1. This is an application for restraining the Defendants from inter alia misappropriating Plaintiffs registered and well known trade mark MILLENNIUM and 
logo (the "Five Bar M logo") and using identical or deceptively similar trade mark(s).
2. The mark/logo of the defendant is given herein:
3. The case of the plaintiff is as follows:
a. Plaintiff is a wholly-owned subsidiary of Millennium and Copthorne Hotels plc ("M&C"). M&C is a London-based publicly listed hotel and resort company incorporated under the laws of England and Wales. It is featured on the London Stock Exchange since 1996. The M&C Group is one of the top 15 hotel groups in the world. The M&C Group owns and operates a leading chain of over 126 international five-star and four-star hotels in diverse locations, in more than 23 countries, under world-famous and reputed brands such as but not limited to MILLENNIUM and GRAND MILLENNIUM etc. The M&C group since 1994 owned, controlled and propagated the MILLENNIUM brand and trade mark and 
logo for hotel properties in numerous countries around the world and is registered proprietor, inter alia, of the trade marks MILLENNIUM and 
logo of the M&C Group. The defendant no. 1 is the company which owns and operates MILLENNIUM Hotel vis. Defendant no. 3. Defendant no. 2 is the Chairman and Managing Director of Defendant no. 1;
b. the M&C Group adopted the trademark/name MILLENNIUM in 1994 and has been extensively using this name and is 
recognized as a symbol of high-quality hotels and services globally and in India. In 1995, the Plaintiff also conceived and adopted the unique, distinctive, contrived and highly stylized "Five Bar M logo" 
. This Logo has been a constant feature of the identity of the M&C Group and is displayed in all its hotels, websites, stationery and other hospitality-related products;
c. it is the most valued asset of the M&C group. In India the plaintiff is proprietor of various trademarks consisting of and/or containing MILLENIUM/MILLENNIUM and/or 
logo including MILLENIUM/hotels and resorts in Classes 35, 36, 42 and 43 for hotels and related services, with the earliest such registrations belonging to Class 16 and having dated back to 1995. Such registration are given in para 17 of the plaint; the earliest of the registration goes to November 03, 2003. Registration of the trademark of the plaintiff in Class 16 dated back to February 8, 1995 and its locations have been used in various movies. The world wide turnover of M&C group is given in para 25 of the plaint;
d. it is argued that M&C group extensively promotes its hotels and services on the Internet especially through its official website www.millenniumhotels.com, owned and operated since 1999 inter alia for online bookings to customers internationally and in India and such documents have been filed along with the plaint. The M&C group is also the owner of numerous other domain featuring the similar name as stated in para 28 and the websites as stated in para 29 & 30 of the plaint;
e. Indian travelling to any part of the world can avail the services of M&C group through various other travel and hotel booking websites/portals such as www.makemvtrip.com, www........