……. TO THE HONOURABLE JUDGE,
THE PLANTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Prevention of Unfair Competition
EXPLANATIONS :1-The special quality floor tiles belonging to our client company, which have been patented for 6 years, have been imitated and put on the market by the defendant without obtaining permission from our client.
2- The defendant not only imitated the product exactly, but did not even change the name of the product. He also copied the packaging exactly.
3-This behaviour of the defendant puts our client in a difficult situation in the market. Our client has to change the products that it does not sell, and the products sold at different prices create a problem of trust among customers. The behaviour of the defendant harms our client company in all respects.
4-We will also file compensation lawsuits against the defendant for the material and moral damages we have suffered so far and criminal lawsuits for his criminal act.
5- In order to prevent this unfair behaviour of the defendant, we also request the court to confiscate both the similar products that our client has patented and all kinds of machinery and vehicles used to produce these products.
6-In case we are found right by your court, we request that the finalised judgement be announced in national newspapers at the defendant’s expense.
LEGAL GROUNDS : BK., TK., HUMK, etc. legislation.
EVIDENCE : Company records, patent documents, trade registry, patent, witnesses, discovery, expert witnesses and all kinds of legal evidence.
RESPONSE TIME : 10 days.
RESULT OF THE REQUEST : For the reasons explained, in order to prevent this unfair behaviour of the defendant by the Court, to prevent the unfair competition of the defendant, to issue an injunction to seize both the similar products that the defendant has our client’s patent and all kinds of machinery and vehicles used to produce these products, In the event that we are found right by your court, we request that the finalised judgement be announced in national newspapers at the expense of the defendant, the costs of the proceedings be charged to the defendant, and the counterparty attorney fee be awarded on our behalf as a lawyer in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF …….
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