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Louis Vuitton Malletier v/s Santosh

The case involves a lawsuit filed by Louis Vuitton Malletier, a French luxury fashion and leather goods company, against the defendants for trademark infringement, passing off, dilution, and other related claims. Louis Vuitton is known for its brand name and various trademarks, including the "Louis Vuitton" word mark, the "LV" logo, and the "Toile monogram" pattern. The plaintiff alleged that the defendants were manufacturing and selling counterfeit products bearing their registered trademarks, causing harm to their business and diluting their brand reputation.

Case Citation: CS(COMM) 635/2018
High Court of Delhi, New Delhi
Decision Date: April 18, 2023

Procedural History:
The plaintiff obtained an ex parte ad interim injunction in February 2018, restraining the defendants from using the plaintiff's trademarks. Local Commissioners were appointed to seize and inventory the infringing products. The injunction was subsequently confirmed in September 2018. The defendants failed to appear or file a written statement, leading to them being proceeded against ex parte. The plaintiff filed ex parte evidence, and the case proceeded to final adjudication.

Issues Presented:
  • Whether the defendants infringed the plaintiff's registered trademarks?
  • Whether the defendants engaged in passing off their goods as those of the plaintiff?
  • Whether the defendants' actions constituted dilution of the plaintiff's trademarks?
  • What relief, including permanent injunction, damages, and costs, should be granted to the plaintiff?
Rules of Law:
  • Indian Trademarks Act, 1999
  • Principles of trademark infringement, passing off, and dilution
  • Relevant case law on the protection of well-known trademarks and awarding damages

Analysis and Reasoning:
The court reviewed the evidence, including the plaintiff's affidavits and the reports of the Local Commissioners. It found that the plaintiff owned valid and subsisting registrations for its trademarks, which had acquired a reputation and were considered well-known. The court determined that the defendants had manufactured and sold counterfeit products bearing the plaintiff's trademarks, constituting trademark infringement, passing off, and dilution. The defendants' actions were deemed intentional and without any plausible explanation.

Holding and Decision:
The court decreed in favor of the plaintiff, granting a permanent injunction against the defendants from using the plaintiff's trademarks. It awarded damages of Rs. 1,50,000 to be paid by defendants no. 1 and 2 and damages of Rs. 3,50,000 to be paid by defendant no. 3. The court also awarded costs to the plaintiff, amounting to Rs. 9,59,413, to be paid by the defendants.

Implications and Significance:
The decision reinforces the protection of well-known trademarks and highlights the consequences for infringers. It emphasizes the importance of enforcing intellectual property rights and provides a deterrent against counterfeiting activities. The case serves as a precedent for future trademark infringement cases, particularly involving luxury brands.

The High Court of Delhi granted a permanent injunction, awarded damages, and ordered the defendants to pay costs to Louis Vuitton Malletier in a trademark infringement case. The court found the defendants guilty of infringing the plaintiff's trademarks, passing off, and dilution. The judgment reaffirms the protection of well-known trademarks and demonstrates the court's commitment to safeguarding intellectual property rights.

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