Complaint
Complaint
Complaint
-versus-
COMPLAINT
COMES NOW, the plaintiff together with the undersigned counsel to this
most honorable court, MOST RESPECTFULLY STATES THAT;
4. That the use of Green Cab Pizza Haus service mark by Respondents
in its pizza business is likely to cause confusion as telephone inquiries were
received by Complainants pizza business.
SEC. 147. Rights Conferred. 147.1 The owner of a registered mark shall
have the exclusive right to prevent all third parties not having the owners
consent from using in the course of trade identical or similar to those in
respect of which the trademark is registered where such use would result in
a likelihood of confusion. In case of the use of identical sign for identical
goods or services, a likelihood of confusion shall be presumed.
PRAYER
b. The defendant shall be ordered to pay P 120, 000 for the Attorneys
Fees.
Such other reliefs and remedies under the premises are likewise
prayed for.
I, Jon Snow, CEO of Yellow Cab Food Corporation, of Legal age, married,
Filipino Citizen and a resident of Puguis, La Trinidad Benguet, after being
sworn according to law, hereby depose and state that;
Jon Snow
Complainant
In witness thereof, I, Mr. Jan Aldrin E. Afos, counsel of the plaintiff, have
herunto set my hand this 29th of September at Baguio City.
-versus-
ANSWER
Other relief and remedies as may be deemed just and equitable under the
premises are likewise prayed for.
By:
HINDIE K. TALUNAN
Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila
Copy furnished:
ATTY. JAN ALDRIN E. AFOS
Counsel for the Plaintiff
19-F, LIBIS, QUEZON CITY
LIBIS, QUEZON CITY