- 16 A B A 70. According to Qian, D1 and D2 belong to a group of B conglomerate business, but they run completely different businesses and C C are independent of each other. D D 71. E F st As set out in the 1 affidavit of Elms, from about February 2015 the plaintiffs received complaints from customers regarding infringing jewellery sold on the GLAMULET websites as evidenced by E F exhibit HWME–32. G H G 72. The plaintiffs also discovered that on Glamulet’s pages on H Facebook GLAMULET was displaying images of P1’s jewellery with the I J K L PANDORA & Device Mark as evidenced by exhibit HWME–33 to Elms’ 1st affidavit (“the Facebook pages”). 73. I J Also, the evidence shows that GLAMULET had been purchasing Google AdWords that contain the plaintiffs’ brand name K L PANDORA. M N M 74. As set out in the 1st affidavit of Elms, most of the Glamulet N websites are currently controlled and operated by D1. On the evidence, O P it is clearly stated on the terms and conditions page that all transactions are processed by D1 with its address at Unit E, 15/F, Cheuk Nang Plaza, O P 250 Hennessy Road, Wanchai Hong Kong. It is also stated that the site is Q Q controlled and operated by D1. R R 75. S T Prior to the incorporation of D1 on 18 March 2015, the Glamulet business appears to have been carried out by D2 as evidenced by the previous version of the terms and conditions posted on the glamulet.com website on 11 December 2014. S T This stated that U U V V