Our Ref: RSRL-____ April 13, 2021

To,
Anuradha Salhotra
RCY House,
C-235, Defence Colony,
New Delhi – 110 024,
India Without Prejudice
By Email
mail@rahulchaudhary.com
Kind Attention: Mrs. Anuradha Salhotra, Advocate

Re: Reply to Cease & Desist Notice dated 6th April, 2021

Mrs. Salhotra,

We write to you on behalf of and under instructions from Our Client, Mr. Nirmal Dhiran Kumar
trading as M/S NKV Home Depot, and in response to the cease and desist notice dated April 6,
2021, addressed to them on behalf of Home Depot International, Inc.

At the outset, Our Client denies and disputes all the contentions and submissions made in the
cease and desist notice, except those which are admitted. It is vehemently denied that Our Client
have in any manner adopted and/or using a similar trade name / trade mark / domain name to your
Company’s trade name / trade mark / domain name The Home Depot.

As it is clearly evident from the table in paragraph 4 of your notice, your Client deals in
manufacturing and trading of home improvement tools and providing home improvement services
including interior designing consultancy under the mark The Home Depot. On the contrary, Our
Client deals in manufacture and trading of gypsum products. Furthermore, Our Client’s trade
name / trade mark NKV Home Depot is entirely distinct from your Company’s trade name /
mark The Home Depot, when seen in totality. Therefore, there is no likelihood of confusion or
deception to the public or the trade.

Notwithstanding the above and without going further into the merits of the matter, to which Our
Clients reserve the right to respond to (if required), Our Clients have agreed to settle the matter
amicably. They have upon the receipt of your notice discontinued the manufacturing of their
gypsum and other products under the mark NKV Home Depot, and are in the process of adopting
a different trade name / mark.

Further, with respect to the products and packaging material in their possession, Our Clients are
in the process of ascertaining the quantity and shall destroy the same within a suitable time
frame. Furthermore, our Client are also under process to take-down all third party websites and
social media accounts where they have used / using their mark NKV Home Depot.

Hope that with the above, the matter can be concluded as settled.

Regards,

Rohan Rohatgi
Advocate
(Enrl. No.: D/1050/2009)