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 by the defendant without permission from our client and put on the market.
2-The defendant did not merely copy the product exactly, but also did not change the product name. The packaging was also copied exactly.
3-The defendant’s behavior is putting our client in a difficult position in the market. Our client is forced to replace products that are not sold, and products sold at different prices are creating trust issues among customers. The defendant’s behavior is 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, as well as criminal proceedings for the defendant’s unlawful actions.
5-We request that the court, in order to prevent the defendant’s unjust behavior, seize any similar products that the defendant possesses that infringe on our client’s patent, as well as any machinery and equipment used in the production of such products, as a precautionary measure.
6-If the court finds in our favor, we request that the final judgment be published in national newspapers at the defendant’s expense.
LEGAL GROUNDS: Civil Code, Commercial Code, Code of Civil Procedure, etc.
EVIDENCE: Company records, patent documents, trade register, patent, witnesses, discovery, expert opinion, and all other legal evidence.
RESPONSE PERIOD: 10 days.
CONCLUSION: For the reasons stated above, we request that the Court issue a preliminary injunction to prevent the defendant’s unfair competition, seize any similar products that the defendant possesses that infringe on our client’s patent, as well as any machinery and equipment used to produce such products, If the Court finds in our favor, the final judgment shall be published in national newspapers at the defendant’s expense, and the litigation costs shall be borne by the defendant. We request that the court rule that the opposing party’s attorney’s fees be awarded to us as attorneys in accordance with the final paragraph of Article 164 of the Attorney Act No. 1136, as amended by Act No. 4667.
PLAINTIFF’S ATTORNEY
