Petition Requesting the Prevention of Violation of Names

TO THE DUTY PRIMARY CIVIL COURT
OF ISTANBUL

A request for interim measures has been made.

PLAINTIFF:
[Name and Surname] (Turkish Republic Identity Number: …)
Address: …

ATTORNEY:
Attorney [Name and Surname]
Address: …

DEFENDANT:
[Name and Surname or Title]
Address: …

SUBJECT: Request to prevent damage to commercial reputation and unfair competition.

EXPLANATIONS

1. My client is a well-known and highly reputable businessman throughout Turkey. He has been operating in the [sector name] industry for many years and, due to his successes, has become one of the leading brands in the sector.
2. The defendant, despite having no connection whatsoever to my client's business, is conducting misleading advertising and promotional campaigns on social media platforms and various news websites, using my client's name in a way that damages my client's trade name and reputation. This constitutes a clear act of usurpation of my client's commercial reputation.
3. The defendant's actions are damaging my client's reputation and causing material and moral harm. If the defendant continues with these misleading advertising campaigns, my client's customer base will lose trust, resulting in irreparable damage.
4. Therefore, the defendant must cease these misleading advertisements, and any activities involving the unlawful use of my client's trade name must be prevented through an injunction until the end of the trial.

EVIDENCE

1. Misleading advertisements on social media platforms,
2. Relevant news website records and screenshots,
3. Witness statements,
4. Other legal and statutory evidence.

LEGAL GROUNDS

Turkish Commercial Code Articles 54-63, Turkish Civil Code Articles 24-25 and related legislation.

CONCLUSION AND REQUEST

For the reasons stated above;

1. The defendant's promotional and advertising activities, which are carried out without the right to use my client's trade name, must be immediately stopped
2. A precautionary measure order shall be issued until the end of the trial
3. The court costs and attorney's fees shall be borne by the defendant

I respectfully request and demand that a decision be made.

Date: …/…/…
Plaintiff's Attorney
: [Name and Surname]
Signature