NEW ZEALAND HIGH COURT, AUCKLAND

RedBull GmbH NZ/AUS division. )

J. Doe & Associates AAL. Ltd.
)
Plaintiffs, CIVIL ACTION NO. 7:11-cv-241
)
v.
)
Woolworths Group Ltd.
)
Subsidary, Countdown Supermarkets.
)
Defendants. JURY DEMAND

I.
COMPLAINT

NOW COME Plaintiff RedBull GmbH New Zealand & Australia (hereinafter

“Plaintiff’s” or “RedBull GmbH”), by and through their attorneys, John Doe & Associates,

Attorneys at law Ltd., and for their complaint against Defendants Woolworths Group Ltd.

(Hereinafter “Defendant’s”, or “Woolworths Group”), state as follows:

Through their actions, the Woolworrths group, and their subsidaries “Countdown”,

have wrongfully, and through unlawful and slanderous means, attempted to halt sale of the

Plaintiff’s products within their stores to individuals below the age of 16 years, on a

malicious basis.

II.
PARTIES

I. Plantiff RedBull GmbH is a multinational corporation currently based in Fuschl,

Austria. The following Civil Action is being demonstrated by RedBull GmbH

AUS/NZ based in Auckland, New Zealand.

II. Defendant Woolworths Group Ltd. are a multinational Limited Retail Organization

currently based in Bella Vista, Australia.

III. Defendant Countdown Supermarkets are a corporate subsidary of the Woolworths

Group, and a Supermarket chain, currently parented by Woolworths Group Ltd.

Based in Bella Vista, Australia.

 III.
SUMMARY

This Civil Action suit is filed on behalf of RedBull GmbH Australia and New Zealand

by John Doe & Associates, Attorney’s at Law Ltd. In pursuance of a Civil claim against the

Defendant The Woolworths Group Ltd., and it’s subsidary Countdown Supermarkets. This

suit is filed on the grounds of gross Defamation, Corporate Slander, the spread of

Misinformation, and the general unbecoming actions imposed and executed by the Defendant,

from September 2nd, 2019 to November 9th, 2021, the date of filing.

On September 2nd, 2019, the Defendant took a levy of actions, both directly and

indirectly which resulted in a significant loss of monetary gain on the side of the plaintiff,

worsened public reception of the Plaintiff’s organization, and the wrongful contractual

termination of the Plaintiff on unlawful grounds as stated and contained of the document(s)

herein.

This document and its attatchments are outlined into a standard order, in a line of

progression beginning with the Complaint, and finishing with the Addendum. The contents of

this document are as follows:

I.
COMPLAINT

II.
PARTIES

III.
SUMMARY

IV.
FACTS

V.
CLAIM

VI.
DAMAGES/PRAYER

VII.
EXHIBITS

VIII.
ADDENDUM

 IV.
FACTS

I. On the Second of September, 2019, Countdown Supermarkets enforced a

nationwide policy disbarring individuals under the age of sixteen years from buying

any energy drink, or caffinated beverage within their stores within New Zealand.

II. At the time of enforcement, the Defendant was operating a total of 180 locations

(supermarkets) across New Zealand, all of which would be subject to said enforcing

policies.

III. Under the Food Act of 1981¹, Energy Drinks of any kind may be sold to, and

distributed to individuals regardless of age in New Zealand.

IV. On the 9th day of November, 2021, at 10:45 am GMT+13, a Civil Action suit was

filed against Defendant on the grounds that their actions directly or indirectly

defamed the Plaintiff, and resulted in an exponential amount of lost revenue.

V. Following the Defendant’s policy change, multiple news articles were released in

regards to said change. Resulting in a gross spread of misinformation in the media,

often pushing a false narrative.

VI. Following the Defendat’s policy change, sales of RedBull, and other affiliated

products in stores across New Zealand dropped significantly, and many New

Zealanders were falsely led to believe that the sale of energy drinks to minors was

unlawful.

VII. The Woolworths Group Ltd. And it’s subsidaries chose to widly publicize the event

and change, resulting in negative publicity towards multiple Energy Drink producers,

including but not limited to the Plaintiff.

 V.
CLAIM

As a result of the actions of the Defendant, the Plaintiff, and all subsidaries thereof

hereby claim that the restrictions implemented by the Woolworth Group caused multiple

millions of dollars in lost revenue, and vast misinformation among the public. By publically

announcing said restrictions, the Defendant inadvertently caused a large percentage of the

public to falsely believe minors were not legally permitted to buy RedBull© products. This

in-turn caused a substantial case of defamation towards the Plaintiff, in addition to a

significant amount of lost revenue. It is on these grounds that the Plaintiff finds it

indespensible that this action, and all results herein are executed to the benefit of the Plaintiff

and all related subsidaries thereof.

The Plaintiff suffered dramatic consequences, both directly and indirectoy as a result

of the unjust actions of the Defendant, either purposefully or by indicrect consequence; and

thus believes it right to open a suit on previously stated grounds. The Defendant, in these

circumstances, through their heavy publication of said policy change, directly or indirectly

created a large spread of misinformation, further discrediting the Plaintiff and causing large

amounts of damages, both in terms of public perception, and in terms of monetary loss in

ramifications to the Defendant’s crude actions. The relating drop in sales as consequence of

the Defendant’s actions lay justification for reparations exceeding the sum in which was

subsequently subtracted.

[PAGE LEFT INTENTIONALLY BLANK]

 VI.
DAMAGES

IV.1(a)

The reckless actions of the Defendant resulted in a large hinderence of the sale of the

Plaintiff’s products nationwide, and in turn, caused millions of dollars in lost revenue.

From 2019-2020, RedBull Energy Drink sales in New Zealand dropped between 7-13%

depending on location, largley following the debut of the Defendant’s new policy in

September of the same year.

IV.1(b)

The actions of the Defendant, in their mass publication of said policy-changes

resulted in disinformation among the public in regards to the legality of the sale and

consuption of energy drinks, which currently encompass no age restrictions in accordance

with the New Zealand Food Act of 1981, and all other comprised relating laws in said regard.

A poll of New Zealanders suggest that upwards of 20% of the New Zealand population

currently believe that it is illegal, or heavily restricted for individuals under the age of 16 to

purchase, consume, or otherwise use caffinated beverages, and in extension, energy drinks;

which include that of the Plaintiff.

IV.2(a)

Either intentionally, or inadvertently, the Defendant through their policies slandered

and defamed the Plaintiff, and their necessary subsidaries in the eys of the public. By heavily

publicizing their Policy-Change, both on the internet, and inside of store locations, the

Defendant reinforces a false negative stereotype surrounding the Defendant, further hindering

their abilities to cohesively function as a corporation.

The Defendant’s actions likely led to a misconception and enforced negative view of

the Plaintiff in the public-eye, and created a hostile environment between the two

corporations, resulting in a loss of both public respect, and monetary value within RedBull

GmbH as an oganization.

 IV.3(a)

PRAYER

As a result of the abovementioned acts, RedBull GmbH is filing a motion for civil

action against the Woolworths Group Ltd. for a sum in excess of $20,000,000 NZD in

Damages, including $5,000,000 NZD as a result of Defamatory actions conducted by the

Defendant, $10,000,000 NZD in reparations to the lost sales of the Plaintiff as a direct result

of the actions of the Defendant, and $5,000,000 NZD in damages as the result of

disinformation spread at the behest of the Defendant, falsely incriminating the Plaintiff in the

public-view. In addition, the Plaintiff asks that all restrictions of age in the sale of products

belonging to said parties therein be lifted, and all previously published virtual and physical

articles deemed by the Plaintiff to be misleading, false, or defaming be recalled with

immediate action.

VII.
EXHIBITS

Find below the necessary exhibits of evidence issued by the Plaintiff in prosecution of

the Defendant on the grounds of the aformentioned allegations on behalf of he Plaintiff and

all other prosecuting parties.

I. On the second day of September, 2021, the Woolworths Grop Ltd. (Defendant) issued a

change in policy disbarring individuals under the age of sixteen years from purchasing

any energy drink, including those produced by the Plaintiff in all locations.

II. Following said policy change, RedBull NZ and AUS sales proceeded to decline by at

least 7% nationwide, worsening when new articles in regards to said policy were

published with the approval of the Defendant to private news organizations.

III. Directly following the change, the Woolworth Group Ltd. Greenlighted a number in

excess of nine major New Zealand publications to report on the story, which in turn led to

mass negative publicity directed towards the Plaintiff.

 VIII.
ADDENDUM

Case of Civil Action ordered as such, and presented to the New Zealand High Court,

Auckland. 24 Corner Waterloo Quadrant & Parliament Street, Auckland CBD, Auckland

1010, New Zealand. Issued on the 9th day of November, in the year 2021.

The Plaintiff on behalf of the represented oragnizatins formally input Jury Demand,

and request reviewal of the NZHC in line with the Courts act, 2016. This Civil Action has

been issued by John Doe & Associates, Attorneys at Law Ltd. 00 South Crescent Ave.

Auckland, New Zealand. In request for the filing and process of a Civil Law suit in the name

of the Plaintiff, RedBull GmbH Australia and New Zealand, 27 Mackelvie Street, Grey Lynn,

Auckland 1011, New Zealand. for civil action against the Defendant, the Woolworths Group

Ltd. And it’s subsidary Countdown Supermarkets, 80 Favona Road, Favona, Auckland 2024,

New Zealand.

All above listed Prayers issued by the Plaintiff are subject to change at the agreement

of both councils, and notice to the Court prior.

Signees,

JohnDoe,JD.
John Doe, JD. J. Doe & Associates.

JaneDoe,PhD.
Jane Doe, JD. J. Doe & Associates.