ALG INDIA LAW OFFICES LLP Intellectual Property Lawyers AAI-4480 @ wowalgindia.com GZ communications @algindia.com © +91.999.9086.519 / +91.892.9975.587 244, Vana Aparinens, Plot No, 6C, Sector 23, Datla, New Delhi - 110077 | OFFICES : New Delhi! Hyderahod a POSTAL ADDRESS: Date: October 26, 2022 Our Ref: IP.E/2208230881 URGENT By Registered AD & Email WITHOUT PREJUDICE f Narayani Ply and Boards Private Limited f Gata No. 678, Gram Nawavdavan, Tehsil-Faridpur, Faridpur, Bareilly, Uttar Pradesh 243001, India. Also at: Ho. 43, 143 Civil Lines Kachahari Road, Bareilly. Email: bpindbly@email.com aniplybl LEGAL NOTICE NOTICE OF CEASE AND DESIST NOTICE OF DEMAND Dear Sirs, 1, We write on behalf of and under instructions from our client Reddit, Inc. [hereinafter referred to as “Our Client”, which expression shall include its affiliates, as well as predecessor/s and successors in right, ttle and interest] having its address at 548 Market Street, #16093 San Francisco, California 94104-5401, United States of America. Please note that the instant notice is being issued without prejudice to the rights of Our Client in law.. Founded in 2005, Our Client operates an internationally renowned website named REDDIT at https://www.reddit.com/, which is an online forum where every day, millions of people around the world including from India submit, vote, and comment on content, news and discussions. Nicknamed as the “front page of the internet", Our Client’s Reddit website has over 50 million daily active users, over 100,000 active communities and over 13 billion interactions, as of January 2021. . Our Client is the registered proprietor and owner across various countries, including India, ofthe mark REDDIT and several other REDDIT formative marks including, but not limited to reddit : © reddit, reddit, REDDIT TALK, REDDIT PUBLIC ACCESS NETWORK, REDDIT GIFTS, etc. (all of which are hereinafter collectively, singly as well as jointly, referred to as the “REDDIT Mark”) in respect of its range of goods and services. Our Client has continuously, extensively and uninterruptedly been using the mark REDDIT as a key, leading, prominent and essential portion of its corporate name, trade name, domain name, and trading style in respect of various aspects of its operations and activities. Intellectual property rights, including trademark rights, in the REDDIT Mark vest exclusively in Our Client, . Our Client's website at hitps://www reddit.com, launched in the year 2005 in several countries including India, has become one of the world’s biggest online platforms for entertainment, social networking, news and content creation, This website, as well as Our Client's other websites under the REDDIT Mark, hosted at www.redditinc.com/ and hitps://redditblog.com/, are accessible and attract a large number of visitors and customers intemationally, including from India. Through its long, continuous and extensive use of the REDDIT Mark, Our Client has developed a substantial user community and has garnered ‘tremendous reputation for its services. This is evident from the fact that the Reddit website is ranked as the 19" top website in the world as per Similarweb Ltd., with over 1.7 billion visits in a month, ranking above various other popular websites including zoom.us and microsoft.com. . Our Client's REDDIT platform is also available through mobile applications which can be downloaded from the Google Play Store as well as the Apple App Store internationally, luding in India. The official Reddit App has been installed by over 100 million users internationally through the Google Play Store. . In India, the popularity of Our Client's services under the REDDIT Mark is also evident from the extensive following of its official subreddit for India — ‘r/india’, created on January 25, 2008 and comprising of over 1.1 million community members. Our Client also has several other India-specific subreddits including ‘r/IndianFood’ (created on November 4, 2010, with over 178,000 members); ‘r/IndiaNews’ (created on May 26, 2008, with over 177,000 members), ‘rfoollywood! (created on April 3, 2008, with over 346,000 members), “r/delhi’ (created on March 7, 2009, with over 284,000 members), ‘r/bangalore’, (createdon April 27, 2008, with over 284,000 members), ‘r/Cricket” (created on March 12, 2008, with over 643,000 members), etc. | Our Client's REDDIT platform is popularly known in the online community and pop culture for its “AMA” (‘Ask me Anything’) sessions on the subreddit ~ ‘r/IAmA’, where general users as well as renowned figures and celebrities introduce themselves and host Q&A sessions. Over the years, various renowned Indian public figures including, Shashi Tharoor, Harsha Bhogle, Anurag Kashyap, Varun Grover, Amab Goswami, Kalki Koechlin, Rahul Yadav, etc,, have hosted ‘AMA’ sessions on the ‘r/IAmA’ and ‘r/India’ subreddits. Various internationally renowned celebrities have also held AMA sessions on the REDDIT platform, including Bill Gates, Barack Obama, Neil DeGrasse Tyson, Snoop Dogg, Madonna, Jerry Seinfeld, Keanu Reeves, etc. Our Client owns a number of trademark registrations and applications for the REDDIT ‘Mark across various jurisdictions, including in India, for goods and services across various classes, Our Client’s rights in the REDDIT Mark are exclusive and proprietary. Details of select trademark registrations owned by Our Client for the REDDIT Mark in select jurisdictions are as follows: Mark Registration No. | Date of Filing Class(es) INDIA REDDIT TRDI-3567287 | June 14,2016 | 9,38, 42, 45 REDDIT 4615953, ‘August 19, 2020 2 REDDIT 4615952 ‘August 19, 2020 38 REDDIT 4615954 ‘August 19, 2020 45 REDDIT PUBLIC ACCESS IRDI - 4553389 | March 6, 2020 38, 42, 45, NETWORK UNITED STATES OF AMERICA PB reddit 3474493 January 18, 2008 41 REDDIT 3786519 Tune 26, 2009 41 REDDIT 4087966 Tune 17, 2011 25 REDDIT 4174690 November 3, 2011 16 reddit 4763648 October 13, 2014 9 REDDIT 5019343, December 15, 2015 9 REDDIT 5053433, February 1, 2016 38 REDDIT 5008166 February 1, 2016 45REDDIT PUBLIC ‘ACCESS 6051898 | September 10, 2019 a2 NETWORK EUROPEAN UNION REDDIT 009386111 | Seplember 20, 2010 | 38,41, 42, 45 INTERNATIONAL REGISTRATIONS [WIPO] REDDIT 1348086 june 14,2016 | a ~ REDDIT PUBLIC ACCESS 1537980 March 6,2020 | 38, 42, 45 NETWORK ‘AUSTRALIA REDDIT 1150794 December 7,2006 | 9,35, 38,42 REDDIT 1848918 Tune 14, 2016 41,45 CANADA REDDIT TMA863431__| November 1,2010 | > ae he ess REDDIT TMA1034587 _| February 25,2016 | 9,42, 45 SWITZERLAND Predait 621478 June 21, 2011 41 MEXICO REDDIT 1245945 Tune 27, 2011 a SINGAPORE REDDIT 4ono1722083T | October 19,2017 | 98,414 PHILIPPINES REDDIT 1348086 October 19,2017 | 7881 9. In addition to trademark registrations, Our Client also owns several domain name registrations incorporating the mark REDDIT, including but not limited to created on April 29, 2005; created on December 13, 2005; created on November 2, 2006; created on September 9, 2009; created on November 11, 2009; created on February 7, 2012; created on October 19, 2017; created on October 25, 2008; etc. 10. Our Client has expended considerable financial resources in its REDDIT Mark and successful enforcement of its rights therein, against several infringers in various jurisdictions, including in India. Details of select successful enforcement actions are provided below:a. Opposition No. 978551 at the Indian Trade Marks Registry against Trademark #& Reddit , Application No. 3831492 for the mark in Class 25, in the name of Siraj Ahmad (Trading as: Reddit Life Style). This application was ordered as Abandoned by the Trade Marks Registry on October 21, 2019, pursuant to Our Client's Opposition. b. Reddit, Inc. v. J.P.Nagle, WIPO Case No. DCO2018-0008 (WIPO Arbitration and Mediation Center, April 24, 2018), where the panel transferred the domain name to Our Client, and observed that “The Respondent must have been aware of the rights of the Complainant in its distinctive REDDIT trademark... The users of the legitimate “www.reddit.com” website are very considerable in number and geographical spread... the Panel holds that the disputed domain name was registered and is used in bad faith.” ©. Reddit, Inc. v. Sebastian Anderson, WIPO Case No. D2019-2964 (WIPO Arbitration and Mediation Center, January 29, 2020), where the panel transferred the domain names and to Our Client, and observed Respondent was likely aware of the REDDIT trademark when it registered the disputed domain names, or knew or should have known that they were identical or confusingly similar to Complainant's marks...this Panel finds that Respondent's registration and use of the disputed domain names were in bad faith.” d. Reddit, Inc. v. Phil Carey, WIPO Case No. D2020-1834 (WIPO Arbitration and Mediation Center, September 30, 2020), where the panel transferred the domain name to the Our Client, and observed “The Panel finds that the disputed domain name is identical to the Complainant's REDDIT mark, in which the Complainant has established rights through extensive registration and some 15 ‘years’ use... The record is convincing that the Respondent registered and has used the disputed domain name in bad faith, seeking to exploit the Complainant's rights in the REDDIT mark." |. Through years of extensive marketing, advertisement, promotion, and actual use across several countries, including in India, the REDDIT Mark has acquired a significant level of ‘goodwill and reputation and is associated exclusively with Our Client. The popularity of Our Client and its REDDIT Mark can be gauged from the fact that Our Client and its services offered under the REDDIT Mark have received widespread media attention from various publications, newspapers, and magazines having accessibility and circulation internationally, including in India, such as NDTV, Times of India, The Hindu, The Indian Express, Adweek, The Verge, Variety, Wall Street Journal, The Atlantic, TechCrunch, Engadget, AdAge, Digital Trends, etc. Our Client's REDDIT Mark also enjoys extensive following on its social media pages, including Facebook, Instagram, Twitter, YouTube, etc., which pages are accessible internationally, including in India. Moreover, even a general search for the word “REDDIT” over the intemet would instantly reveal that the REDDIT Mark is renowned and exclusively associated with Our Client.12, 13. 15. Our Client's REDDIT Mark enjoys tremendous reputation, brand image and goodwill internationally, including in India and is recognized by members of the public as signifying the goods and services exclusively provided by Our Client, Owing to long, consistent and extensive use internationally, including in India, and successful record of enforcement, Our Client's REDDIT Mark is entitled to be protected as a well-known trademark, as defined under Section 2(1)(zg) read with Section 11(6) of the Trade Marks Act, 1999 in India and is entitled to be protected for goods and services across classes. Our Client has recently discovered that you have filed a Trademark Application No. 5416131 for the mark REDDIT (hereinafter referred to as “Impugned Application”) before the Trade Marks Registry. Our Client has also come across your online business listing, from the contents of which itis noted that you are using the marks REDDIT and. (hereinafter referred to as “Impugned Marks”), in respect of plywood boards. The Impugned Marks are identical and deceptively and confusingly similar to Our Client's earlier and registered trademark REDDIT. Your blatant copy of not only Our Client’s word y. reddit ) evidences your dishonesty in adoption. The device element vi. Il doesnot impart any dissimilarity to your logo mark as against Our Client’s REDDIT Mark. The identity of the Impugned Marks and Our Client’s REDDIT Mark is evident from the below side-by-side comparison: mark REDDIT but also the same font in your logo mark ( ‘Our Client's Trademarks Impugned Marks REDDIT REDDIT reddit . Your aforementioned actions are bound to, and in fact appear to be designed to, create confusion and deception in the minds of consumers and the public at large. The Impugned Marks create a false association of your goods and services with Our Client and its earlier, registered and well-known REDDIT Mark, Your adoption and use of the Impugned Marks appear to be undertaken with the sole intention of illegally benefitting from the goodwill and reputation generated by Our Client’s REDDIT Mark internationally, including in India. Your aforementioned actions appear to be designed to take unfair advantage of and to trade upon Our Client's REDDIT Mark by causing initial interest confusion. It is inconceivable that you did not have actual or constructive knowledge of Our Client’s earlier, registered, and well-known REDDIT Mark at the time of your adoption of the Impugned Marks.16. Your adoption and use of the Impugned Marks is without authorization from Our Client and amounts to infringement, unfair competition, unfair trade practice, passing-off, debasement, tarnishment and dilution of Our Client's REDDIT Mark. 17, Our Client is aggrieved by, and objects to, your aforesaid actions and complains of legal injury. It is evident that your actions are with a view to unauthorizedly exploit and to illegally benefit from Our Client's prior and registered REDDIT Mark. Your actions cause confusion and deception amongst the members of the trade who are bound to be misled into connecting and associating your goods with the goods and services of Our Client, or otherwise imagining or believing that your goods are sponsored by, approved by or otherwise affiliated with Our Client in one or the other manner. Your conduct constitutes unfair trade practice under both consumer protection laws and competition laws, “passing off” and “infringement” and also amounts to both “falsification of trade mark” and “falsely applying a trademark” under the Trade Marks Act, 1999. You are also liable to account for the profits that you have made as a result of your above said actions and also to pay damages to Our Client. 18, Accordingly, we request and demand that you immediately: a) identify and undertake to withdraw/surrender all application(s), petition(s) and registration(s) incorporating orn any manner referring to any of the Impugned Marks REDDIT and (in stylized, plain-text, color or other forms) or any other ‘mark(s) incorporating or deceptively or confusingly similar to Our Client's REDDIT ‘Mark, including but not limited to your trademark Application No. 5416131; b) undertake not to own, apply for registration of, or acquire/obtain any application(s) or registration(s) for or featuring any of the Impugned Marks REDDIT and Kail (in stylized, plain-text, color or other forms) or any other mark(s) incorporating or deceptively or confusingly similar to Our Client's REDDIT Mark, in any manner whatsoever in the future; c) permanently cease and desist from using any of the Impugned Marks REDDIT and (in stylized, plain-text, color or other forms) or any other mark(s) incorporating or deceptively or confusingly similar to Our Client's REDDIT Mark, in any manner whatsoever in respect of your business, directly or through any of your lessees/subsidiaries/distributors/agents/affiliates, including all use as part of your signage, brochures, business cards, labels, promotional materials, advertisements, domain name/s, company name/s, URLs, software, mobile applications, e-mail addresses, screen names, user names, website contents {whether or not visible}, staffuniforms, documents, reports, data, invoices, receipts, stationery, and on any other ‘materials and things; 4) have removedltaken down any and all references to any of the Impugned Marks Bor any other mark incorporating or deceptively or confusingly similar to Our Clients’ REDDIT Mark at all websites, webpages, social media pages and online platforms whose content is in any manner, drectly/indrectly controlled by you, including but not limited to webpages hosted at hitps://www justdial.com/s REDDIT and cancel, and destroy any and all advertisements, promotional material, inventories, business cards, labels, receipts, ete. ference to any of the Impugned ©) withdraw, brochures, hoarding, stationery, and/or any other items bearing or containing any ret Marks REDDIT and (in stylized, plain-text, color or other forms) or any other rmark(s) incorporating or deceptively or confusingly similar to Our Client's REDDIT Mark in any manner whatsoever; and 1) acknowledge and confirm to us in writing within 14 days from the receipt of this demand letter that you are complying in terms of the above. 19. In the event that you do not comply with the above requisitions, Our Client reserves the right to take such further legal action(s) as it deems appropriate or necessary to protect its intellectual property rights. This includes, without limitation, all actions permitted by law, including seeking orders for injunctive relief, monetary damages, fines and penalties, etc. against you without any further notice to you, which will be solely to your risk, cost and consequences. 20, Our Client reserves its rights in the matter to take all such actions as may be available under the law and nothing in this letter shall be construed as a waiver or relinquishment of any right or remedy possessed by Our Client, all of which are expressly reserved. 21. Please correspond only with us and only in writing, 22. You are on legal notice. Yours truly, ABHIM ze: | pong ANYU ALG India Law Offices LLP KUMAR" [Abhimanyu Kumar, Advocate] Soesmnase a soa (Enrol No. D/1123/2009)