1. The Plaintiff has, by way of the present Suit, sought, inter alia, the protection of his personality rights, his right to privacy, and his right to live with dignity as granted under Article 21 of the Constitution of India, and also the protection of his moral rights under the Copyright Act, 1957. The Plaintiff uses the screen name “Akshay Kumar” right from the beginning of his career spanning more than 35 years and has, over the years, been identified by that

screen name, “Akshay Kumar”. The Plaintiff asserts that personality rights, his right to privacy, and his right to live with dignity, as well as his moral rights are being infringed and violated through unauthorized use, commercial exploitation, and misrepresentation on social media and e-commerce platforms and across the internet by various entities, some of whom are impleaded as Defendants.

2. The Plaintiff has, in the plaint, demonstrated his reputation as a renowned film actor, producer, and public figure with a distinguished career in the Indian film industry spanning over three decades. The Plaintiff has referred to the films (more than 150 in number) in which he has acted in paragraph 23 of the plaint, further detailed in Exhibit A at page 155 of the plaint. The Plaintiff's performances in successful and acclaimed films, including "Hera Pheri", "Airlift" ,"Khiladi", “Rustom”, “Bhool Bhulaiyaa”, and "Khakee", have garnered him wide recognition as one of the foremost stars of his generation.

3. The Plaintiff has provided an illustrative list of the numerous awards and honors he has received in paragraph 30 of the plaint. Notably, he was conferred the Padma Shri in 2009 by the Government of India for his contribution to cinema. Thereafter, he received the National Film Award for Best Actor for his performances in “Rustom” and “Airlift” (2016). He has also been awarded two Filmfare Awards, namely for Best Villain (Ajnabee) in 2002 and Best Comedian (Garam Masala) in 2006. Further, the Plaintiff was also conferred an Honorary Doctorate of Law by the University of Windsor in 2008 and was the recipient of

the Outstanding Achievement in Cinema at The Asian Awards in 2011, amongst numerous other such accolades.

4. Further, the Plaintiff enjoys a substantial presence on social media platforms. As detailed in paragraph 31 of the plaint, the Plaintiff has over 66.6 million followers on Defendant No. 2’s platform Instagram, over 49 million followers on Defendant No. 2’s platform Facebook, and over 46 million followers on Defendant No. 3’s platform X (formerly Twitter). This extensive digital following serves as tangible evidence of the Plaintiff's widespread popularity, substantial public recognition, and the considerable goodwill he commands in the public domain. It also reinforces the distinctiveness and exclusive public association of the Plaintiff’s indicia, including his name, image, and persona, in the minds of the public.

5. Learned Senior Counsel points out that, as set out in paragraph 33 of the plaint, the Plaintiff has endorsement arrangements with reputed brands, which have associated themselves with the Plaintiff owing to his popularity, goodwill, and credibility amongst the public. Dr. Saraf submits that the Plaintiff has, over the years, built a distinct personal brand, such that the public associates his screen name and persona with qualities of trust, credibility, and excellence. The goodwill and recognition generated have created a strong nexus between the Plaintiff’s reputation and the brands, products, and commercial activities with which he is associated.

6. Dr. Saraf submits that the Plaintiff’s personality, including his name, screen name, signature, image, likeness, voice and tone, distinctive performance, appearance, and mannerisms, have become uniquely identifiable with him in the minds of the public. It is contended that the Plaintiff possesses an inherent and enforceable right to control, protect, and commercially exploit his personality, and that any u