Delhi HC Grants John Doe Order to Protect Dream11’s Trademark Rights

In a landmark decision, the Delhi High Court granted a John Doe order in favor of Dream11, issuing a permanent injunction against the fraudulent website "dream11lotery.com" and email ID "admin@dream11.com" for trademark and copyright infringement. This case sets a strong precedent for brand protection in India's digital landscape.

Trademark Jun 4, 2025 0 Add to Reading List

Delhi HC Grants John Doe Order to Protect Dream11’s Trademark Rights

BACKGROUND OF THE CASE

This case deals with trademark infringement and copyright infringment . Parties involes in the case were plaintiff -Sporta Technologies Private Limited and defendant –anonymous person . the suit was filed by sporta technologies private limited against defendant for seeking permenat injuction .so basically in this case infringers used registerd trademark dream11. They have created dream11lotery.com. which was simiar to dream11 .

dream11 is platforms wheres users make virtual team and user earns points based on player performance. The plaintiff argured that infringers uses similar mark and misled the public , copied visual element and design leading to cop[yright infringement .the court supported the claims made by plaintif and gave judgement in favour of plaintiff.

Two defendants were identified:

Defendant No. 1: Anonymous individual (referred to as John Doe) who created and ran the fake website.

Defendant No. 2: The domain name registrar of “dream11lotery.com,” who enabled the registration of the deceptive domain .

Justice Mini Pushkarna observed:The fake site’s name and content confused consumers .It was a clear attempt to pass off as the original brand .The defendants violated both trademark and copyright laws.The Court noted that the imitation of Dream11’s website design, style, and content qualified as copyright infringement, in addition to trademark misuse.

The court directed to submit the infringing goods to trademark holder .the defendants did not file written statements despite being served via email. therfore, the Delhi High Court proceeded ex parte, meaning it ruled in favor of the plaintiffs without requiring a trial. The court exercised its authority under Order VIII Rule 10 of the Civil Procedure Code.
the court oberserved that ex parte evidence would waste of judicial resources since evidence produced by plaintiff was sufficient to make judgement in favour of plaintiff.

The Court issued a permanent injunction:Banning the use of Dream11-like marks, domain names, or content Ordering the suspension of the fake domain Directing the domain registrar to reveal the registrant’s details . The Court also held that recording ex parte evidence would waste judicial time, as the evidence on record was already sufficient to rule in favor of the plaintiffs.

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Legal Reasoning

Trademark Infringement:The defendants used the word “DREAM” and a domain almost identical to “dream11.com,” causing confusion among users. This violated the exclusive rights Dream11 had under the Trade Marks Act, 1999.

Copyright Infringement:The fake website copied the layout, design, fonts, and promotional content of Dream11’s platform. Such elements are considered original creative work protected under the Copyright Act, 1957.

Passing Off: Even if the fake site hadn’t used the exact trademark, it looked and felt similar enough to deceive users, which amounted to passing off—a form of unfair competition

Conclusion

The delhi high court gave judgement in favor of Sporta Technologies Private Limited (Dream11), granting a permanent injunction against the defendants for trademark and copyright infringement. The court found that the defendants had unlawfully used marks similar to "DREAM", domain names like "dream11lotery.com", and the email address "admin@dream11.com", which misled users into believing they were associated with Dream11.

Since the defendants failed to respond despite being served via email, the court proceeded ex parte and exercised its authority under Order VIII Rule 10 of the Civil Procedure Code. The court said that recording ex parte evidence would waste judicial resources. The court upheld plaintiff claims and restricted the defendants from further infringing activities, the court provided comprehensive relief to protect Dream11’s brand and intellectual property.

This judgment is a strong message against online brand impersonation. The Delhi High Court reaffirmed that digital platforms are entitled to full protection under intellectual property laws. By upholding Dream11’s rights, the Court has set a precedent for combating cyber fraud, safeguarding brand reputation, and ensuring consumer trust in the digital era.