In a trademark and copyright case involving MRF Limited (“MRF”) and Powermax Rubber Factory and Powermax Tyre (collectively “Powermax”), the Madras High Court decided in favor of MRF. The Court granted a permanent injunction restraining Powermax from using MRF’s brand, and also granted nominal damages in its favour.
MRF filed the suit under various sections of the Trade Marks Act, 1999, the Copyright Act, 1957, and the Commercial Courts Act, 2016. It sought perpetual injunctions to prevent Powermax from infringing its registered trademarks and artistic works, including the “Muscleman Device,” “MRF CHEETAH,” “MRF SAHARA,” “MRF SAFARI,” and “PAHALWAN.” Additionally, MRF asked for the removal of all infringing materials and claimed special damages amounting to Rs. 25,01,000.
The court acknowledged that Powermax had ceased using the trademarks “CHEETAH,” “SAHARA,” and “SAFARI” following a cease and desist notice from MRF, rendering adjudication on these specific infringements unnecessary. The court therefore focussed on the alleged infringement of the “Muscleman Device” and the “PAHALWAN” trademarks.
In its pleadings, MRF contended that the long-standing use of the trademarks in suit had established significant goodwill and reputation in the market. It therefore argued that Powermax’s use of a similar “bodybuilder” logo was dishonest and aimed at leveraging MRF’s established market presence. MRF provided evidence of significant investments in developing and advertising its trademarks and argued that Powermax’s actions had resulted in substantial financial losses and potential consumer confusion.
Powermax, on the other hand, argued that their logo, depicting a half-size bodybuilder with a robotic head, was independently created to signify the strength of their tyres, and did not constitute infringement or passing off. They also claimed that similarities in logos were inevitable given the shared thematic representation of tyre strength. As copyright protection does not extend to themes, Powermax submitted that there was no copyright infringement.
The court found in favor of MRF, and held that the “bodybuilder” logo used by Powermax was deceptively similar to MRF’s “Muscleman Device.” The court ruled that the similarities were likely to cause confusion among consumers, amounting to both trademark and copyright infringement, as well as passing off. The court emphasized that the distinctive elements of MRF’s logo had been copied, which would mislead the public into associating Powermax’s products with those of MRF.
Based on its findings, the court granted MRF the requested injunctions and ordered Powermax to cease using the infringing logos and materials. Additionally, the court also awarded nominal damages of Rs. 5,00,000 to MRF and mandated Powermax to pay the costs of the suit.
Citation: M/S.Mrf Limited v. Powermax Rubber Factory, C.S.No.75 of 2021 (H.C. Madras April 1, 2024). Available at: http://indiankanoon.org/doc/106508485/, Visited on: 06/04/2024.
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