SEKAR REPORTER

Court News from Madras High Court

O.A.Nos.440 to 443 of 2022 in C.S.(Comm.Div) No.150 of 2022 SENTHILKUMAR RAMAMOORTHY,J trademarks “THALAPPAKATTI” and “THALAPPAKATTI BRIYANI HOTEL” from 1957 and has obtained registrations in respect thereof under class 42 and class 43. It is further stated that the mark was declared as a well known trademark on 22.09.2010. The present action is directed against the video uploaded by the third defendant. After playing the video, learned counsel asserts that the said video tarnishes the reputation of the plaintiff’s trademark and is defamatory.  He also points out that the video was uploaded on YouTube and Facebook and that it has had 1.2 million views as evidenced by the document at page 59 of the typed set of papers.

by ·

I

O.A.Nos.440 to 443 of 2022 in

C.S.(Comm.Div) No.150 of 2022

SENTHILKUMAR RAMAMOORTHY,J

In a suit for alleged trademark infringement, the plaintiff has

presented four Original Applications.

  1. Learned counsel for the plaintiff asserts that the plaintiff has

used the trademarks “THALAPPAKATTI” and “THALAPPAKATTI BRIYANI HOTEL” from 1957 and has obtained registrations in respect thereof under class 42 and class 43. It is further stated that the mark was declared as a well known trademark on 22.09.2010. The present action is directed against the video uploaded by the third defendant. After playing the video, learned counsel asserts that the said video tarnishes the reputation of the plaintiff’s trademark and is defamatory.  He also points out that the video was uploaded on YouTube and Facebook and that it has had 1.2 million views as evidenced by the document at page 59 of the typed set of papers.

  1. On examining the material documents and on viewing the

video, the said video  prima facie appears to tarnish the reputation of the

https://www.mhc.tn.gov.in/judis

Page No.1/2

SENTHILKUMAR RAMAMOORTHY,J

kal

plaintiff and its trademark inasmuch as it does not appear prima facie to be within the bounds of fair comment by a food reviewer. Assertions of fact and not opinion are made without indicating a rational basis. Therefore, an order of interim injunction is granted restraining the respondents from  broadcasting  the  impugned video  through the URL indicated or otherwise. The said interim order shall operate for a period of two weeks from the date of receipt of a copy of this order.
  1. Issue notice to the respondents returnable by 17.08.2022.

Private notice is also permitted. The applicant/plaintiff shall comply with Order XXXIX Rule 3 CPC.

List on 17.08.2022.

02.08.2022

kal

O.A.Nos.440 to 443 of 2022 in C.S.(Comm.Div) No.150 of 2022

https://www.mhc.tn.gov.in/judis

Page No.2/2

 

 

 

 

N THE HIGH COURT OF JUDICATURE AT MADRAS

(Ordinary Original Civil Jurisdiction)

C.S. (Com. Div.) No.             of 2022

 

M/s. Thalappakatti Naidu Anandha Vilas Biriyani Hotel,

Represented by its authorized signatory,

  1. Kamesh (M – 42 years),

Having its branch office at Flat No. B3,

New No. 17, Old No. 18A, 11thStreet,

Nandanam Extension, Chennai – 600 035                                                                                      … Plaintiff

 

-VS-

 

1) Youtube,

Google LLC,

Unit No. 26, The Executive Center,

Level 8, DLF Centre, Sanad Marg,

Connaught Place, New Delhi – 110001

 

2) Facebook Inc,

One BKC Bandra Kurla Complex,

Bandra East, Mumbai – 400 051

 

3) Mrs. Faiza,

W/o. Kadhar Sulaimaan,

No. 504, Housing Board Phase – I,

Thirupattur – 635 601                                                          … Defendants

 

PLAINT UNDER ORDER VII RULE 1 OF CPC READ WITH ORDER

IV RULE 1 OF HIGH COURT O.S. RULES AND SECTION 134 AND

SECTION 135 OF THE TRADE MARKS ACT, 1999

 

The Plaintiff above named respectfully submits as follows:-

 

  1. The Plaintiff is M/s. Thalappakatti Naidu Anandha Vilas Biriyani Hotel, represented by its Authorised Signatory, V. Kamesh, having registered office at No. 15, East Car Street, Dindigul – 624 001 and its branch office at Flat No. B3, New No. 17, Old No. 18A, 11th Street, Nandanam Extension, Chennai – 600 035.

 

  1. The address for the purpose of service of notices and processes on
    the Plaintiff is that of its Counsel M/s. Vijayan Subramanaian,
    V. Bhaskar, A. Murali, Roshini R and Preetha Natarajan, Advocates, having their office at No. 17, Lakshmi Street, New Avadi Road, Kilpauk, Chennai – 600 010.

 

  1. The First Defendant is Youtube, Google LLC, at Unit No. 26,
    The Executive Center, Level 8, DLF Centre, Sanad Marg, Connaught Place, New Delhi – 110 001.The suit summons may be served on the
    First Defendant through the District Courts Patiala House, New Delhi.

 

  1. The Second Defendant is Facebook Inc, One BKC Bandra Kurla Complex, Bandra East, Mumbai – 400 051.The suit summons may be served on the First Defendant through the Metropolitan Magistrate Court, Mumbai.

 

  1. The Third Defendant is Faiza, W/o. Kadhar Sulaimaan, No. 504, Housing Board Phase – I, Thirupattur – 635 601. The suit summons may be served on the Third Defendant through the Magistrate Court, Thirupattur.

 

  1. The Plaintiff submits that originally during 1957, Mr. P. Nagasamy Naidu alias THALAPPAKATTI NAIDU, commenced hotel business, particularly in preparation and serving of Biriyani at Dindigul town.
    The said Mr. Nagasamy Naidu sported a THALAPPA (head gear)
    in his head and was referred to as THALAPPAKATTI NAIDU and the hotel by reference to his pet name, is being named as Thalappakatti Naidu Anandha Vilas Biriyani hotel. The business has acquired enormous popularity for the extraordinary quality and unique flavor
    and taste, particularly in preparation of Biriyani by the name THALAPPAKATTI Biriyani.

 

  1. The Plaintiff submits that the food preparations made and served in Thalappakatti Biriyani Hotel has acquired enormous popularity throughout Tamil Nadu and other states by virtue of extensive tourist flow through the Dindigul Town as it is the transit point for Kodaikanal hill and temple town Madurai and business travelers.

 

  1. It is respectfully submitted that even during the lifetime of P. Nagasamy Naidu and subsequently, there was extensive articles published about
    the special and unique preparations found in the hotels run by the Plaintiff and their predecessors.

 

  1. The trademark and trading style Thalappakatti Biriyani Hotel has acquired the secondary meaning to denote and connote the product
    of the Plaintiff which assures to the public a unique taste and standard in the food preparations. The various articles published in several
    Tamil magazines would brief and establish the high popularity of
    the name Thalappakatti Biriyani and the products prepared and served in the Thalappakatti Biriyani Hotels run by the Plaintiff. In fact, the popularity is so vast that the said name was also being referred in several Tamil feature films as a landmark place for quality food.

 

Details of few films in which the name of “Thalappakatti Biriyani Hotel” had been referred:

 

S. No. Film
1. Kumbakarathangaiyaa (1991)
2. Andhapuram (1999)
3. April Madhathil (2003)

 

4. Red (2002)
5. Kutthu (2004)
6. Biriyani (2013)
7. Chennai 600028 (2016)

 

  1. It is submitted that all the above mentioned movies are released long back and the name Thalappakatti is so popular that it has become the household name throughout South India and there is extensive reference to this name even in TV shows and chat shows. Thalappakatti Biriyani for the common man refers to the unique taste and quality. The Plaintiff is maintaining the unique taste and quality by meticulous efforts.

 

  1. The Plaintiff has also taken steps to protect the trademark and trading
    style by applying for registration of the trademark and trading style ‘THALAPPAKATTI BIRIYANI HOTEL’. It is submitted that the Deputy Registrar of Trade Marks, Government of India, Chennai vide order dated 22/09/2010, has directed the registration of the trade mark of ‘THALAPPAKATTI BIRIYANI HOTEL’ of the Plaintiff and Application No. 1408388 of the Plaintiff was allowed. It is submitted that the Trade Mark registry has issued the certificate of registration on 23/09/2010.

 

  1. It is pertinent to mention here that the mark of the Plaintiff has
    been declared as “WELL KNOWN TRADEMARK” by the Deputy Registrar of Trade Marks, Government of India, Chennai vide order dated 22/09/2010.

 

  1. The Plaintiff submits that he is planning to open branches all over the world and the Plaintiff having branches all over the world including Singapore, Dubai, MALAYSIA USA, FRANCE and Sri Lanka and has Restaurants in all over Tamil Nadu, Pondicherry, Karnataka, Kerala and currently have 96 restaurants in the name Thalappakatti.

 

  1. The details of the restaurant run by the Plaintiff are mentioned below;

 

SL. NO. LOCATION
1. Anna Nagar
Nungambakkam
T.Nagar
Velachery
Parrys
Besant Nagar
Ashok Nagar
Ramavaram
OMR
Medavakkam
Tambaram
Mount Road
Mogappair
Poonamallee
Guindy
Valasaravakkam
Kanchipuram
Shanthi Colony
Camp Road, Selaiyur
Chrompet
Vandalur
Perambur
Ambattur
Navalur
Central
Perungudi
Padur
Redhills
ECR

 

 Ambur
Vellore
Pondicherry
Ulundurpet
Kattukuppam/ Cuddalore
Periyamudaliyar Chavadi
Nagercoil
Dindigul – I Manikundu
Bathalagundu
Dindigul – II RS ROAD
Oddanchatram
Karur
Madurai
DGL-Bye Pass
Theni
Kalavasal
Dharapuram
Palani
Trichy
Tirunavelli
Virudnagar
Senthai Pettai
Bathalagundu- II
Anna Nagar
Indira Nagar
MG Road
HSR Layout
Jayanagar
Marathahalli
Brigade Road
Kamanahalli
Kudlu Gate

 

 Madiwala
Sarjapur
Mahadevpura
Hosur
Uttarahalli
Yelahanka
RR Nagar
New Bel Road
Basaweswara Nagar
RMZ
Forum Mall
Arekere
Electronic City
Whitefield
Coimbatore
Tiruppur
Neelambur
Fun Extreme
Udumalpet
Pallakad
Singanallur
Sundarapuram
Erode
Coimbatore
Kalamaserry
Trivandrum
Lulu Trivandrum
MG Road Trivandrum
Lulu Cochin
France
USA
Singapore

 

 Malaysia
Dubai
Sri Lanka

 

  1. It is very clear from the above paras, the Plaintiff is running a well-known restaurant all over the world. The Plaintiff’s restaurant named Thalappakatti is well-known in keeping high standards and traditional taste which has been passed on to them by their ancestors since 1957.

 

  1. While so the Plaintiff saw a defamatory video uploaded by the Third Defendant in her channel named “KAYAL SAMAYAL” and posted in the First and Second Defendants platform. The heading of the video in Tamil is mentioned as “,dp BoardI ghh;j;J VkhwhjPh;fs;!! Dindigul Thalappakatti Restaurant” and with a caption “DON’T WASTE YOUR TIME” and showing the restaurant’s name board.

 

  1. The Third Defendant in the video states as follows:

 

  1. a) The Third Defendant directing someone to remove menu board kept in the entrance of the Plaintiff restaurant

 

  1. b) The video continues to show the entire site of the Plaintiff restaurant and the name board THALAPPAKATTI.

 

  1. c) The Third Defendant starts to give a statement saying that two years before she had food in the Batlagundu branch of the plaintiff restaurant namely Thalappakatti and the food served at the restaurant were worst.

 

  1. d) The Third Defendant continues to say that once again after two years she visited the Plaintiff’s restaurant today at Batlagundu and she continues to make defamatory statements against THALAPPAKATTI restaurant.
  2. e) The Third Defendant continues to say that 10 years before the taste of the food served in the Plaintiff’s hotel at Chennai was good.

 

  1. f) The Third Defendant continues to say that the Plaintiff has opened the restaurant nook and corner and she was not able to bear the atrocity (ml;lfhrk;) of the Plaintiff.

 

  1. g) The Third Defendant continues to say that she is not aware on what basis the management employs their staffs and the staffs does not have any knowledge about the restaurant.

 

  1. h) The Third Defendant continues to say that she waited for 20 minutes and the staff came and informed her that only biryani is available and Third Defendant say that her time was wasted.

 

  1. i) The Third Defendant continues to say that this kind of service in the Plaintiff restaurant THALAPPAKATTI will continue forever and request the viewer’s not to waste their time.

 

  1. The Third Defendant has also taken to the Social Media like
    Facebook, Whatsapp, YouTube, etc. to cause wide publicity to the unsubstantiated allegations. The Third Defendant uploaded the said
    video in her channel named KAYAL SAMAYAL on 30/05/2022 in
    the First Defendant YouTube platform and the link of the YouTube
    is https://youtu.be/IZ5L8HsGRW0and the said video is viewed in the
    First Defendant’s platform by more than 4,000viewers.

 

  1. The Third Defendant uploaded the said video in her channel named KAYAL SAMAYAL in the Second Defendant Facebook page named
    KAYAL SAMAYAL on 04/06/2022 and the link of the page in Facebook is https://fb.watch/dl6xucDW6l/and the said video is viewed in
    the Second Defendant’s page by more than 14,512 viewers as on date.
    The comments made by the public is attached in the typeset of papers.

 

  1. It is submitted that the Third Defendant entered the Plaintiff’s restaurant at 41pm on 29/05/2022. The Third Defendant enquired about the menu and she directed the waiter that the food items ordered by her to be delivered within 5 minutes of time. The waiter said all the items are available and informed her it will take 10 to 15 minutes to be delivered. The Third Defendant wanted to meet the manager of the restaurant and the manager met her and enquired about her queries.

 

  1. The Third Defendant informed the manager she is a famous YouTube blogger and complained that the waiter informed her that the food cannot be delivered in 5 minutes. The manager politely informed the Third Defendant the food will be delivered as soon as possible but she went out of the restaurant at 6.01 pm and started taking the impugned video outside the restaurant.

 

  1. It is submitted that it is totally false to state that the restaurant did not have any items except kushka as alleged by the Third Defendant in her impugned video. All the items were available and other customers had food of various items all day including 5.42 pm to 8.30 pm.
    The various bills attached in the typeset will clearly shows that the Third Defendant’s statement is absolutely false.

 

  1. The Third Defendant’s video amounts to defame the Plaintiff restaurant’s reputation by making false, frivolous and malicious statements against the Plaintiff’s restaurant. The Third Defendant has uploaded the video in First and Second Defendants platform with malicious intentions of gaining popularity and personal gain. The video contains false and slanderous propaganda against the Plaintiff’s restaurant. The video and other statements in the video is a calculated attempt to cause loss and create an atmosphere of hatred against the Plaintiff’s restaurant in the minds of the general public.

 

 

  1. The Third Defendant’s impugned video is a targeted attack directed against the Plaintiff’s restaurant with an attempt to attract more viewers towards her video. The video as a whole is disparaging and denigrating in nature. It is submitted that the Third Defendant’s YouTube channel and her Facebook page “KAYAL SAMAYAL” is her only source of revenue and that the Impugned Video was also therefore a part of her occupation calling and created in the course of her trade.

 

  1. The Third Defendant’s Impugned Video is uploaded with a solely commercial purpose of generating revenue. The Third Defendant for her monetary gain is attacking the reputation of the Plaintiff’s restaurant in an attempt to attract more viewers to her YouTube channel / Facebook page and thereafter divert such viewer to various other videos uploaded by the Third Defendant. The Third Defendant cannot assert a fundamental right to abuse the Plaintiff’s restaurant by making false / malicious allegations against it to gain monetary benefit.

 

  1. It is submitted that with the advent of internet and social media platforms like Facebook, YouTube, WhatsApp and Twitter, there has been increasing trend whereby several videos like the Impugned Video are being created in the garb of providing a review of products / brands available in the market where brand images are being used without authorization, reckless statements are made in respect of such brands under the garb of freedom of speech and expression without due regard to the reasonable restrictions thereon with a view to target maximum views for the videos so posted on such social media sites and to make unfair gains on the basis of the views generated.

 

  1. It is submitted that the Plaintiff requested the Third Defendant to cease and desist from publishing or in any manner communicating the Impugned Video to the public and calling upon her to remove the Impugned Video from social media sites including her Facebook page and her YouTube channel. The Third Defendant refused to comply with the aforesaid request of the Plaintiff.
  2. It is submitted that the language used in the social media videos will have the effect of irreparably damaging the reputation of the Plaintiff’s restaurant and damages alone will not be an adequate remedy.
    The Plaintiff now has reliable information that the Third Defendant is taking steps to upload and telecast in all other social media platforms and convey the same allegations in the form of interviews and other mode. If the Third Defendant is not restrained, the Plaintiff’s restaurant will be put to irreparable loss, mental agony and prejudice.

 

  1. It is submitted that Section 29 (8) of the Trademarks Act, 1999 states as follows;

 

29 (8) – A registered trade mark is infringed by any advertising of that trade mark if such advertising

 

(a) takes unfair advantage of and is contrary to honest practices in industrial or commercial matters; or

 

(b) is detrimental to its distinctive character; or

 

(c) is against the reputation of the trade mark.

 

  1. It is very clear from Section 29 (8) of the Trademarks Act, 1999 that the Third Defendant has infringed the Plaintiff’s trademark “THALAPPAKATTI”. The Plaintiff is entitled to get a relief against the Third Defendant for infringing the Plaintiff’s trademark “THALAPPAKATTI”.

 

  1. The Plaintiff is entitled to get a decree of permanent injunction restraining the defendant from continuing publishing/telecasting the impugned advertisement. Unless this Hon’ble Court grants a permanent injunction restraining the defendant from the said offending activities, the Plaintiff and they would suffer irreparable loss, hardship and damages, which cannot be compensated in pecuniary terms.

 

  1. The cause of action for the present suit arose when the Third Defendant uploaded the impugned video on 30/05/2022 in her YouTube channel and her Facebook page on 04/06/2022 and the video was viewed by the public through First Defendant YouTube channel and the Second Defendant’s Facebook page and when the public started enquiries about the videos in the branches of the Plaintiff’s restaurant named THALAPPKATTI and the First Defendant’s YouTube’s platform URL https://youtu.be/IZ5L8HsGRW0and the Second Defendant Facebook page URL https://fb.watch/dl6xucDW6l/which is accessible all over the world including the city of Chennai within the jurisdiction of this Hon’ble Court. The cause of action continues to arise everyday as the Third Defendant would continue to telecast the said video until the defendant is restrained by an order of this Hon’ble Court.

 

  1. The Plaintiff states that the present suit is for a suit for Trade Mark infringement and the same is maintainable before this court, by virtue of first proviso to Section 7 of the commercial courts Act, 2016 read with Section 134 and Section 135 of the TRADE MARKS ACT, 1999 and this Hon’ble Court has jurisdiction to entertain the present suit.

 

  1. The Commercial Division of this Hon’ble Court has got jurisdiction to entertain and try this suit. The subject matter of the suit is infringement of trademark and other Consequential Reliefs. Therefore, it is a commercial dispute under Section 2(1)(c)(17) of the Commercial Courts, Commercial Division and Commercial Appellate Division of High Courts Act, 2015. The suit has to be field before a Court not Inferior to a District Court under the provisions of Section 134(1)(a) & 134(1)(c) of the Trademarks act, 1999. In view of this statutory mandate, the suit falls within the ambit of section 7 provisos (1) of the Commercial Courts, Commercial Division and Commercial Appellate Division of High Courts Act, 2015. Therefore, this suit may be heard and disposed off by the Commercial Division of the Hon’ble High Court of Madras.

 

  1. The Plaintiff values the suit for the purpose of the court fee for each prayer (i) to (iv) value of each prayer is Rs. 2000/- and the total value Rs. 8000/- each prayer court fee Rs. 60/- and the total court fees paid Rs. 240/- under Section 27(b) and the Plaintiff’s value relief claimed in prayer 36 (e) at Rs. 25,00,000/- and pays court fee of Rs. 75,000/- under Section 35 of Tamil Nadu court fee act r/w Appendix 1A of High Court  Fee rules.

 

  1. The Plaintiff, therefore, prays that this Hon’ble Court maybe pleased grant a decree and judgment on the following prayers: –

 

  1. Granting a permanent injunction restraining the 3rd Defendant, their men, servants, agents or anyone claiming through or under them from in any manner Infringing the Plaintiff Trade Mark and Trading style “Thalappakatti Biriyani Hotel” by continuing and uploading the Impugned Video using any URL on the YouTube platform or through any other social media platform for defaming the Plaintiff’s restaurant named “THALAPPAKATTI” and direct the Third Defendant to take down or remove the Impugned Video.

 

  1. Grant an order of permanent injunction restraining the First Defendant his employees, representatives, agents and all other persons claiming under him or acting in concert with him or on his behalf or acting on his instructions from continuing or uploading the impugned video and to take down / remove and / or block / restrict access to the Impugned Video from the URL https://youtu.be/IZ5L8HsGRW0 or any other URL on the YouTube platform defaming the Plaintiff’s restaurant named “THALAPPAKATTI”.

 

 

  1. Grant an order of permanent injunction restraining the Second Defendant his employees, representatives, agents and all other persons claiming under him or acting in concert with him or on his behalf or acting on his instructions from continuing or uploading the impugned video and to take down / remove and / or block / restrict access to the Impugned Video from the URL
    https://fb.watch/dl6xucDW6l/ or any other URL on the Facebook page defaming the Plaintiff’s restaurant named “THALAPPAKATTI”.

 

 

  1. grant an order of permanent injunction, restraining the Third Defendant and their men and agents or any other persons claiming through them, from in any manner, continuing or uploading the impugned video and uploading any further defamatory videos, articles, statements, photos or caricatures insinuating the reputation of the Plaintiff’s restaurant named “THALAPPAKATTI” and in any manner by holding any press meet, releasing or distributing any statement to the Print and Electronic Media any messages, videos, in Facebook, Twitter, YouTube, WhatsApp and other websites and all other forms of online videos/messages pending disposal of the above suit.

 

  1. The Third Defendant be ordered to pay a sum of Rs. 25,00,000/- towards damages for defaming the Plaintiff’s restaurant named “THALAPPAKATTI”;

 

  1. For costs of the suit; and

 

  1. Pass such further or other orders as this Hon’ble Court may deem fit and proper in the circumstance of the case and thus render Justice.

 

 

Dated at Chennai on this the 25th day of June 2022

 

 

COUNSEL FOR PLAINTIFF                                                          PLAINTIFF

 

 

 

VERIFICATION

 

I, V. Kamesh son of R. Venkatachalam, Authorised Signatory of the Plaintiff Hotel, hereby verify that what are stated above Para 1 to 32 of this plaint are true to the best of my knowledge, belief and information.

 

Verified at Chennai on this the 25th day of June 2022

 

 

PLAINTIFF

 

LIST OF DOCUMENTS FILED UNDER ORDER XI RULE 1 OF C.P.C

AS AMENDED ACT 4 OF 2016.

 

S. No. Date Description of Documents Remarks
23/09/2010 Trade Mark Registration Certificate No. 1408388 for the Plaintiff’s hotel Photo Copy
07/08/2014 Trademark Registration Certificate No. 1998652 for the Plaintiff’s hotel Photo Copy
28/06/2019 Board Resolution passed by the Plaintiff Photo Copy
29/05/2022 CCTV footage taken from Plaintiff’s restaurant Photo Copy
29/05/2022 Various bills showing the food items sold at the Plaintiff’s restaurant from 5.42 pm to 8.30 pm Photo Copy
30/05/2022 Thumbnail photo of the video uploaded by the Third Defendant in her channel named KAYAL SAMAYAL in the First Defendant YouTube platform Photo Copy
30/05/2022 Photos taken from the video uploaded by the Third Defendant in her channel named KAYAL SAMAYAL in the First Defendant YouTube platform Photo Copy

 

 – Comments posted by the public in the First Defendant YouTube platform Photo Copy
04/06/2022 Thumbnail photo of the video uploaded by the Third Defendant in her page named KAYAL SAMAYAL in the Second Defendant Facebook blog Photo Copy
04/06/2022 Photos taken from the video uploaded by the Third Defendant in her channel named KAYAL SAMAYAL in the Second Defendant Facebook blog. Photo Copy
– Comments posted by the public in the Second Defendant Facebook page Photo Copy

 

LIST OF MATERIAL OBJECTS

 

  1. O. – 1 – Pendrive containing the impugned video of the Third Defendant uploaded in First and Second Defendant platforms.

 

Dated at Chennai on this the 25th day of June 2022

 

 

COUNSEL FOR PLAINTIFF                                                          PLAINTIFF

 

LIST OF DOCUMENTS RELIED UPON BY THE PLAINITIFF
UNDER ORDER VII RULE 14 (2) CPC

 

Nil at present.

 

Dated at Chennai on this the 25th day of June 2022

 

 

COUNSEL FOR PLAINTIFF                                                          PLAINTIFF

 

 

 

 

VERIFICATION

 

I, V. Kamesh son of R. Venkatachalam, Authorised Signatory of the Plaintiff Hotel, do hereby declare that the above listed documents are true to my knowledge and information and I believe the same to be true.

 

Verified at Chennai on this the 25th day of June 2022

 

 

 

PLAINTIFF

 

STATEMENT OF ADDRESS FOR SERVICE FILED UNDER
ORDER VI RULE 14 (A) CPC
Plaintiff

 

 

 

 

 

 

 

Address for Service

 

 M/s. Thalappakatti Naidu Anandha Vilas Biriyani Hotel,

Represented by its authorized signatory,

V. Kamesh (M – 42 years),

Having its branch office at Flat No. B3,

New No. 17, Old No. 18A, 11th Street,

Nandanam Extension, Chennai – 600 035

 

M/s. Vijayan Subramanaian,
M.V. Bhaskar, A. Murali, Roshini R and Preetha Natarajan, Advocates, having their office at No. 17, Lakshmi Street, New Avadi Road, Kilpauk, Chennai – 10

 
Defendants
  1. Youtube,

Google LLC,

Unit No. 26, The Executive Center,

Level 8, DLF Centre, Sanad Marg,

Connaught Place, New Delhi – 110 001

 

 

2. Facebook Inc,

One BKC Bandra Kurla Complex,

Bandra East, Mumbai – 400 051

 

3. Mrs. Faiza,

W/o. Kadhar Sulaimaan,

No. 504, Housing Board Phase – I,

Thirupattur – 635 601
Address for service Same as stated above.

 

Dated at Chennai on this the 25th day of June 2022

 

 

COUNSEL FOR PLAINTIFF                                                          PLAINTIFF

 

VERIFICATION

 

I, V. Kamesh son of R. Venkatachalam, Authorised Signatory of the Plaintiff Hotel, do hereby declare and state that what is stated in the foregoing statement of address to the best of my knowledge, belief and information.

 

Verified at Chennai on this the 25th day of June 2022

 

 

           PLAINTIFF

 

 

 

 

 

MEMO OF VALUATION UNDER ORDER VII RULE 1 (i) OF CPC

 

Sl. No. Prayer Number Value for the purpose of Court fee (in Rupees) Court Fee paid thereon
(in Rupees)		 Under TN Court Fees and Suits Valuation Act, 1957
1 Prayer (i) 2000              60 Sec. 27(b)
2 Prayer (ii) 2000              60 Sec. 27(b)
2 Prayer (iii) 2000 60 Sec. 27(b)
3 Prayer (iv) 2000 60 Sec. 27(b)
4 Prayer (v) 25,00,000 75,000 Sec. 35
  Total 25,06,000 75,180  

 

Dated at Chennai on this the 25th day of June 2022

 

 

COUNSEL FOR PLAINTIFF

You may also like...