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M/S. South India Beverages Pvt. Ltd. vs General Mills Marketing Inc. & Anr. on 13 October, 2014

In the decision reported as 2015 (61) PTC 231 South India Beverages Pvt. Ltd. v. General Mills Marketing Inc. this issue was addressed by a Division Bench of this 25 2016 SCC OnLine Del 5420 CS(COMM) 698/2023 Page 23 of 31 Signature Not Verified Digitally Signed By:BABLOO SHAH Signing Date:08.10.2024 16:17:42 Court with respect to same products i.e. ice cream. The rival marks under consideration were 'HAAGEN-DAZS' and 'D'DAAZS'. Propounding the rule of anti-dissection to contend that the respondent's mark 'HAAGENDAZS' should be viewed as an indivisible whole and when viewed in its entirety, it was not deceptively similar to the impugned trademark 'D'DAAZS', the rival argument was that 'DAZS' formed a prominent part of the trademark 'HAAGEN-DAZS' and therefore warranted protection against the impugned trademark. The Division Bench then referred to various judicial decisions and opined that the rule of anti-dissection essentially mandates that where the issue is of deceptive similarity between composite marks, the commercial impression of the mark as a whole needs to be considered for the reason the jurisprudence behind the anti-dissection rule was that the combination of the terms in its entirety and not its dissected elements constitute the distinctive mark.

Automatic Electric Limited vs R.K. Dgawan & Anr. on 6 January, 1999

26. Reliance is placed upon RN Gosain v. Yashpal Dhir, AIR20 and Automatic Electric Limited v. R. K. Dhawan21, wherein it has been held that a person cannot say at one time that a transaction is valid and thereby obtain some advantage, to which he could only be entitled on the footing that it is valid, and then turn around and say it is void for the purpose of securing some other advantage.
Delhi High Court Cites 11 - Cited by 93 - Full Document

Rhizome Distilleries P. Ltd & Ors. vs Pernod Ricard S.A. France & Ors. on 23 October, 2009

46. Lastly, reliance placed by the learned counsel for the defendants 28 2024: DHC: 2478 CS(COMM) 698/2023 Page 28 of 31 Signature Not Verified Digitally Signed By:BABLOO SHAH Signing Date:08.10.2024 16:17:42 upon Rhizome Distilleries P. Ltd & Ors. v. Pernod Ricard S.A. France & Ors. 29 is misplaced since the Court therein was dealing with a common dictionary word 'Imperial' whereas in the present case, this Court is called upon to adjudicate upon the two registered trademarks of the plaintiff 'NIMYLE' and 'JOR-POWR' as also the impugned mark of the defendants 'POWRNYM', which are coined words, not found in the dictionary coupled with the deceptively similar get-up/ trade dress thereof.
Delhi High Court Cites 8 - Cited by 42 - V Sen - Full Document

R.N. Gosain A vs Yashpal Dhir on 23 October, 1992

26. Reliance is placed upon RN Gosain v. Yashpal Dhir, AIR20 and Automatic Electric Limited v. R. K. Dhawan21, wherein it has been held that a person cannot say at one time that a transaction is valid and thereby obtain some advantage, to which he could only be entitled on the footing that it is valid, and then turn around and say it is void for the purpose of securing some other advantage.
Supreme Court of India Cites 7 - Cited by 281 - S C Agrawal - Full Document

M/S. Amar Singh Chawal Wala vs M/S. Shree Vardhman Rice & Genl. Mills on 29 May, 2009

14.9. The impugned mark 'POWRNYM' of the defendants is derivative of the registered trademarks 'NIMYLE' and 'JOR-POWR' belonging to the plaintiff since they have lifted 'POWR' from the registered trademark 'JOR-POWR' and 'NIM'/ 'NYM' (mis-spelled but having identical pronunciation) from the registered trademark 'NIMYLE' of the plaintiff. As such, the impugned mark 'POWRNYM' is deceptively similar. Further, the defendants have also dishonestly imitated the trade dress including the get-up, identical shape of bottle and label as that of the plaintiff's products under the registered trademark 'NIMYLE'. 14.10. Such an adoption by the defendants cannot be innocuous/ bona fide rather, is a deliberate act to ride upon the goodwill and reputation of the plaintiff's registered and well-known trademarks 'NIMYLE', 'JOR- POWR' and NIM family of marks and create an injurious association in the minds of consumers that the impugned mark is a latest entrant in the NIM family of marks. Reliance is placed upon Kaviraj Pandit Durga Dutt Sharma v. Navaratna Laboratories 8, Cadila Health Care Ltd. v. Cadila 8 AIR 1965 SC 980 CS(COMM) 698/2023 Page 9 of 31 Signature Not Verified Digitally Signed By:BABLOO SHAH Signing Date:08.10.2024 16:17:42 Pharmaceuticals Ltd. 9, Laxmikant Patel v. Chetanbhai Shah 10, Amar Singh Chawal v. Shri Vardhman Rice & Genl.

T.V. Venugopal vs Ushodaya Enterprises And Anr. on 29 December, 2000

In such a situation and in view of what has been held in BK Engineering v. UBHI Enterprises 14, TV Venugopal v. Ushodaya Enterprises 15 and Midas Hygiene v. Sudhir Bhatia 16, the defendants' use of the impugned trade dress enhances the risk of injurious association and confusion of the defendant's 'POWRNYM' floor cleaners with the plaintiff's goods under 'NIMYLE', 'JOR-POWR' and the NIM family of marks.
Andhra HC (Pre-Telangana) Cites 73 - Cited by 1 - Full Document

Midas Hygiene Industries P. Ltd. And ... vs Sudhir Bhatia And Ors. on 22 January, 2004

In such a situation and in view of what has been held in BK Engineering v. UBHI Enterprises 14, TV Venugopal v. Ushodaya Enterprises 15 and Midas Hygiene v. Sudhir Bhatia 16, the defendants' use of the impugned trade dress enhances the risk of injurious association and confusion of the defendant's 'POWRNYM' floor cleaners with the plaintiff's goods under 'NIMYLE', 'JOR-POWR' and the NIM family of marks.
Supreme Court of India Cites 1 - Cited by 411 - Full Document

Stiefel Laboratories, Inc & Anr vs Ajanta Pharma Ltd. on 1 July, 2014

The Division Bench then referred to the decision reported as 211 (2014) DLT 296 Stiefel Laborataries v. Ajanta Pharma Ltd. and therefrom extracted the rationale for the anti-dissection rule :'The rationale of the anti- dissection rule is based upon this assumption:'An average purchaser does not retain all the details of a mark, but rather the mental impression of the mark creates in its totality. It has been held to be a violation of the anti-dissection rule to focus upon the 'prominent' feature of a mark and decide likely confusion solely upon that feature, ignoring all other elements of the mark. Similarly, it is improper to find that one portion of a composite mark has no trademark significance, leading to a direct comparison between only that which remains.' In view of the aforesaid, the Division Bench opined that the principles of 'anti-dissection' and that of 'identification of 'dominant mark' are not antithetical to one another but are rather complimentary. It was held that the constituent elements may be viewed as a preliminary step in ultimately determining probable customer reaction to the conflicting composites as a whole. The Division Bench expounded that the rule of anti-dissection does not absolutely restrict consideration of the constituent elements of a composite mark and more significantly, where less than the entire trademark was appropriated amounting to infringement thereof, there would be no violation of the anti-dissection rule. Reliance was placed on the decision reported as 380 F.3d 1340 Re Chatam Int'l, Inc, where the Court held that the commercial impression created by the dominant part 'GASPAR' of the registered mark 'GASPAR'S ALE' was far more substantial than by its other part 'ALE and therefore the impugned mark 'JOSE GASPAR GOLD' was found to be deceptively similar to the registered mark. Reference was then made to decision reported as 405 F. Supp.
Delhi High Court Cites 16 - Cited by 22 - S Sachdeva - Full Document
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