THE HIGH COURT OF DELHI AT NEW DELHI
(Original Commercial Jurisdiction-IP Division)
I.A. No. ______ of 2025
in
CS (Comm.) No. 25 of 2025
IN THE MATTER OF:
Urbanclap Technologies India Private Limited …Plaintiff
Versus
Kent RO Systems Ltd. & Ors. …Defendants
INDEX
S. No. Particulars Page No.
1. Application Under Section 151 Of Code Of 1-6
Civil Procedure, 1908 On Behalf Of The
Denfendant No. 1 And 2 Seeking
Permission For Filing Pen Drive For
Production Of Certain Documents In
Support Of The Written Statement On
Behalf Of The Said Defendants; along with
supporting affidavit
2. Affidavit with Proof of Service 7-9
Place: New Delhi
Date: 15.05.2025
Counsels for the Applicants/Defendant No. 1 & 2
Adv. Garima Joshi (D/9784/2022) | Adv. Nikita Seth (D/2567/2024)
Rajeshwari & Associates
S-357, First Floor, Panchsheel Park,
New Delhi-110017
E:garima@[Link]
nikita@[Link]
M: +91-9873598716
+91-9588174061
1
THE HIGH COURT OF DELHI AT NEW DELHI
(Original Commercial Jurisdiction-IP Division)
I.A. No. ______ of 2025
in
CS (Comm.) No. 25 of 2025
IN THE MATTER OF:
Urbanclap Technologies India Private Limited …Plaintiff
Versus
Kent RO Systems Ltd. & Ors. …Defendants
APPLICATION UNDER SECTION 151 OF CODE OF CIVIL
PROCEDURE, 1908 ON BEHALF OF THE DENFENDANT
NO. 1 AND 2 SEEKING PERMISSION FOR FILING PEN
DRIVE FOR PRODUCTION OF CERTAIN DOCUMENTS IN
SUPPORT OF THE WRITTEN STATEMENT ON BEHALF OF
THE SAID DEFENDANTS
The Defendant No. 1 and 2 most respectfully showeth:
1. The present suit has been filed by the Plaintiff for seeking
injunction against the said Defendants from sending
infringement reports to e-commerce platforms, disparagement,
defamation and for seeking damages and other related reliefs.
2. That the Defendant No. 1 and 2 have filed a combined written
statement in response to the present suit vide Diary No.
3309958/2025 dated 09.05.2025 along with the supporting
documents filed vide Diary No. 3323258/2025 and an
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application for condonation of delay in filing the said written
statement vide Diary No. 3323338/2025.
3. That the Plaintiff in the present suit alleges that their product
links were taken down from the platform of Defendant No. 3
owing to misleading and malicious infringement reports raised
by the Defendant No. 1 and 2 with the Defendant No. 3.
However, this submission by the Plaintiff herein is absolutely
false, frivolous, manipulative and devoid of any merit.
4. That the Defendant No. 1 and 2 in their combined written
statement have submitted and proved that the links of the
impugned product of the Plaintiff were taken down from the
platform of Defendant No. 3 on merits and not due to any
patent infringements reported by the said Defendants.
5. That the Defendant No. 1 and 2 by way of this present
application are seeking liberty of this Hon’ble Court to place
on record a product-specific template provided by Defendant
No. 3 on their seller hub which needs to be filled and uploaded
by all the sellers for listing of their products on the website as
per their product specifications, based on which the Defendant
No. 3 verifies if the products being listed on its platform
conforms to the quality standards being set by Defendant No.
3.
6. It is submitted that the said template is in the format of an Excel
Sheet with .xlsm extension, owing to which it cannot be
produced in a .pdf format without the contents therein getting
changed or tampered with.
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7. Therefore, the Defendant No. 1 and 2, herein the Applicants,
crave leave of this Hon’ble Court for allowing them the
permission to file a pen drive, containing the said Excel Sheet
and any other supporting or corroborating evidences that
cannot be otherwise supported in a .pdf file.
8. That the Applicants have downloaded the product template
pertaining to the impugned products from the platform of
Defendant No. 3 and stored them inside the pen drive, only for
the purpose of proper adjudication of the present suit.
9. It is submitted that the Applicants want to place on record the
said pen drive as the same is a material document to decide the
accompanying suit for a temporary and/or a permanent and
mandatory injunction on account of the alleged misleading
communications, disparagement, defamation and for seeking
damages and other related reliefs.
[Link] the present application is bona fide and filed to protect the
rights and interests of the Defendant No. 1 and 2 in the present
suit.
[Link] the present application has been filed in the best interests
of justice, equity and fair play and no prejudice shall be caused
to the Plaintiff/Respondent if the present application is
allowed. However, grave harm may be caused to the
Applicants/Defendant No. 1 and 2 if the present application is
not allowed.
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PRAYER
[Link], in the light of the present facts and circumstances of
the case, the Defendant No. 1 and 2, herein the Applicants,
most humbly pray that the Hon’ble Court may be pleased to:
a) Pass an Order to grant permission to the Applicants/
Defendant No. 1 and 2 to place on record the said Pen
Drive, consisting of the Excel Template as mentioned in
paragraph 5;
b) Pass any other Order or grant any other reliefs that the
Hon’ble Court may deem fit and necessary in the present
case.
Place: New Delhi
Date: 15.05.2025
DEFENDANT NO. 1 & 2
THROUGH
Counsels for the Applicants/Defendant No. 1 & 2
Adv. Garima Joshi (D/9784/2022) | Adv. Nikita Seth (D/2567/2024)
Rajeshwari & Associates
S-357, First Floor, Panchsheel Park,
New Delhi-110017
E:garima@[Link]
nikita@[Link]
M: +91-9873598716
+91-9588174061
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20/05/2025, 20:41
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Rajeshwari & Associates Mail - Advance Service of Application on behalf of the Defendant No. 1 & 2 u/s 151 of CPC, 1908 seeking…
Nikita Seth <nikita@[Link]>
Advance Service of Application on behalf of the Defendant No. 1 & 2 u/s 151 of CPC,
1908 seeking permission for filing pen drive - CS(Comm) 25 of 2025
1 message
Nikita Seth <nikita@[Link]> Tue, May 20, 2025 at 8:40 PM
To: asavari@[Link], office@[Link], Manas Raghuvanshi <manas@[Link]>, [Link]@[Link],
[Link]@[Link]
Dear Sir/Ma'am,
We represent the Defendant No(s). 1 and 2 in the captioned suit.
On the instructions of our clients, we are filing an application u/s 151 of CPC, 1908 seeking permission for filing pen drive
to produce certain documents in support of the written statements filed by the said Defendants.
Please find the said application attached below along with the documents to be filed thereunder.
Kindly consider this email as a complete and proper service of the said application and documents.
Regards
Nikita Seth
Associate | Litigation
Rajeshwari & Associates
S-357, 1st Floor, near HDFC Bank,
Panchsheel Park, New Delhi,
Delhi 110017
2 attachments
Pendrive [Link]
1585K
WATER_PURIFICATION_UNIT.xlsm
1131K
[Link] 1/1