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7. It is stated that ice creams and related products bearing the NATURAL Family Marks are sold through franchised ice cream parlors located in several places across India on an extensive basis. It is stated that the Plaintiffs have a large network of over 130 franchised ice cream parlors in several places across India selling goods and rendering services under the NATURAL Family Marks. It is stated that for the period between December 2017 and May 2021 the Plaintiffs received more than one lakh enquires through their website for grant of a franchise. The franchisees of the Plaintiffs (i) use the NATURAL Family Marks (ii) sell ice creams and allied/ ancillary products and render services including retailing and ice cream parlor services under/ bearing the NATURAL Family Marks (iii) use signage, menu cards/ rate cards, packaging material and uniforms bearing the NATURAL Family Marks (iv) carry on activities as per Plaintiffs' business format; so as to indicate and suggest to the 910-ial-4383-2022.doc public at large that they are authorized franchisees of the Plaintiffs. It is stated that the Plaintiffs' ice cream parlors are popularly known as NATURAL or NATURALS ice cream parlors. Statements of the Plaintiff's annual approximate turnover and promotional expenses for the years 1994 to 2021 are at paragraphs 19 and 21 of the Plaint. A statement setting out the quantity of ice creams bearing the NATURAL Family Marks manufactured and sold by the Plaintiffs to their NATURAL franchisees from 2014-2021 is at paragraph 16 of the Plaint. A perusal of the statement shows that in the years 2018-2019 and 2019-2020 the Plaintiffs sold over 47 Lakh kilos of ice cream each year. Plaintiffs' Auditor's Certifcate in support of the statement is at Exhibit J to the Plaint. It is stated that the Plaintiffs' goods bearing the NATURAL Family Marks have a presence and are extensively sold through online platforms such as Swiggy, Zomato, Thrive and Amazon.

10. Mr. Kamod submits that in December 2021, the Plaintiffs learnt that the Defendant Nos. 1 to 4 are offering their ice creams under the impugned trade mark "Mooow NATURALS" / "Natural Icecreams Mow" in Andhra Pradesh on 910-ial-4383-2022.doc Defendant Nos. 5 and 6's online platforms viz. Zomato and Swiggy, respectively. Printouts of extracts from Defendant Nos. 5 and 6's online platforms showing the Defendant Nos. 1 to 4's listing bearing the impugned "Mooow NATURALS" and "Natural Icecreams Mow" trade marks are at Exhibits KK and LL to the Plaint. Printout of a receipt dated 6th December 2021 issued by the Defendant No. 5's platform for an order placed on the Defendant Nos. 1 to 4 is at Exhibit MM to the Plaint. Photograph of the Defendant's ice-cream up and carry bag bearing the impugned "Mooow NATURALS" trade mark are Exhibits NN Colly and OO to the Plaint, respectively. It is stated that Defendant Nos. 1 to 3 are jointly manufacturing and selling the impugned products. The packaging of the impugned product states that Defendant No.3 is the manufacturer and marketer of the impugned product. A perusal of the online records in respect of the FSSAI License numbers shown on the Defendants' impugned product and their listing on Zomato shows that Defendant No.3 is a proprietary concern of Defendant No.1. The extracts also show the involvement of Defendant No.2. Online MCA records show that Defendant No.1 is a Director of Defendant No.2 and the offcial email address of Defendant No.2 viz. [email protected], which email 910-ial-4383-2022.doc address is also printed on the packaging of the impugned product. Extracts from the offcial FSSAI website in respect of FSSAI License Nos. 11220333001469, 10117009000080 and 10121009000002 are at Exhibits PP-1, PP-2 and PP-3 to the Plaint, respectively. Extract from the offcial MCA website in respect of Defendant No.2 is at Exhibit QQ to the Plaint. The receipt issued by Defendant No.5 for the impugned product shows that the Defendant No. 4 is supplying the impugned products. It is stated that Defendant No. 4 is connected with or controlled by Defendant No.1. An extract from the Defendants' Facebook showing the mark "Mooow Natural Icecreams is at Exhibit RR to the Plaint. It is stated that the Defendants domain name www.mooownaturals.com is not functional / is dormant.