalised
                 and interactive set up. What communication is being done to a user in that
                 interaction is open to anybody's imagination. At least in an advertisement in
                 print digital, medium or TVC, the assessment is limited to what is seen or heard
                 in the commercial. In an in-mall marketing campaign, the possibilities of
                 imputation, aspersion, implication, overstatement, leading to even a slight
                 disparagement, will be limitless. The marketing executives body language,
                 gestures, conversations or suggestive indications will also animate the
                 promotional interaction. There is therefore, intrinsically lesser material
                 available to the court to consider and the threshold would have to be slightly
                 lesser in this regard when considering possibility of the impugned activity being
                 misleading or disparaging.

                 Conclusion

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                  70.     In these facts and circumstances, this Court is of the opinion that the
                 impugned activity undertaken by defendant choosing to compare plaintiff's
                 'NIVEA' products (either expressly or by implication or association) and
                 defendant's products, especially those under the trademark 'Ponds', are prima
                 facie misleading and disparaging, and cause irreversible prejudice to plaintiff.

                 71.     Defendant,        their     directors,   wholesalers,   distributors,   partners,
                 proprietors, agents or assignees are restrained from conducting the impugned
                 activity or such similar marketing/advertising activity, comparing plaintiff's
                 'NIVEA' products (either expressly or by implication or association) and
                 defendant's products (especially those under the trademark 'Ponds'), which
                 amount to disparagement or denigration of plaintiff's products or business.

                 72.     Accordingly, the said application stands disposed of, with the aforesaid
                 directions.

                 CS(COMM) 300/2021
                 1.      List on 24th July, 2024 before the Joint Registrar.

                 2.      Judgment be uploaded forthwith on the website of this Court.



                                                                                    ANISH DAYAL, J.

MAY 09, 2024/sm/na Signature Not Verified Digitally Signed I.A. 7636/2021 in CS(COMM) 300/2021 54 of 54 By:MANISH KUMAR Signing Date:13.05.2024 14:47:35