TO THE COMMERCIAL COURT OF FIRST INSTANCE
prosecutor:
PLAINTIFF’S LAWYER :
THE DEFENDANT:
SUBJECT OF THE LAWSUIT: It consists of a request to detect and stop the defendant firm’s encroachment on my client’s registered trademark and a request for material and moral compensation.
FACTS :
1- My client, my company …….. in its history, it has been operating in the textile field for many years and has established a chain of stores.
2- Our customer has registered the phrase ……… as a trademark with the number ……. …….. during the year, my client has used this brand in workplaces, billboards, signs and advertising tools. The quality of service has gained a well-deserved reputation, has become a recognized and sought-after brand.
3- My customer is still continuing both production and marketing activities with this brand and has created a good Sunday share for himself. The company against which the determination is requested operates in the textile sector at the address where the determination is requested, and uses the phrase ………. like a registered trademark, as seen on the label copy, on the textile products it sells………. we have added.
4- The company against which the determination is requested operates in the field related to the goods and services covered by my client’s registered trademark and uses almost the same phrase as the registered trademark in its goods and services without my client’s permission. ……… he uses his expression deliberately and with the aim of creating confusion. This issue constitutes a violation of the ……… clause.
5- My client’s registered trademark presented in the Oct. 556 p. It is a Decree Law and it is not possible to use it as a trade name and business name by another person without the permission of my client. Otherwise, it constitutes an infringement of the trademark right due to unfair competition.
6- For the reasons written above, since the symbol used by the company against which the determination is requested is exactly the same as my client’s registered trademark, you must apply to your court to determine that this situation constitutes an infringement of rights……… A decision to collect the client’s brand, the products and advertising materials used by the company against which a decision is requested due to unfair competition, by way of a precautionary measure.
LEGAL BASES:
EVIDENCE : My client’s copy of the trademark registration certificate, a photocopy of the product label used by the person against whom the identification is requested.
CONCLUSION AND REQUEST: For the reasons written above, I respectfully request and request by proxy that the person about whom the determination is requested be determined to have used the phrase ………. i have decided that the phrase used by the person against whom the determination is requested in his products ……… resembles my client’s registered trademark in a way that creates favoritism, this situation constitutes an infringement of my client’s registered trademark due to unfair competition, the person requested to determine that he uses my client’s registered trademark, the products he uses will be collected through an injunction, all court costs and attorney’s fees will be charged to the other party. ../../..
Plaintiff Lawyer
Lawyer…
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