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11. The business model of the Company is unique inasmuch as it sells Ayurveda related products and courses using only online platforms to consumers primarily located outside India. It sells the products only on its own website/domain http: / /theavurvedaexperience.com/ which is run via Shopify, a web based ecommerce store. For this purpose, the Plaintiff herein had made large monetary investments on various online platforms including the social networking site Facebook, in order to target a range of customized set of individuals, who would then be shown specific advertisements tailormade for that category of individuals, in order to then induce such individuals to click on advertisements, thereby leading to the website of the Plaintiff, in which such individual would voluntarily provide details to the Plaintiffs, if s/he chooses to purchase the product. Such data was provided to the Plaintiffs voluntarily and with the conscious knowledge that the sharing of such information was protected by terms and conditions available on the website of the Plaintiffs, particularly the privacy policy, the Plaintiffs proposed to adopt. Therefore, any proposed violation could open the Plaintiffs to potential harm including, but not limited to legal recourse against the Plaintiffs. Such details were parted with by the individuals/ proposed customers in line with the privacy policy available on the website of the Plaintiffs, and any violation of such policy/unauthorized access / use of data could lead to potential harm. As such, the Plaintiffs obtained and established a niche customer database, which in itself has enormous spring-boarding effect. The decision to undertake expenditure to obtain details of a particular kind of audience who is then targeted, is premised upon in-depth analytical research conducted by the Plaintiffs in order to ensure that marketing is only done for audiences who become profitable in the long term. Upon establishing its target audience, the Plaintiffs spend capital to be able to obtain access to such target audience through websites such as Facebook. The Plaintiff then uses engaging and innovative advertisements developed using skill and judgment, which are also tailor-made for different categories of such target audiences, in order to ensure a higher click to conversion rate. For instance, a lady who is in her fifties and who enjoys Starbucks coffee would be shown a specific set of catchwords, with a specific going to Fitness First gymnasiums. Such customers are then induced to click on the advertisement that leads to the website of the Plaintiffs, showcased the appropriate products (which may be most relevant to them) through copyrighted creative content, subsequent to which they voluntarily provide their personal information, while purchasing the product. Such personal information includes data such as their names, e-mail addresses, home/office address, and phone numbers. It is pertinent to note that each product has a different set of copyrighted creatives, and in many cases audiences used to promote such product. Both such creatives and selection of specific audiences are continuously optimized by a team of professionals employed by the Plaintiffs, to achieve the most optimal return on advertising spend/ reduce customer acquisition cost, and therefore requires application of significant skill and judgment for adapting strategy and operations to such processes which are. constantly evolving. The copyrighted customer data received post the completion of several manual and online creative processes developed over a substantial period of time is only generated upon the customer undertaking a purchase transaction. As such, the Plaintiffs only obtain the information after twice exercising their unique skill, judgment, and substantial statistical research - first to decide which persons to show advertisements to; and second to design specific advertisements for a specific product for such persons, which would then induce them to visit the webpage of such chosen product on the website of the Plaintiff. Lastly, the website of the Plaintiff No. 1 also contains copyrighted material which then sets the pitch for proposed customers to and make a purchase decision, and thereby provide the above-mentioned data to the Plaintiffs. Such development of material, including the database of customers is not just on the basis of labour or capital having been expended, but is clearly the result of skill and judgment of the Director and certain other employees of the Plaintiffs, which cannot be characterized as purely mechanical. Moreover, taking several granular advertising investment decisions on the basis of the cookie-data, and other analytical data obtained by the Plaintiff is also a part of its sophisticated marketing methods. In this regard, the Plaintiffs have invested substantial capital, labour, and time in order to test over 1900 such audiences to perfect their ability to predict fruitful advertising targets. It has come to the knowledge of the Plaintiff that the Defendant Nos. 1 & 2 through the Defendant No.3 have been illegally spamming the customers of the Plaintiffs. It is on account of trying to reach the appropriate targeted markets/ customers that the Plaintiff expends huge expenditure to obtain a targeted database. However, by accessing, and stealing such customer database of the Plaintiff No. 1 in a wholly unauthorized and illegal manner, the Defendants No.l and 2 have obtained a Ayurveda products without having to spend any amount of money, and without exercising even a modicum of skill and judgment. Further, the Plaintiffs have spent over Rs. 28 Crore (Rupees Twenty-Eight Crore only) in order to obtain information which is/has been being illegally used by the Defendants Nd.l and 3.