claiming through them and/or under them and all other persons from creating, publishing, uploading sharing, disseminating etc. the videos identified in paragraph 27 of this application, or any other videos which are identical to, or similar in content, and/or any other videos or content in any format, which discloses any details pertaining the Plaintiffs on the internet or through social media platforms, websites, blogs, or any other media such as the Metaverse, blockchain, any Artificial Intelligence program, or any other media such as print, audio-visual etc. that result in (a) Violation of the Plaintiffs’ right to privacy; and/or (b) Tarnishing and bringing disrepute to the goodwill and reputation that is vested Bachchan family name of the Plaintiffs; and/or (c) Exploitation and/or misappropriation of the Plaintiffs’ personality rights; (d) Defamation of the Plaintiffs (ii) An order granting ex parte relief in terms of prayer (i) above; (iii) An order directing the Defendant No. 10, to reveal the identity and all other contact details of Defendant Nos. 1 to 9, 12, including but not limited to name, e-mail ids, basic subscriber information, IP address etc. (iv) An order directing Defendant No. 10 to immediately de-list and deactivate all videos that are subject to restraining orders of this Hon’ble Court in terms of the prayer (i) and/or (ii) above; (v) An order directing the Defendant No. 11, MeitY to ensure that access is disabled to all infringing content that is uploaded by the Defendant Nos. 1 to 9, Defendant 12, which is identical or similar to the videos identified in paragraph 27 of this application, and/or any other videos and/or content in any format, including but not limited to use of pictures, names images, likeness that violate the rights of the Plaintiffs; And pass any other order as this Hon’ble Court may deem fit in the facts of the present case.‖ 20. The facts, as recited hereinabove, make out a clear prima facie case in favour of the plaintiffs and against the defendants, justifying grant of ad interim relief. Given the nature of the grievance that has Signature Not Verified Digitally Signed By:SUNIL SINGH NEGI CS(COMM) Signing Date:21.04.2023 08:06:01 230/2023 Page 9 of 15

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