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9. Defendant No.1 Telegram is a cloud based instant messaging and voice over IP service. Telegram client apps are available for android, iOS, Windows Phone, Windows, MacOS and Linux. These users of Telegram can send messages and exchange photos, videos, stickers, audio and files of any type.

10. Plaintiff claims that as on April, 2020 Telegram had around 400 million monthly active users with atleast 1.5 million new users signing up every day.

11. Grievance of the plaintiff in the present suit is that the defendant No.1 grants access and permission to the users of the application to create various channels while not disclosing the identity of such users and in view of the absence of the identity being known, the plaintiff has impleaded them as defendant No.2. The said users of defendant No.1 have created channels with IDs: t.me/dainkjagran, t.me/dainikjagranhindi, t.me/dainikjagran_jnm, t.me/dainikjagranpdf, t.me/dainik_jagran, t.me/dainikjagran, t.me/DJagran, t.me/Dainik_Jagran_pdf, t.me/Fainik_Jagran_News, t.me/dainikja. On these channels the e-papers of the plaintiff are being uploaded in PDF format on daily basis and thus the defendant No.1 with the help of these channels are not only permitting availability of current editions of the e-paper but also users subscribing to the channels of defendant No.1 can download all the previous editions of the e-paper published in the past, which is otherwise available to a user only if he subscribes the e-paper subscription while visiting the website of the plaintiff.