Petition for a Lawsuit to Prevent Unfair Competition

TO THE DUTY PRIMARY COMMERCIAL COURT
OF ANKARA

PLAINTIFF: … Inc. Chairman of the Board of Directors
Name and Surname – (Turkish Republic Identity Number: …) – Address

ATTORNEY: Lawyer's Name and Surname – Address

DEFENDANT: Name and Surname – Address

SUBJECT OF THE LAWSUIT: Prevention of unfair competition.

EXPLANATIONS:

1. Our client company's specially designed bags, which have been produced under patent for ... years, have been counterfeited and put on the market by the defendant without our client's permission. The defendant not only counterfeited the product but also copied its design exactly, without even changing the product name. This behavior of the defendant is causing our client a difficult position in the market. Our client is forced to replace products it doesn't sell, and the sale of these products at different prices is creating a trust issue among customers. The defendant's behavior is damaging our client company in every respect.
2. We will also file separate compensation lawsuits against the defendant for the material and moral damages we have suffered to date, as well as criminal proceedings for the defendant's actions deemed criminal. We request that the court, as a precautionary measure, seize all products in the defendant's possession that are similar to those for which our client holds the patent, as well as all machinery and equipment used in the production of these products, in order to prevent this wrongful conduct. Furthermore, we demand that the sale of the counterfeit products the defendant has put on the market be stopped, and that these products be collected and destroyed. If the court finds us justified, we request that the final judgment be published in national newspapers, with the costs to be borne by the defendant.

EVIDENCE:

1. Patent documents,
2. Commercial registry,
3. Witness accounts,
4. Discovery,
5. Expert examination and all types of evidence.

WITNESSES:

1. Name and Surname – (Turkish Republic Identity Number: …) – Address
2. Name and Surname – (Turkish Republic Identity Number: …) – Address

LEGAL GROUNDS: Turkish Code of Obligations, Turkish Commercial Code, Turkish Code of Civil Procedure, and related legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above,

1. To prevent the defendant's unfair competition,
2. A precautionary measure is requested to seize both the products in the defendant's possession and all machinery and equipment used in the production of these products
3. The defendant is ordered to cease selling counterfeit products and to have these products recalled from the market
4. If your court rules in our favor, the publication of the final judgment in national newspapers will be ordered, with the costs to be borne by the defendant
5. As the plaintiff's attorney, I respectfully request and demand that the court order the defendant to bear the court costs
   

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Plaintiff's
Attorney's Name and
Surname