Trademark Protection In The Digital Age; Domain Name

Author: LawSphereX

Category: Technology, Cyber & Privacy

Published: 2026-08-23T21:35:50.855Z

Updated: 2026-08-30T07:11:32.059Z

TRADEMARK PROTECTION IN THE DIGITAL AGE;

DOMAIN NAME Pooja Nair PR, LLM (Corporate and Commercial Law), Christ (Deemed To Be) University Bangalore

ABSTRACT

This paper is dealing about the Trademark protection in digital age in the matter of Domain name. India is the 8th largest market for eCommerce with a predicted revenue of US$71,292. 1 million by 2023 and India Poised to Be 2nd-Largest E-Shopper Base Globally, E-Retail to Hit 70 billion By 2027.

This paper is talking about issues raised by the trademark holders in online and it gives a brief about cybersquatting which referred to as domain squatting, Counterfeiting refers to the practise of making fake copies of a commodity, documentation, or currencies without permission of the original owner or consent from the appropriate authority, Typosquattting refers to a person who registers with common typos of the company’s domain name, Cyber Twin refers to issues raised between domain name holder and the person who have the right to claim over the domain name, Domain Name Warehousing refers to the person who is holding expired domain name. The paper will focus on the remedies which are available under Indian laws Trademark act, 1999 and it further divided into civil remedies and criminal remedies. It further focuses on strategic goals of WIPO and ICANN.

This paper describes the digital protection in long run along with the case studies which are related to the importance of digital protection.

INTRODUCTION

In the digital age, trademarks are more important than ever. With the rise of online commerce and social media, businesses need to do everything they can to protect their brands from infringement. One of the most important ways to protect a trademark is to register it with the United States Patent and Trademark Office (USPTO)1. Registration gives the owner of the trademark the exclusive right to use it in commerce. This means that no one else can use the trademark without the owner's permission. In addition to registration, there are a number of other things that businesses can do to protect their trademarks in the digital age. These include: * Monitoring the internet for unauthorized use of the trademark2. * Filing trademark infringement lawsuits3. * Sending cease-and-desist letters to infringers4. * Educating customers about the importance of protecting trademarks5.

Domain names are also important assets for businesses. A domain name is the address of a website on the internet. For example, the domain name for Google is "www. google. com. " When choosing a domain name, it is important to choose one that is relevant to the business's products or services. It is also important to choose a domain name that is not already in use by another business. DEFINITION OF TRADEMARK: A trademark is a sign that is used to distinguish the goods or services of one party from those

1 U.S. Patent and Trademark Office. General Information on Trademark Protection. (2024)

2 U.S. Patent and Trademark Office. US Intellectual Property and Counterfeit Goods – Landscape Review. (2020)

3 U.S. Patent and Trademark Office. “Trademark Infringement.” USPTO Infringement.

4 U.S. Patent and Trademark Office. “Cease and Desist Letters.” USPTO Cease and Desist.

5 U.S. Patent and Trademark Office. “Importance of Trademarks.” USPTO Importance.

of others6. Trademarks can be words, phrases, symbols, designs, or even sounds. They can be registered with a government agency to provide the owner with exclusive rights to use them. Trademarks are important because they help consumers identify and choose the goods and services they want. They also help businesses to build brand recognition and reputation. DEFINITION OF DOMAIN NAME: A domain name is a unique identifier that is used to locate and access websites on the internet7.

Domain names are registered with domain name registrars, who are authorized by the Internet Corporation for Assigned Names and Numbers (ICANN) to manage the registration of domain names. Domain names can be registered for a variety of purposes, including for personal use, business use, or to protect a trademark. When a domain name is registered for business use, it can be considered a form of intellectual property. This means that the owner of the domain name has certain rights to use and control the domain name, and others cannot use the domain name in a way that is likely to cause confusion or deception. There are a number of ways to protect a domain name under intellectual property law. One way is to register the domain name as a trademark.

This will give the owner of the trademark the exclusive right to use the domain name in connection with the goods or services that are covered by the trademark. Another way to protect a domain name is to file a domain name registration dispute with ICANN. This is a process that can be used to resolve disputes between two parties who are claiming ownership of the same domain name. Domain names are valuable assets, and it is important to take steps to protect them from infringement. By registering a domain name as a trademark or filing a domain name registration dispute, you can help to ensure that your domain name is used for its intended purpose and that you are able to benefit from its value. Here are some additional things to keep in mind about domain names and intellectual property

6 United States Patent and Trademark Office. “What is a Trademark?” USPTO Trademark Definition.

7 Internet Corporation for Assigned Names and Numbers (ICANN). “What is a Domain Name?” ICANN

Domain Name. law: * Domain names are not trademarks by default. In order for a domain name to be considered a trademark, it must be used in connection with goods or services in a way that is likely to cause confusion or deception. * Even if a domain name is not registered as a trademark, it may still be protected by trademark law if it is used in a way that is likely to cause confusion or deception. * It is possible to register a domain name that is identical or similar to a trademark owned by another party. However, doing so may lead to a domain name registration dispute. * If you believe that your domain name has been infringed, you may be able to file a lawsuit or file a domain name registration dispute. PROCEDURE TO OBTAIN DOMAIN NAME: The process for registering a domain name is similar to that for a trademark, with the following steps:

1 Search for existing trademarks

A trademark search is not required, but it is suggested for safety reasons8.

2. File a trademark application via the e-portal to the Trade Mark Department registrar.

3 Obtain TM numbers

A TM number is obtained from the TM Department and submitted to the registrar of Trade Marks within two days.

4 Submit an examination report

The Trade Marks Department sends an examination report within 12 months, and the applicant must respond to the report and address objections.

5. Submit written documentation in the form of an affidavit supporting the use of a trademark.

6 Audition

The applicant must defend the application on merit before the registrar decides whether to grant registration. 8 United States Patent and Trademark Office. “Conducting a Trademark Search.” USPTO Trademark Search.

7 Publishing or promoting the trademark in a trade mark magazine

The trademark will be published in the Trade Mark Journal (TMJ) after registration is approved. If opposition is lodged, the applicant has four months to submit a notice of opposition.

8 Opposition's case

The outcome of opposition procedures varies, and the registrar must decide whether to register the mark after hearing from both parties.

9 Trademark renewal

Trademarks must be renewed every ten years, and applicants must provide necessary documentation, such as the name of the business owner, partners, and directors, full postal address and phone numbers, and a copy of the firm's certificate of registration.

10. For each application, 15 labels must be sent, including the time frame and description of

the products or services for which the registration application is being made. IMPORTANCE OF REGISTRATION OF DOMAIN NAME: The digital age has brought with it new challenges for trademark protection. In the past, trademarks were primarily protected through registration with national governments. However, with the rise of the internet, it has become possible for anyone to register a domain name that is identical or similar to a registered trademark. This has led to a surge in trademark infringement cases involving domain names9. DOMAIN NAME INFRINGEMENT: The word infringement refers to unauthorized use, duplication, or sales of materials or products that are legally regarded as protected intellectual property (IP)10. The domain name infringements include cybersquatting, counterfeiting, typo-squatting, cyber twin, domain name warehousing etc...

1 CYBERSQUATTING

Cybersquatting is a type of intellectual property (IP) infringement that occurs when someone

9 United States Patent and Trademark Office, "Trademark Basics"

10 World Intellectual Property Organization, "What is Intellectual Property?"

registers, uses, or sells a domain name that is identical or confusingly similar to a trademark or service mark owned by another party. The cybersquatter typically registers the domain name with the intent to profit from the goodwill11 associated with the trademark or service mark, such as by selling the domain name to the trademark owner or by using it to redirect traffic to a website that is unrelated to the trademark or service mark. Cybersquatting is prohibited under both the Anti cybersquatting Consumer Protection Act (ACPA) and the Uniform Domain Name Dispute Resolution Policy (UDRP)12. The ACPA is a federal law that provides trademark owners with a cause of action against cyber-squatters. The UDRP is a set of rules that governs how domain name disputes are resolved through arbitration.

1.1 CASE STUDY

Amul case; With a fiscal year 2019–2020 annual turnover of more than 38,550 crore Indian rupees (about $5.28 billion, or 385,500,000,000 Indian Rupees), Amul is one of India's top dairy companies. Someone set up phishing websites for the business using the following domain names, making it a target of cybersquatting: Amuldistributor.com Amulboard.com Amufran.org.in Amuldistributorindia.com13 The crooks' behaviour is As part of their scheme, they opened phoney bank accounts in Amul's name and sent fraudulent forms via email. They demanded payment in order to become an Amul distributor and franchisee.

11 Anticybersquatting Consumer Protection Act (ACPA)

12 Uniform Domain Name Dispute Resolution Policy (UDRP)

13 Amul cybersquatting incident, 2018-2020

They launched recruiting scams on the website in which candidates were required to pay a fee in order to apply for positions. Between 2018 and 2020, a scam was carried out.

1.2 REMEDIES

To establish a claim under the ACPA, a trademark owner must prove that: * The cybersquatter registered the domain name with the intent to profit from the trademark or service mark; * The domain name is identical or confusingly similar to the trademark or service mark; and * The cybersquatter has no legitimate rights or interests in the domain name. To establish a claim under the UDRP, a trademark owner must prove that: * The domain name is identical or confusingly similar to a trademark or service mark in which the trademark owner has rights; * The domain name was registered and is being used in bad faith14; and * The trademark owner has no legitimate interests in the domain name.

If a trademark owner is successful in either an ACPA or UDRP proceeding, the court or arbitrator may order the cybersquatter to transfer the domain name to the trademark owner or to pay damages to the trademark owner. Here are some examples of cybersquatting: * Registering the domain name "nike. com" with the intent to sell it to Nike, Inc.

14 ACPA and UDRP claim requirements

Registering the domain name "apple.com" and using it to redirect traffic to a website that sells counterfeit Apple products * Registering the domain name "microsoft.com" and using it to send spam emails

ICANN; Filing a complaint with one of India's many courts. Can give the online squatter a cease-and-desist letter. The victim might seek a passingoff order from the online squatter.

2 COUNTERFEITING

Counterfeiting in domain name under IPR is a type of intellectual property (IP) infringement that occurs when someone registers, uses, or sells a domain name that is identical or confusingly similar to a trademark or service mark owned by another party, with the intent to deceive consumers into believing that the website is affiliated with the trademark owner15. This can harm the trademark owner's reputation and business, and can also lead to consumer confusion and financial losses. The word counterfeiting is not mentioned under the Trademark Act, 1999 and also it neither defined or nor penalized under the Act. But it has been mentioned in the Act as ‘falsifying trade mark’ or ‘falsely applying a trade mark16’.

There are a number of ways to counterfeit a domain name, including: Registering a domain name that is identical or confusingly similar to a trademark or service mark owned by another party. Using a domain name that is identical or confusingly similar to a trademark or service mark owned by another party to redirect traffic to a website that is not affiliated with the trademark owner.

15 World Intellectual Property Organization, "Counterfeiting"

16 The Trademark Act, 1999 (India)

Using a domain name that is identical or confusingly similar to a trademark or service mark owned by another party to sell counterfeit goods or services Counterfeiting in domain name is a violation of both trademark law and the Anticybersquatting Consumer Protection Act (ACPA). Counterfeiting is defined under Indian Penal Code, 186017 in section 28 of IPC states that “A person is said to counterfeit who causes one thing to resemble another thing, intending by means of that resemblance to practise deception, or knowing it to be likely that deception will thereby be practised”.

2.1 CASE STUDY

SIRONA HYGIENE PRIVATE LIMITED V. PARULBEN NAVNATH CHOTHANI TRADING AS SHIV ENTERPRISE & ORS CS(COMM)260/2022 In this case Justice Pratibha M. Singh of Hon’ble Delhi court condemned the counterfeit goods or products has increased in internet and needs to be arrested to protect the rights of the owner of the trademark as also the customer who purchase these products18.

2.2 REMEDIES

The trade mark law offers administrative remedies, allowing the party who has been wronged to have his complaint addressed by requesting the Trademark Registry's assistance, which operates through the Registrar of Trademarks. The act also gives the trade mark owner the ability to sue for infringement. Additionally, the trademarks act gives the court the authority to issue ex-parte injunctions in the right circumstances to stop counterfeiters from selling their products and to facilitate the discovery of papers or other pertinent evidence. The law also offers civil relief, such as restraining orders, accounts of earnings, and the delivery of

17 Indian Penal Code, 1860, Section 28

18 SIRONA HYGIENE PRIVATE LIMITED V. PARULBEN NAVNATH CHOTHANI TRADING AS SHIV

ENTERPRISE & ORS CS(COMM)260/2022 counterfeit goods for destruction19. The Trade Mark Act, 1999 under the section 103 provides penalty for false trademark or trade description etc, with imprisonment up to three years and a fine may extend from fifty thousand to two lakhs20.

3 TYPOSQUATTING

Typosquatting is a form of cybersquatting in which cybersquatters register domain names that are very similar to the domain names of well-known brands, but contain common misspellings or typographical errors. They then use these domain names to create fake websites that are designed to look like the legitimate websites. When unsuspecting internet users visit these fake websites, they may be tricked into providing personal information, such as credit card numbers or passwords, or they may be infected with malware21. Under intellectual property law (IPR), typosquatting can be a violation of trademark law. Trademark law protects words, phrases, symbols, and designs that are used to identify and distinguish the goods and services of one company from those of another. Typosquatting is a serious problem that can harm businesses and consumers.

By registering domain names that are identical or confusingly similar to trademarks owned by other companies, cybersquatters can divert internet traffic away from the legitimate websites, steal personal information, and profit from the trademark owner's goodwill. The essentials of typosquatting creating a domain name: (1) typographical errors; (2) frequent misspellings, such as foreign language and phonetic spellings; (3) differently phrased domain names, such as singular/plural terms; and (4) various top-level domain names, such as the substitution of ". com" for ". org", etc. The category of misspellings based on typing mistakes is the most common. Typosquatting frequently takes advantage of mistakes in writing, for instance: Swapping letters: http://www. kk-lpl. com

19 The Trade Mark Act, 1999

20 The Trade Mark Act, 1999 under the section 103 provides penalty for false trademark or trade description etc

21 WIPO, "Domain Name System Abuses

Typosquatting, " http://www.k-llp.com and http://www.kkll.com have missing letters. Double-spaced letters: http://www.kk-lllp.com The following URLs include typos: http://www.kk-ll.com, http://www.kk-lllp.com, and http://www.jj-kkp.com.

3.1 CASE STUDY

Yahoo! Inc. v. Akash Arora &Anr(1999) Delhi HC7 This case relates to unauthorised use of internet domain name that are identical to the registered trademark. In this case , the defendant using the domain name ' Yahoo India' which was very similar to the registered domain name ' Yahoo! ' It was determined that the defendant's "Yahoo India" could lead internet users to become confused and deceived into thinking that both are the same and are a part of the same "Yahoo! " The court stated that the defendant's disclaimer in this respect is insufficient and that it is irrelevant whether the word "Yahoo" has a dictionary definition because Yahoo! has already amassed the necessary "distinctiveness" and "uniqueness" as needed by trademark law over the years.

The High Court has also ruled that commercial organisations utilise internet domain names for the same functions as any trademark or service mark22. Gulshan Khatri v. Google Inc. , 2017 This case A complaint was submitted in this case to contest the registration of the domain name "googlee. in"23. According to the complaint, the respondent's domain name is conceptually and aesthetically identical to the complainant's domain name, and the respondent is attempting to capitalise on the long-standing reputation of the complainant. The complainant argued that the domain name "googlee. in" in response appeared to be directly associated with them. Additionally, it was argued that the domain name, which is utilised for the search engine, would confuse the audience and be perceived negatively by them. While the complaint domain name "google.

in" had been registered and was active on the market since 1997, the respondent registered the

22 Yahoo! Inc. v. Akash Arora &Anr(1999) Delhi HC7

23 Gulshan Khatri v. Google Inc., 2017

domain in 2007. The arbitrator in this dispute determined that the domain name "googlee.in" was the same as another previously registered domain name, and he or she ordered the registry to cancel the former and transfer the latter to the complainant.

3.2 REMEDIES

In instances of typosquatting, trademark owners have two options for reclaiming ownership of the cybersquatted domain name: they can file a lawsuit in U.S. federal court under the Anti-Cybersquatting Consumer Protection Act (ACPA) or they can choose to pursue an administrative proceeding under the Uniform Dispute Resolution Policy (UDRP), developed by the Internet Corporation for Assigned Names and Numbers (ICANN).

4 CYBER TWIN

It describes a circumstance in which each party to the dispute has a legitimate claim to a specific domain name. Both parties have a rightful claim to the domain name in this case. The most challenging issues to resolve include cyber twins because the law of trademark and unfair competition may otherwise let both parties to benefit from concurrent use of both. A cyber twin is a domain name that is identical or confusingly similar to a trademark owned by another party. Cyber twins can be registered in bad faith with the intention of selling them to the trademark owner or using them to divert traffic away from the trademark owner's website. Under intellectual property (IP) law, cyber twins can be considered trademark infringement. The trademark owner may be able to file a lawsuit against the cyber twin registrant to have the domain name transferred to them or to have it cancelled.

In order to prove trademark infringement, the trademark owner must show that: They have a valid trademark; The cyber twin is identical or confusingly similar to their trademark; The cyber twin is used in commerce; and The use of the cyber twin is likely to cause confusion, mistake, or deception. If the trademark owner is successful in their lawsuit, the court may order the cyber twin registrant to transfer the domain name to them or to have it cancelled. The court may also award the trademark owner damages, including lost profits and attorneys' fees. In addition to trademark infringement, cyber twins can also be considered cybersquatting.

4.1 CASE STUDY

Online India Capital Co. Private. Ltd. Vs. Dimensions Corporate In this case where two people contend that they are the rightful owners of the domain name and that another person or company registered the name first. Here a lawsuit where the plaintiff is requesting a permanent injunction to stop the defendant from using the website name www. mutualfundindia. com because it is similar to the plaintiff's website name www. mutualfundsindia. com. The plaintiff's side countered that all of the financial services and information on their website were a result of their study and analysis and that they had registered their domain name 7-8 months prior to the defendant's registration24. Its entire clientele, which includes Alliance Capital and Kotak Mahindra Mutual Fund.

All of their clients, such as Kotak Mahindra Mutual Fund, Alliance Capital Mutual Fund, and Taurus Mutual Fund, advertised on the aforementioned website; nevertheless, the distribution of their clients is only caused by the letter 'S' in the two site names.

24 Online India Capital Co. Private. Ltd. Vs. Dimensions Corporate 2000VAD(DELHI)860,

[2000]102COMPCAS352(DELHI), 2000 A I H C 2964, 2000 CLC 1631 (DEL), (2000) 85 DLT 733, (2000) 3 ARBILR 196, (2000) 102 COMCAS 362 The defendants argued that because the phrases "MUTUAL FUND INDIA" are so generic and descriptive in and of themselves, making them common to use on a daily basis as well, it makes no sense to have a monopoly on such non-novel or nonunique words. The defendants further demonstrated that their website was registered six years before to the plaintiff's. They are unable to implement a check method to determine who registers after them all. After reviewing the ratios of both parties' arguments, the court reached a conclusion. In the case of Data Concepts, Inc. v Digital Consulting Inc. , The plaintiff failed to demonstrate that the name of their website has any secondary meaning, which is a requirement to establish in order to obtain the court's favour.

The court came to the conclusion that yes, mutual fund India, these words are descriptive and can be used by many people. As a result, the case was dropped25. Due to their respective trademark rights for DCI, both organisations have a rightful claim to the domain name (dci. com). But Data Concepts managed to register the trademark dci. com in 1993. The entity that registered first would appear to win in situations when both parties had rights, but the Sixth Circuit determined that there was still a chance of infringement. A full trial must be held in order to determine whether trademark infringement occurred because it is both a factual and legal issue. Due to a lack of proof and the fact that Digital was unaware that Data had ever existed, the action was dismissed because Data did not support claims that dci. com misled users about the two marks.

A company's trademark is subject to additional problems in cyberspace in addition to those already discussed. Another place in cyberspace where a trademark dispute can occur is in hypertext connections. It simply means moving a user from one area of a website to another. Between web pages, these links are placed. For instance, when we click a "Gucci" hyperlink on a website, we are not directed to the company's official website but rather to another website that may sell a comparable

25 Gulshan Khatri vs Google Inc. on 20 March, 2017

product but not one from the Gucci brand. Infringing trademarks is the result of these linkages. Further, it is easy to control the hyperlink present in cyberspace. Therefore, a practical answer is yet to be devised in this aspect.

4.2 REMEDIES

If a trademark is violated online, there are several different remedies that can be used. A forum has been established within the World Intellectual Property Organisation (WIPO), which was established for the protection of intellectual property, where claims can be made on a global scale. In addition, several more laws have been passed to offer remedies. Additionally, Section 28 of the Trademarks Act gives a trademark owner the sole authority to use their brand and forbid others from using it. The National Internet Exchange of India was established in 2003 to help the nation provide adequate and improved internet services. Additionally, it offers some defence against online trademark infringement.

5 DOMAIN NAME WAREHOUSING

The act of "holding" expired domains rather than releasing them back into the public domain is known as this. The registrar attempts to sell particular domains to the prior registrant or a new registrant at a price above the going rate by blocking their release. DOMAIN NAME PROTECTION IN ICANN AND WIPO: Only in those national and international countries where they are validly registered do trademarks receive recognition and protection; they may not be protected globally. Only one organisation, ICANN [Internet Corporation for Assigned Names and Numbers], registers and supremely protects domain names as trademarks or service marks, in addition to receiving national and international protection under the relevant nation's trademark law and various international trademark treaties.

A domain name cannot be completely protected by any national or international trademark law anywhere in the globe. The WIPO (World Intellectual Property Organisation) and the ICANN have recommended the two strong and severe steps listed below to achieve this crucial goal: strict and censored system of domain name registration through accredited registrars [by ICANN] and an effective and efficient dispute resolution procedure known as the Uniform Domain Name Disputes Resolution procedure (UDNDR Policy). DIGITAL PROTECTION IN LONG RUN: Today the technology is moving towards digitalization and the importance of data protection have increased. Demand for domain name registrations associated with certain companies, products, or services has increased as a result of the rapid expansion of online business and advertising.

There have been a number of issues involving intellectual property infringement as a result of the rush to reserve domain names. Many people are under the impression that if they successfully register a domain name with a business, they automatically have the right to use it. The notion that a trademark is no longer required to reserve rights to use a domain name is simply untrue; when a domain name is registered, you are, in fact, purchasing certain rights to use the domain name. However, simply registering a domain name does not automatically grant you the right to use it. This is because any rights you acquired by registering the domain name are still limited by and subject to trademark laws. A common misconception is that if a domain name has been successfully registered with a business, the owner has the right to utilise it.

It's a common misconception that you can reserve the right to use a domain name without registering a trademark, but this is simply untrue. When you register a domain name, you are, in fact, buying the right to use the name. The mere act of registering a domain name, however, does not automatically grant you the right to use the domain name. This is due to the fact that whatever rights you might have obtained by registering the domain name are nonetheless constrained by and governed by trademark regulations. It is very important to have the knowledge about the digital protection for a long run.

CONCLUSION

In India, domain names can be protected as trademarks under the Trade Marks Act, 1999. However, there are some specific requirements that must be met in order for a domain name to be registered as a trademark. These requirements include: * The domain name must be distinctive. This means that it must be unique and memorable, and it should not be easily confused with other domain names or trademarks. * The domain name must be used in connection with goods or services. This means that the domain name must be used to identify and distinguish the goods or services of the trademark owner from those of others. * The domain name must not be descriptive of the goods or services that it is used in connection with. This is because descriptive trademarks are not registrable under the Trade Marks Act. If a domain name meets all of these requirements, it can be registered as a trademark.

This will give the trademark owner the exclusive right to use the domain name in connection with the goods or services that it is registered for.

REFERENCE

1) The Trade Marks Act, 1999 (India) – Retrieved from https://ipindia.gov.in

2) ICANN. Uniform Domain Name Dispute Resolution Policy (UDRP). Retrieved from

https://www.icann.org/udrp

3) WIPO.

Domain Name Dispute Resolution Policies. Retrieved from https://www.wipo.int/amc/en/domains/

4) Yahoo! Inc. v. Akash Arora & Anr., 1999 (Delhi High Court). Retrieved from

https://indiankanoon.org/doc/1782415/

5) Sirona Hygiene Private Limited v. Parulben Navnath Chothani Trading as Shiv Enterprise

& Ors., 2022 (Delhi High Court). Retrieved from https://indiankanoon.org/doc/1564904/

6) Online India Capital Co. Pvt. Ltd. vs. Dimensions Corporate, 2000 (Delhi High Court).

Retrieved from https://indiankanoon.org/doc/1204445/

7) Data Concepts, Inc. v. Digital Consulting Inc., 150 F.3d 620 (6th Cir. 1998). Retrieved

from https://openjurist.org/150/f3d/620/data-concepts-inc-v-digital-consulting-inc

8) Gulshan Khatri v. Google Inc., 2017 (IN Arbitration). Retrieved from https://www.nixi.in