Delhi HC Protects Dream11 Trademark, Issues Permanent Injunction Against Infringement

By Legal Wires 6 Minutes Read

In a significant development in intellectual property law, the Delhi High Court has taken a firm stand to protect the trademark rights of Sporta Technologies Pvt. Ltd., the company behind India’s leading fantasy sports platform, Dream11. The ruling, delivered on October 16, 2024, marks an important victory in the ongoing battle against trademark infringement and sets a crucial precedent for the fantasy sports industry, which has witnessed substantial growth and investment in recent years.

Dream11 was launched in 2012 and quickly became synonymous with fantasy sports in India, offering users a platform to create virtual teams based on real-life games. Over the years, it has attracted significant attention and investments, establishing itself as a recognized brand, both in India and globally. The company’s success is not just limited to its user base, but also includes notable achievements like becoming the official partner of the Indian Premier League (IPL) in 2019. This partnership further solidified Dream11’s brand recognition, earning it accolades and expanding its user base.

The defendant’s website, www.dream11com.in, provided identical fantasy sports services, creating confusion among consumers and diverting users to an illegal betting platform, Gugobet, further tarnishing the brand’s reputation.

Key Highlights of the Judgment

• Trademark Protection: The Delhi High Court recognized the trademark rights of Sporta Technologies over the ‘Dream11’ name, logo, and related elements, which have been registered and protected under Indian trademark laws.
• Permanent Injunction Granted: The Court granted a permanent injunction restraining the defendant from using the ‘Dream11’ mark or any deceptively similar variant as a domain name, trademark, trade name, or email address.
• Unfair Competition: The Court found that the defendant’s actions constituted unfair competition, as they involved copying key elements of the Dream11 platform, which misled consumers and damaged the brand’s reputation.

Background of the Case

• Sporta Technologies, incorporated in 2007, launched the Dream11 fantasy sports platform in 2012. Over the years, it has built a strong presence in the market, evident from its central sponsorship agreement with the Board of Control for Cricket in India (BCCI) for the IPL in 2019.
• The platform has received awards like the Red Herring 100 and Red Herring Asia 100, further enhancing its credibility in the industry.
• The defendant’s website, www.dream11com.in, mirrored Dream11’s user interface and included identical elements such as the trademark, tagline, and layout, creating confusion among consumers.

Court Proceedings and Interim Order

• After the suit was filed, the Delhi High Court issued an ex-parte ad-interim injunction on September 22, 2023, ordering the suspension of the infringing domain.
• The defendants failed to submit a written statement, leading to the closure of their right to defend themselves. This prompted the plaintiff to seek a decree under Order VIII Rule 10 of the Civil Procedure Code, 1908, allowing for a summary judgment in their favor.

Court’s Analysis and Reasoning

• The Court emphasized that, in uncontested suits, it is permissible to base decisions solely on the contents of the plaint.
• Upon comparison, the Court found that the defendant’s website was a near-replica of Dream11’s platform, using the same trademarks, logo, and tagline, ‘Dream Big’, thereby misleading users and infringing on Dream11’s trademark rights.
• The defendant’s actions were deemed clear instances of trademark infringement and copyright violation, taking unfair advantage of Dream11’s established brand and goodwill.

Final Ruling and Injunction

• The Court concluded that the plaintiff had sufficiently established its case, demonstrating that the defendant’s actions were aimed at capitalizing on Dream11’s established brand reputation.
• The Court granted a permanent injunction, preventing the defendant from using the ‘Dream11’ mark in any capacity and upholding the integrity of Dream11’s intellectual property rights.
• The judgment serves as a critical precedent for protecting intellectual property in the fantasy sports industry, reinforcing the need for strict enforcement against trademark infringement.
• It also signals the judiciary’s readiness to protect businesses from unauthorized replication of their digital platforms, ensuring fair competition and consumer trust.

Case: Sporta Technologies v Hong Y1 F35, CS(COMM) 663/2023, decided on 16-10-2024

Legal Wires

Team @LegalWires