Suit for Copyright Infringement

IN THE CIVIL COURT OF court_grade, district

Civil Suit No. _____ of year

plaintiff_name, a resident of plaintiff_address, holding CNIC No. plaintiff_cnic ... Plaintiff

VERSUS

defendant_name, a resident of defendant_address, holding CNIC No. defendant_cnic ... Defendant

SUIT FOR COPYRIGHT INFRINGEMENT, INJUNCTION, DAMAGES, AND DELIVERY UP OF INFRINGING COPIES

The Plaintiff respectfully submits:

1. That the Plaintiff is the author and copyright owner of the following literary, artistic, or musical work: copyrighted_work. The work was first published on publication_date and copyright was registered with the Intellectual Property Organization of Pakistan vide Registration Certificate No. registration_number.

2. That under the Copyright Ordinance 1962, the Plaintiff has the exclusive right to reproduce, publish, perform, and communicate the work to the public.

3. That the Defendant, in gross violation of these exclusive rights, has infringement_act. The infringing copies are being sold/distributed distribution_channel.

4. That the Plaintiff gave notice to the Defendant on notice_date demanding cessation of infringement and removal of infringing copies. The Defendant has ignored this notice and continues to infringe.

5. That the infringing copies are quality_comparison to the Plaintiff's original work, indicating deliberate copying.

6. That the Plaintiff has suffered damages_description as a direct result of the infringement.

7. That there is no defence or justification for the Defendant's conduct. The infringement is infringement_nature.

8. That the Plaintiff is entitled to recover damages, profits earned by the Defendant, injunctive relief, and delivery up of all infringing copies under Section 60 Copyright Ordinance 1962.

9. That this Honourable Court has jurisdiction to entertain this suit as the claim falls within its pecuniary jurisdiction.

PRAYER

The Plaintiff therefore prays that this Honourable Court may be pleased to:

(a) Pass a decree declaring that the Plaintiff is the owner of copyright in the work and that the Defendant has infringed the said copyright;

(b) Grant a permanent injunction restraining the Defendant from reproducing, publishing, distributing, or selling infringing copies;

(c) Award damages to the Plaintiff in the sum of Rs. damages_claimed;

(d) Direct the Defendant to deliver up all infringing copies to the Plaintiff;

(e) Award costs of the suit; and

(f) Grant such further and other relief deemed just and proper in the circumstances.

VERIFICATION

Verified on oath at verification_place on this _____ day of _____, year, that the contents of the above plaint are true and correct to the best of my knowledge and belief.

_____________________________ plaintiff_name Plaintiff Through: _____________________________ counsel_name Advocate