• adding of an underscore; • changing the number from 1212 to 1213; or • shuffling the words within the name of the channel such as: t.me/rakeshpaidvideo being changed to t.me/paidcoursesrakesh. 19. The number of channels that can be created in this manner are innumerable. The Plaintiffs’ works have thus been disseminated without any hindrance whatsoever, despite the injunction order, and the infringers are operating under completely masked identities. Repeated blocking of the channels is proving to be insufficient. It is in view of this unsurmountable challenge to curb infringement, that the Plaintiffs seek the prayer in the present application for disclosure of identity of the creators of the infringing channels. The prayer in the present application reads as under: “15. In light of the above-mentioned facts and circumstances, it is most humbly prayed before this Hon’ble Court that it may be pleased to pass an order: a. directing Defendant No 1 to disclose the identity of the creators of the infringing channels reported by the Plaintiffs and listed at DOCUMENT 2 b. any other order as may be deemed necessary in the facts and the circumstances of the case.” 20. In reply to this application, the following broad defences are taken by Telegram: (i) A substantial number of channels have already been blocked. Telegram shall continue to remove infringing content as may be reported by the Plaintiffs. Signature Not Verified Digitally Signed By:DEVANSHU JOSHI Signing Date:31.08.2022 12:12:31 CS (COMM) 282/2020 Page 12 of 51