TO THE HONORABLE COURT,
…….
PLAINTIFF: …….
ATTORNEY: …….
DEFENDANT: …….
SUBJECT: Prevention of Unfair Competition
EXPLANATIONS:
1-The special floor tiles belonging to our client’s company, which have been produced under patent for 6 years, have been copied and released onto the market by the defendant without our client’s permission.
2-The defendant not only copied the product exactly but also did not change the product name. The packaging was also copied exactly.
3-The defendant’s actions are putting our client in a difficult position in the market. Our client is forced to replace unsold products, and products sold at different prices are creating trust issues among customers. The defendant’s actions are causing harm to our client’s company in every way.
4-We will file separate compensation claims for the material and moral damages we have suffered to date, and we will also file a criminal case against the defendant for his unlawful actions.
5-To prevent the defendant’s unlawful acts, we request that the court seize the similar products infringing on our client’s patent, as well as the machinery and equipment used in their production, as a precautionary measure.
6-If the court rules in our favor, we request that the final decision be published in national newspapers, with the costs borne by the defendant.
LEGAL BASIS:
Civil Code, Commercial Code, Code of Civil Procedure, etc.
EVIDENCE: Company records, patent documents, commercial register, patents, witnesses, discovery, expert opinion, and all other legal evidence.
RESPONSE PERIOD: 10 days.
CONCLUSION: For the reasons stated above, we request that a preliminary injunction be issued to prevent the defendant’s unfair competition, and that the defendant’s products that infringe on our client’s patent and the machinery and equipment used in the production of these products be seized. If the court rules in our favor, the final decision will be published in national newspapers at the defendant’s expense, and the litigation costs will be borne by the defendant. We request that the court order the defendant to pay our attorney’s fees in accordance with the last paragraph of Article 164 of the Attorney’s Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY