Dear AnabolicSteroids,
********** (seat: **********, Switzerland), is addressing you as the representative of Novartis AG (seat: **********, Switzerland; hereinafter “Novartis”) regarding the above subject matter.
Novartis is a global healthcare company based in Switzerland that provides solutions to address the evolving needs of patients worldwide. Novartis is one of the largest pharmaceutical companies in the world and its products are sold in about 155 countries and reached nearly 800 million people globally in 2018. About 125 000 people of 145 nationalities work at Novartis around the world.
It has come to the attention of our client in July 2019 that an entity named “Novatis labs” has been branding their own anabolic steroids products under such name, which is confusingly similar to our client’s trademark NOVARTIS®. Our client has noticed that you have “Novatis labs” products displayed on your website (**********, see in the end of the letter the links to “Novatis labs” products).
As you may know, NOVARTIS® is a registered trademark of Novartis and an important asset thereof. Accordingly, Novartis must be extremely vigilant in protecting its intellectual property rights and in preventing the unauthorized use of its trademarks. Novartis holds numerous trademark registrations for NOVARTIS® worldwide, e.g. International Registration No. 663765 (registered in 1996). Therefore, considering, (i) the similarity between “Novatis labs” and the trademark NOVARTIS®, and (ii) the absence of any authorization from Novartis for “Novatis labs” to use their trademark NOVARTIS®, and (iii) the non-existence of any other kind of relationship between “Novatis labs” and Novartis, Novartis considers this to be a violation of its rights.
Our client has reached out to the owner of “Novatis labs”, Roy Butterton, with a cease-and-desist letter and the latter complied with consent to rebrand his products. In consequence, most online presence of “Novatis labs” has been replaced by its new name “Nova Labs” and all references to “Novatis labs” have been removed (e.g. **********).
Considering:
1. The use of the term “Novatis labs” infringes our client’s trademark rights;
2. The owner of “Novatis labs”, Roy Butterton has consented to rebrand his products under the name “Nova labs”
we hereby send you this request to remove all links and contents about “Novatis labs” from your website. Kindly respond to our request within 7 (seven) days.
The foregoing is without prejudice to the rights or remedies of Novartis, all of which are expressly reserved. We look forward to your reply.
Kind regards,
**********
To comply with the above request all references to "Novatis" will be replaced with "Nova".
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