2023:DHC:2796 mobile application “MPL”. The defendants carry on business under the trade name “Striker Club” through their website, mobile application “Striker,” as also under the trade name “MPL”. The defendants’ business through the Striker Website includes the creation of an online marketplace where third-party users can purchase, sell and trade Digital Player Cards, which include the image of a player along with the player’s name/initials. Like plaintiff no.1, the defendants also use NFT technology to authenticate player cards for the Striker Website. 18.8. Unlike the plaintiff no.1, the defendants do not have authorization or licenses from plaintiffs no. 2 to 6 to use their names, surnames, initials and images or other attributes of their personality for their business. 18.9. Through the Striker Website and Striker mobile application, the defendants have a similar business model to that of the plaintiff no.1. The defendants do not have any license or authorization from plaintiffs no.2 to 6, yet they use Digital Player Cards with NFTs which include artistic drawings of plaintiffs no.2 to 6 along with their names. The entire value of the digital art collectibles/NFTs available on the Striker Website is derived from the names, likeness and personalities of the players and not on account of the artistic contents of the images. 18.10.The cause of action for the present suit arose in January, 2023 when plaintiff no.1 became aware of the Striker Website. 19. Based on the aforesaid averments, the present suit has been filed by the plaintiffs on account of unlawful use of player marks and other attributes of plaintiffs no. 2 to 6, which amounts to (i) unfair competition (including Signature Not Verified Digitally Signed By:AMIT BANSAL CS(COMM) 108/2023 Signing Date:26.04.2023 Page 8 of 51 13:09:16

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