Sir,

Through you, a notice was sent by your client Actsfolio International, having its registered office at -
Kings Tower No. 887, 6th Cross, First Stage, HBR Layout, Hennur Cross, Bengaluru (Karnataka) 560043 to
our client M/s Pinks Marketing, 108, MG Road, 1st Floor, Indore (M.P.) 452 001. And its proprietor Smt.
Pinky Motwani Husband Shri Daulat Motwani, Thikana – 108, MG Road, 1st Floor, Indore (M.P.) 452 001
dated 08.08.2018, which was received by our client on 20.08.2018. The reply comes from the
information provided by our client as follows :-

(1) That the statement mentioned in para no. 1 of the notice is false and hereby denied, it is denied
that various types of goods were consigned to our client by your client, whose total outstanding was Rs.
13.82,504 /- as on 01.08.2018. The statement mentioned further in this para is also false and hereby
denied that our client has made payment for the aforementioned amount 13,82,504/- in part by a
cheque no. 104186 dates 11.07.2018 issued against Bank of India. It is also false and denied that the
said payment was for the material and purchase order supplied by your client.

With regard to the issue of the impugned cheque, the true fact is that your client and our client had
signed an MoU dated 24.07.2017. According to the terms of which “3 signed and undated blank cheque”
were to be deposited by our client to your client as security deposit, which were deposited with your
client by our client. The statement of your client that the cheques mentioned in para no. 1 we issued by
our client for the partial payment of Rs.13,82,504/-, is completely false and misuse of the cheque given
as security deposit. In truth, as per the MoU dated 24.07.2017 our client had presented 3 undated
signed blank cheques to your client, they have been misused by your client, in respect of which our
client is going to separately initiate legal proceedings against your client.

In respect of payment in the MOU dated 24.07.2017 this condition is also mentioned that, "60 days from
receipt of goods via NEFT or RTGS 3% cash discount for payment within 30 days". Accordingly, if there
was really any payment due to your client by your client, then its payment could have been received
through the medium of banking process of NEFT or RTGS method, which your client has not followed
and thereby defrauded our client and misused the cheques presented as security deposit. In such a
situation, the act done by your client as above is contrary to law and in clear violation of the terms of the
MoU dated 24.07.2017.

In addition to the above actual facts, the goods which you have been authorized by your client to our
client, in relation to that the sales person at the Indore office of your client’s company Mr. Sudev Dubey,
is telling the retailers in and around the areas adjacent to Indore, that “you G.R. (goods return) the
distributor, i.e. our client, and that we will anyhow coerce the money out from the distributor. And Mr.
Sudev Dubey is also telling the retailers that you only return the goods, meaning that there is no need to
pay for the goods to the distributor. The company will not take back the goods from the distributor,
meaning that it will not return the goods, the company will anyhow recover the money from the
distributor.”

Similarly, our client had supplied the goods to the retailer M/s Poyam Stores situated in Mandsaur, and
when our client asked the said retailer to pay for the goods, they said that "Sudev-ji has said that, you do
G.R., and we will anyhow recover the money.” This is how your company and your company's sales
person located in Indore also want to harm our client and are harming the business reputation of our
client.

(2) That, all the statements mentioned in para no. 2 of the notice are denied on grounds of being
false and contrary to the actual facts as above. There is absolutely no liability of our client towards your
client.

(3) That, all the statements mentioned in para No. 3 of the notice are also denied for completely
false in the light of reality as mentioned above. Our client and its proprietor Mrs. Pinky Motwani do not
have any liability towards your client.

(4) That, with regard to the statements given under para no. 4 of the notice, the reply being that
when our client came to know about the aforementioned activities of your client company’s sales
person Mr. Sudev Dubey located at Indore, our client was compelled to ask the concerned bank to do a
stop payment of the cheques given as security to your client, and that the goods that are lying in
possession of our client, are ready to be returned happily. In this regard, our client has several times
intimated Mr. Sudev Dubey, the sales person of your client's company, but Mr. Sudev Dubey did not pay
attention to any information of our client, nor did he give any positive response to your client.

(5) That, all the statements mentioned in para No. 5 of the notice are also denied for completely
false in the light of reality as mentioned above. Our client does not have any liability towards your client.

(6) That, all the statements mentioned in para No. 3 of the notice are also denied for completely
false in the light of reality as mentioned above. When there is no liability of our client is made towards
your client, then in such a situation any question, of getting our client to be punished in respect of any
kind of economic offence and any other kind of punishment mentioned in the Negotiable Instrument
Act, does not arise. Our client is not liable to your client under any circumstances.

(7) That, all the statements mentioned in para No. 7 of the notice are also denied for completely
false in the light of reality as mentioned above. There is no contravention of any provision of the
Negotiable Instrument Act by our client.

(8) That, with regard to the para no. 8 of the notice, the reply is that your client has no legal right to
take any action against our client under Section 138 - Negotiable Instruments Act. Also, in light of the
actual facts as herein stated above your client has no right of claim to ask the payment for the amount
of the cheque.

(9) That, all the statements mentioned in para No. 9 of the notice are also denied for completely
false. In the light of reality of facts as mentioned above, our client is not liable to pay the amount of the
impugned cheques in any time period to your client.

(10) That, all the statements mentioned in para No. 10 of the notice are also denied for completely
false. In the light of reality of facts as mentioned above, our client is not liable to pay the amount of the
impugned cheques in any time period to your client.

Despite this, if any action of any kind is taken by your employer against our client in a competent court,
then our client will properly respond to such litigation. It is necessary to remind your client here again
through you that there was a MOU which had been signed between your client and our client on
24.07.2017. The conditions mentioned therein have been violated by your client, in respect of which
our client is going to institute criminal and legal proceedings against your client.

(11) That, the statements mentioned in the para no. 11 are denied.

(12) That, with respect to the statements mentioned in para no. 12 of the notice letter, the reply is
that our client is not liable to pay any amount of the legal notice sent by you.

Therefore, you are informed through this reply to the notice, you give proper and good advice to the
client to not institute any legal proceedings against our client in the light of the above true facts and
explanations and do not try to get our client involved in any kind of legal proceeding. Despite this, if any
kind of frivolous proceeding is taken by your client against our client, then it will be competently
contested by our client, and in that regard all expenses incurred by our client and your client the liability
for the same will solely rest upon your client only. The fee for this reply to the notice and expenditure is
Rs. 5,100/- made out and due to your client. Let it be known.