IN THE COURT OF SENIOR CIVIL JUDGE, KARACHI

Suit No. : ________ 2019

Starbucks Coffee House, 2401-Utah Avenue South Seattle, Washington, United

States.
Plaintiff.
Versus
Sattar Buksh Caffe, Block-4 Clifton in Karachi, Pakistan.
Defendant.

Suit for Trademark Infringement

WRITTEN STATEMENT TO THE SUIT FILED BY PLAINTIFF
Most Respectfully Sheweth:
1. The suit is not maintainable, either in law or in facts.
2. The suit is vague and misconceived as the allegations made in the plaint are
false, fictitious and self-serving.
3. Para no. 1 of the plaint is admitted and needs no reply.
4. Para no. 2 of the plaint is admitted and needs no reply.
5. Contents of Para. 3 are based on false allegations and are out-rightly denied.
6. As far as the name is concerned Starbucks was established in 1973, while
the name Sattar Buksh has been around for at least 500 years or more, so the
name cannot be contested.
7. Contents of Para. 5 are out rightly denied as Defendant’s logo font and
colour values are different. The logo has a moustache guy instead of a
mermaid like that of Plaintiff’s, as well as tea leaves and coffee beans. The
black, twisted moustache is a symbol of command and power of manhood in
this region and can therefore not be mixed up with the Plaintiff’s logo.
8. Contents of Para. 6 denied. The coffee served by Defendant is not
Starbucks’ but a Brazilian blend that no other coffee shop in Pakistan is
serving.
9. The menu served by the Defendant ranges from desi to continental foods as
the owner took food courses in Italy.
 10. Contents of Para. 7 and 8 are denied. The defendant never received any
notice from the plaintiff in this regard. No cause of action has accrued in
favour of the plaintiff and against the defendant.
11. Para. 10 denied. The plaintiff has not annexed requisite court fee.

PRAYER
It is therefore, prayed that titled suit may kindly be dismissed with costs.

Karachi.
Dated: 11th November, 2020
Defendant.
Sattar Buksh Caffe.
Verification:
It is hereby stated that the facts given above are true and correct to the best of
my knowledge, information and belief.