Every time a consumer types a brand name into a search engine, they are doing something instinctive and commercially significant: they are expressing brand preference. The search query “Hindware sanitaryware” or “MakeMyTrip flights” or “Agarwal Packers and Movers” is not a neutral information request it is a declaration of where the consumer intends to spend money. The commercial value of that moment, captured and auctioned by Google through its keyword advertising programme, is worth billions of dollars globally and forms the financial backbone of the world’s most powerful digital advertising ecosystem. It is also, as Indian courts have now conclusively held, a space where the Trade Marks Act, 1999, operates fully and where brand owners who hold registered trademarks have enforceable rights against both the advertisers who bid on their marks and the platform that runs the auction.
The legal question at the heart of keyword advertising trademark disputes is deceptively simple to state and genuinely difficult to resolve: when a competitor purchases a registered trademark as an invisible backend keyword so that their advertisements appear when consumers search for that trademark, does that constitute “use” of the trademark under the Trade Marks Act, 1999? For over a decade, Indian courts gave inconsistent answers to this question, leaving brand owners uncertain and advertising platforms operating in a legal grey zone. The trilogy of decisions Consim Info Pvt. Ltd. v. Google India Pvt. Ltd., 2013 (54) PTC 578 (Mad) in 2013, Google LLC v. DRS Logistics (P) Ltd., 2023 SCC OnLine Del 4809, decided 10 August 2023, and Hindware Ltd. v. Grohe India Pvt. Ltd., CS(COMM) 591/2017 & 592/2017, decided 22 May 2026 (MANU/DE/4120/2026) has now answered that question with considerable clarity, though not without internal tensions that practitioners must understand. Layered on top of these decisions is the complementary and partially conflicting ruling in Google LLC v. MakeMyTrip (India) Private Limited & Ors., 2023 SCC OnLine Del 7965, decided 14 December 2023 (2023:DHC:8960-DB), which introduced an important qualification: keyword use does not automatically constitute infringement if no confusion arises in the mind of the internet user.
This article examines the full arc of Indian keyword advertising trademark law: the statutory provisions under which liability arises, the international comparative context, the line of Indian cases and the specific legal questions each resolved, the intermediary liability framework under Section 79 of the Information Technology Act, 2000, and the practical implications for brand owners, advertisers and digital marketing professionals operating in India today. The language is kept deliberately accessible this area of law sits at the intersection of IP and digital commerce, and the practitioners who need to understand it span the full spectrum from senior trademark lawyers to in-house counsel advising marketing teams.
The Statutory Framework Section 29 of the Trade Marks Act, 1999
The starting point for any keyword advertising analysis in India is Section 29 of the Trade Marks Act, 1999, which defines infringement of a registered trademark. The provision is architecturally complex it runs through eight sub-sections, each addressing a different mode of infringing use and the keyword advertising debate turns specifically on which sub-section applies to the invisible backend use of a trademark as a search trigger.
Section 29(1) covers the classic infringement scenario: a person uses a mark identical or deceptively similar to a registered mark in relation to the same goods or services for which the mark is registered. Section 29(2) extends infringement to use in relation to identical or similar goods where there is a likelihood of confusion. Section 29(4) addresses the case of a mark identical or similar to a well-known registered mark used in relation to dissimilar goods, where such use takes unfair advantage of or is detrimental to the distinctive character or repute of the registered mark. Section 29(6) is the provision that has attracted the most attention in keyword advertising cases: it provides that a person uses a registered trade mark “in advertising” when they use the mark on business papers, in advertising, or in any other manner, without the consent of the proprietor. Section 29(6)(d) specifically covers use “in advertising goods or services.” Section 29(8) adds a further dimension: the use of a registered trademark in comparative advertising in a manner that takes unfair advantage of its repute or is contrary to honest practices constitutes infringement.
The central legal debate in keyword advertising cases is whether an invisible keyword a backend trigger that the consumer never sees can constitute “use” of the trademark “in advertising” within the meaning of Section 29(6). Google’s consistent argument across all Indian proceedings has been that keywords are purely technical bidding parameters, not marks used “in” any advertisement. A trademark must be visible, Google argued, to constitute use in advertising. Indian courts have now, with near unanimity, rejected this argument.
The Mechanics of Keyword Advertising and Why They Matter to Trademark Law
Before analysing the case law, it is useful to understand precisely how Google’s advertising programme works, because the mechanics directly determine where trademark use occurs.
When an advertiser say, a competitor of a well-known brand sets up a campaign on Google Ads, they select keywords that will trigger the display of their advertisement. These keywords are entered into Google’s backend system and are never displayed to the end consumer. The advertiser bids an amount they are willing to pay per click. Google’s algorithm then decides, based on the bid amount, the quality score of the advertiser’s landing page, and the relevance of the ad content, whether to display the advertiser’s sponsored link when a user enters that keyword as a search query. Crucially, Google also operates a “Keyword Planner” tool through which it actively suggests additional keywords to advertisers and that tool, as all the Indian cases have found, routinely suggests competitor trademarks as effective keywords.
The consumer experience is this: a person searches “Hindware sanitaryware” on Google. The search results page shows, at the top, sponsored advertisements labelled “Ad” for Cera Sanitaryware or Grohe, followed lower down by organic results including Hindware’s own website. The consumer searching for Hindware sees a competitor’s advertisement first. The trademark “HINDWARE” is not visible in the competitor’s advertisement it appeared only in the search query. But it was the use of “HINDWARE” as a backend keyword that caused the competitor’s advertisement to appear. That diversion of consumer intent and the commercial value it captures is the harm that trademark law is asked to address.
The Madras High Court’s Early Engagement Consim Info
The first serious Indian judicial engagement with keyword advertising and trademark infringement came from the Madras High Court in Consim Info Pvt. Ltd. v. Google India Pvt. Ltd. & Ors., 2013 (54) PTC 578 (Mad). Consim Info operated the well-known matrimonial service Bharatmatrimony.com and held registered trademarks for “Bharatmatrimony,” “Tamilmatrimony,” “Telugumatrimony,” and related marks. The company sued Google in 2009 after discovering that competitors such as Shaadi.com and SimplyMarry.com were purchasing Consim’s registered trademarks as AdWords keywords, causing their advertisements to appear prominently when users searched for Bharatmatrimony.
The Madras High Court’s engagement with the case was cautious and ultimately inconclusive on the core infringement question. The single judge initially granted an interim injunction but vacated it in October 2010, directing Google India to adhere to its existing policy of protecting registered trademarks from competitor use. The Division Bench, deciding the appeal in 2013, upheld this approach without categorically resolving whether keyword use constituted infringement under the Trade Marks Act. The court directed Google to maintain its policy of not allowing Consim’s registered trademarks to appear in the actual text of competitor advertisements but stopped short of declaring the invisible backend keyword use itself to be infringement.
The Consim case established an important foundational point: the Madras High Court recognised that the use of a competitor’s trademark as a keyword raises genuine trademark concerns and warrants judicial attention. But its resolution directing adherence to Google’s own voluntary policy rather than declaring legal liability left the deeper statutory question open. For nearly a decade, that uncertainty persisted.
The Delhi High Court’s Division Bench in DRS Logistics The Active Participant Standard
The watershed moment in Indian keyword advertising trademark law came with the Division Bench of the Delhi High Court’s ruling in Google LLC v. DRS Logistics (P) Ltd. & Ors. and Google India Private Limited v. DRS Logistics (P) Ltd. & Ors., 2023 SCC OnLine Del 4809, decided 10 August 2023 (also cited as 2023:DHC:5615-DB). This decision, authored by Justice Vibhu Bakhru and Justice Amit Mahajan, is the most analytically comprehensive treatment of the keyword advertising trademark question by any Indian court and established the framework within which all subsequent decisions have operated.
DRS Logistics (P) Ltd. owned the well-known trademark “AGARWAL PACKERS AND MOVERS” for its logistics and moving services. The company found that competitors were purchasing its trademark as a keyword on Google Ads, causing sponsored links for rival packers-and-movers companies to appear at the top of search results when consumers searched for Agarwal Packers and Movers. The single judge had granted an interim injunction, holding that the invisible use of DRS’s trademark as a keyword constituted infringement. Google appealed.
The Division Bench addressed three distinct but interrelated questions: first, whether keyword use constitutes “use” of a trademark under Section 29 of the Trade Marks Act; second, whether such use constitutes infringement; and third, whether Google was entitled to the safe harbour protection available to intermediaries under Section 79 of the Information Technology Act, 2000. The court’s answers to each question require careful analysis.
On the first question – whether keyword use is “use” of a trademark the Division Bench held squarely that Google’s use of trademarks as keywords in its Ads Programme amounts to “use” of the trademark “in advertising” within the meaning of Section 29(6) of the Trade Marks Act, 1999. The court rejected Google’s argument that an invisible backend keyword is not “use” in any legally cognisable sense. The Keyword Planner tool actively suggests competitor trademarks to advertisers; Google earns revenue from every click triggered by those trademarks; and Google structures its entire auction system around the commercial value of brand-specific search queries. This, the court held, was active commercial participation in the use of the trademark not merely the passive provision of a neutral platform.
On the second question – infringement the Division Bench introduced an important qualification that has shaped all subsequent analysis. The court held that keyword use constitutes infringement only when it causes confusion or likelihood of confusion in the mind of the average internet user, or when it takes unfair advantage of or is detrimental to the distinctive character or repute of the trademark. The court specifically rejected the doctrine of “initial interest confusion” as it has been applied in some US courts the idea that even momentary confusion before a consumer realises they are looking at a competitor’s advertisement constitutes actionable confusion. The Delhi High Court held that the relevant test is whether a reasonably informed internet user someone who understands how search engines work, who knows the difference between organic and sponsored results would be confused by the appearance of a competitor’s advertisement alongside the searched trademark. This consumer is more sophisticated than the traditional benchmark of the consumer with imperfect recollection, because the digital search environment provides immediate visual cues about what is a sponsored advertisement and what is an organic result.
On the third question – intermediary liability the Division Bench held that Google was not entitled to the safe harbour protection under Section 79 of the Information Technology Act, 2000. Section 79 protects intermediaries from liability for third-party content where the intermediary merely provides access or storage facilities and acts without knowledge or involvement in the infringing content. The court found that Google’s active role in suggesting trademarked keywords through Keyword Planner, running the auction, setting the commercial terms, and earning direct revenue from each click placed it firmly outside the “passive conduit” category that Section 79 is designed to protect. An intermediary that actively designs, operates, and profits from the mechanism of infringement cannot claim the protection that Parliament intended for neutral information carriers.
The MakeMyTrip Correction – No Confusion, No Infringement
The same Division Bench applied the DRS Logistics framework in Google LLC v. MakeMyTrip (India) Private Limited & Ors., 2023 SCC OnLine Del 7965, decided 14 December 2023 (2023:DHC:8960-DB), and in doing so sharply qualified the practical significance of the DRS finding for everyday keyword advertising practice.
MakeMyTrip had sued Google and its competitor Booking.com for trademark infringement, arguing that Booking.com’s use of “MakeMyTrip” as a keyword on Google Ads causing Booking.com’s advertisements to appear when consumers searched for MakeMyTrip constituted infringement. The single judge had granted an interim injunction. The Division Bench set it aside.
The court found, on the evidence, that when a user searches “MakeMyTrip” on Google, MakeMyTrip’s own organic result appears first, prominently. The Booking.com sponsored advertisement appears alongside but is clearly labelled “Ad.” Seven out of ten times in the evidence before the court, MakeMyTrip’s own link was the first organic result a consumer would see, with Booking.com’s advertisement either alongside or below it. Given this, the court found that a reasonably informed internet user one who understands how search results work would not be confused into thinking that the Booking.com advertisement was connected with, endorsed by, or emanated from MakeMyTrip. The consumer searching for MakeMyTrip would find MakeMyTrip; the presence of Booking.com’s advertisement nearby did not divert or confuse.
The Division Bench also rejected MakeMyTrip’s argument that the use of its trademark as a keyword constituted infringement under Section 29(4) the dilution provision applicable to well-known marks used in relation to dissimilar goods because the conditions for Section 29(4) include a threshold that the defendant’s use takes “unfair advantage” of or is “detrimental to” the distinctive character or repute of the mark. The court found these conditions were not satisfied at the interim stage on the facts before it. The Supreme Court subsequently declined to interfere with the Division Bench’s ruling, a bench of Chief Justice DY Chandrachud, Justice JB Pardiwala, and Justice Manoj Misra finding no case for trademark infringement on those facts.
The practical significance of MakeMyTrip is substantial. It makes clear that the DRS Logistics holding that keyword use is “use” in advertising does not automatically translate into infringement liability. The trademark owner must establish actual confusion or unfair advantage on the facts. Where the trademark owner’s organic search result continues to appear prominently alongside the sponsored advertisement, and the labelling of the sponsored result as an “Ad” is clear, and the goods and services of the advertiser are distinguishable from those of the trademark owner, infringement will not be made out merely because a competitor bid on the trademark as a keyword. This was characterised by some commentators as a partial victory for Google, and with reason it preserved the viability of substantial portions of the keyword advertising business even as it conceded that keywords are “use” for statutory purposes.
Hindware v. Google – The Definitive Statement on Platform Liability
The most recent and most significant ruling in this series is the Delhi High Court’s judgment in Hindware Ltd. v. Grohe India Pvt. Ltd., CS(COMM) 591/2017 & 592/2017, decided 22 May 2026 (MANU/DE/4120/2026, also cited as 2026:DHC:4614), authored by Justice Mini Pushkarna. This is the first case in Indian IP law in which a court, after a full trial on evidence, permanently restrained Google from using a registered trademark as a keyword and awarded damages against Google for trademark infringement making it qualitatively different from the interim-stage analyses in DRS and MakeMyTrip.
The facts have been summarised earlier but bear recitation in the specific context of legal significance. Hindware a leading sanitaryware brand using its trademark since 1991, recognised as a well-known trademark by the Delhi High Court in HSIL Limited v. Kripton Ceramics Pvt. Ltd. & Ors. in April 2017 discovered in 2013 that competitors Cera Sanitaryware and Grohe India had purchased “HINDWARE” and its variants as keywords on Google AdWords. Consumer searches for “HINDWARE,” “HINDWARE SANITARYWARE,” “HINDWARE SANITARY,” and “HINDWARE SANITARYWARE INDIA” returned competitor advertisements at the top of results, above Hindware’s own listing. Cera and Grohe settled with Hindware during proceedings. The dispute against Google as the platform that designed, operated, marketed, and profited from the keyword auction proceeded to trial.
Justice Pushkarna held, after examining the full trial record including cross-examination of Google’s witnesses, that using a registered trademark as a keyword to trigger the display of an advertisement constitutes use “in advertising” under Section 29(6)(d) of the Trade Marks Act, 1999, regardless of whether the trademark itself is physically visible in the advertisement. The judgment stated: “it is not necessary that the registered trademark physically appears in an advertisement for the same to be used ‘in advertising.'” This was the clearest and most unequivocal judicial statement yet on the invisible use question that had divided courts and commentators since the Consim litigation in 2009.
On Google’s liability as a platform, the judgment went further than DRS Logistics in several respects. First, the court rejected Google’s characterisation of itself as a neutral intermediary providing a tool that advertisers chose to use. The evidence at trial showed that Google’s Keyword Planner actively suggested “HINDWARE” and its variants to competing advertisers, that Google’s auction system was specifically designed to monetise the commercial pulling power of brand-specific searches, and that Google’s agreements with advertisers Grohe and Cera specifically enabled and facilitated the use of Hindware’s trademark in the ad system. Second, the court held that where a platform actively designs a product that monetises another’s registered trademark without that trademark owner’s consent, the platform cannot claim it was merely “making available a tool.” Google “cannot be permitted to shrug off responsibility by making available a tool that leads to infringement, and then turning around to claim that the said tool was not mandatory,” Justice Pushkarna observed. Third, on the intermediary liability question, the court held that Google’s active role in keyword suggestions, auction design, advertiser agreements, and revenue extraction placed it squarely outside the safe harbour of Section 79 of the IT Act consistent with DRS Logistics.
The court granted a permanent injunction restraining Google LLC and Google India from using “HINDWARE,” “HINDWARE SANITARYWARE,” “HINDWARE SANITARY,” “HINDWARE SANITARYWARE INDIA,” or any combination thereof as advertising keywords. Google was ordered to pay ₹30 lakh as nominal damages to Hindware, a figure that reflects the court’s recognition that the primary measure of Hindware’s loss years of consumer diversion through the AdWords programme was difficult to quantify precisely and that punitive or exemplary damages were not sought on the pleadings as framed.
Reconciling DRS, MakeMyTrip, and Hindware – The Current Legal Position
Reading these three decisions together, the current legal position on keyword advertising trademark liability in India can be stated as follows.
The use of a registered trademark as a keyword in Google’s advertising programme constitutes “use” of the trademark “in advertising” within the meaning of Section 29(6) of the Trade Marks Act, 1999. This is not conditional on the trademark being visible in the final advertisement the invisible backend trigger is sufficient to satisfy the statutory concept of use. Google, as the operator of the keyword auction, is itself a “user” of the trademark for these purposes, given its active role in suggesting trademarked keywords, operating the auction, and earning revenue from each click.
However, use does not automatically constitute infringement. Infringement requires, in addition to use, that the use causes confusion, likelihood of confusion, unfair advantage, or detriment to the distinctive character or repute of the registered mark. The relevant consumer is an informed internet user who understands the difference between sponsored and organic results. Where the trademark owner’s own listing continues to appear prominently alongside the competitor’s sponsored advertisement, and the advertisement is clearly labelled as sponsored, and no other circumstances suggesting confusion or deception are present, infringement will not be established merely by the act of keyword purchase.
The factors that distinguish a finding of infringement from a finding of mere use without infringement include: the strength and distinctiveness of the registered mark (a coined, fanciful mark like “HINDWARE” commands stronger protection than a descriptive term); the degree to which the trademark owner’s own listing is displaced by competitor advertisements in the search results (if the trademark owner’s result is pushed off the first page, confusion and diversion are more readily established); the visual clarity of the “Ad” label distinguishing sponsored results from organic ones; and whether the goods or services of the advertiser overlap with those of the trademark owner to a degree that amplifies consumer confusion.
Google’s safe harbour defence under Section 79 of the IT Act, 2000, is unavailable where Google plays an active role in suggesting the infringing keywords, designing the auction system, and earning revenue from the trademark use. A platform that is a passive conduit for third-party advertisements retains Section 79 protection; a platform that actively participates in the commercial exploitation of another’s trademark does not.
The Comparative Context – CJEU’s Google France Doctrine and US Fair Use
The European Court of Justice addressed the keyword advertising question in Google France SARL v. Louis Vuitton Malletier SA, Case C-236/08, decided 23 March 2010. The CJEU held that Google’s operation of the AdWords programme did not itself constitute “use” of the advertiser’s trademarks it was the advertiser who was using the mark, not Google. However, the CJEU also held that the advertiser’s use could constitute infringement if it adversely affected one of the functions of the trademark its function as a guarantee of origin, or its advertising or investment function. The CJEU’s approach differs from the Indian position in one important respect: the CJEU exempted Google itself from direct use liability, while the Delhi High Court has held Google to be a user an “active participant” in the keyword use. The Indian courts’ approach is therefore more protective of trademark owners and more demanding of advertising platforms.
In the United States, keyword advertising disputes have been addressed primarily through the doctrine of initial interest confusion and, where applicable, the nominative fair use doctrine. The latter permits a competitor to use another’s trademark to refer to that competitor’s own goods or services “compare our product to Brand X” provided the use is honest and does not mislead consumers about the source of the advertiser’s goods. Neither of these doctrines has been formally adopted in Indian trademark law, and the Delhi High Court in DRS Logistics specifically declined to apply initial interest confusion as a standalone basis for infringement, preferring instead a more contextual assessment of whether an informed internet user would actually be confused.
The Advertiser’s Position – Direct Liability for Keyword Bidding
While the focus of much Indian litigation has been on Google’s platform liability, the position of the competitor-advertiser who actually bids on a trademark keyword is equally important and considerably more straightforward. The advertiser who purchases a registered trademark as a keyword, causing their advertisement to appear alongside or above the trademark owner’s organic result, is the primary infringer. The advertiser uses the trademark “in advertising” within the meaning of Section 29(6) by deploying it as the trigger for their sponsored link. The advertiser also benefits commercially from the diversion of consumer intent that the keyword creates. There is no Section 79 IT Act defence available to the advertiser that provision is specific to intermediaries, not to users of the platform.
The Hindware case illustrates this clearly: Cera and Grohe, as the advertisers who purchased the “HINDWARE” keyword, settled with Hindware rather than contest liability. Their settlement is a clear recognition that direct advertiser liability for trademark keyword bidding is effectively unchallengeable on the current state of Indian law. Any brand owner in India who discovers a competitor bidding on their registered trademark as a keyword has a straightforward cause of action against that competitor under Section 29(6) of the Trade Marks Act, 1999, and can seek a permanent injunction, damages, and account of profits under Section 135 of the same Act.
Practical Implications for Brand Owners, Advertisers, and Platforms
The body of case law examined in this article generates several concrete practical implications.
For brand owners, the current legal position provides a powerful enforcement tool against competitor keyword bidding on registered marks, particularly where the mark is coined, fanciful, or well-known, where the competitor’s advertisement displaces the brand owner’s own organic listing, and where the goods and services are identical or closely related. The Hindware decision provides a template for seeking a permanent injunction against both the advertiser and Google as the platform operator. A brand owner should monitor search results for its registered marks actively, document instances of competitor keyword bidding, preserve evidence of consumer diversion through search analytics, and move the court for both interim and permanent relief. Given the Hindware ruling that invisible keyword use constitutes use in advertising without requiring visible appearance of the mark, the evidentiary threshold for establishing the factual basis of the claim is achievable through standard search result screenshots.
For advertisers using competitor keywords in Google Ads in India, the Hindware ruling and the DRS framework together mean that bidding on a competitor’s registered trademark as a keyword carries real legal risk, particularly where the competitor’s mark is a coined or well-known mark, where the advertiser’s goods or services are identical or closely similar, and where the advertising is structured in a way that displaces or confuses consumers looking specifically for the competitor’s products. The MakeMyTrip decision provides some comfort for advertisers in markets where the trademark owner’s own listing continues to appear prominently and the “Ad” label is clear but this comfort is fact-specific and not a blanket licence to bid on competitor trademarks. Legal counsel advising advertisers in India should conduct a trademark clearance analysis before approving keyword bidding strategies that include competitor brand terms.
For Google and other advertising platforms operating in India, the combined effect of DRS Logistics and Hindware is that the “passive intermediary” defence is not available for keyword advertising operations where the platform actively suggests trademarked terms to advertisers through tools like Keyword Planner, operates the auction system as a commercial product, and earns revenue directly attributable to consumer responses triggered by trademark-specific searches. The Section 79 IT Act safe harbour requires genuine passivity a platform that designs, promotes, and profits from a product that monetises third-party trademarks without those trademark owners’ consent cannot credibly claim to be a neutral conduit. The practical response for platforms operating in India may involve implementing trademark-specific consent protocols analogous to the systems used in the European Union following the CJEU’s Google France ruling before allowing third parties to bid on registered Indian trademarks as keywords.
Conclusion
The journey of keyword advertising trademark law in India from the Madras High Court’s inconclusive engagement in Consim Info in 2013 to the Delhi High Court’s landmark final ruling in Hindware in May 2026 represents one of the most practically significant developments in Indian trademark jurisprudence of the past decade. The law is now settled on the foundational question: the use of a registered trademark as an invisible backend keyword in a digital advertising platform constitutes “use” of that trademark “in advertising” under Section 29(6) of the Trade Marks Act, 1999, and a platform that actively designs and profits from this use cannot shelter behind the intermediary safe harbour in Section 79 of the IT Act.
The qualification introduced by MakeMyTrip that use without confusion is not infringement is important and prevents a reading of the law that would make all keyword advertising per se unlawful. Indian courts are not hostile to digital advertising; they are insisting that it operate within the boundaries that trademark law sets for all uses of another’s brand. The Hindware ruling’s award of a permanent injunction against Google, reached after full trial, gives this body of law a finality and authority that interim-stage decisions could not provide.
The trajectory of this area of law points toward increasing enforcement by Indian brand owners and toward greater compliance obligations for advertising platforms. The introduction of clearer platform policies on trademarked keywords in India driven by the litigation risk that the current case law creates is a natural commercial response. For the IP practitioner, the keyword advertising domain is no longer an area of theoretical interest: it is an active enforcement frontier where the legal tools are clear, the cases are decided, and the remedies are available.
References
- Trade Marks Act, 1999 – Section 29 – https://ipindia.gov.in/writereaddata/Portal/IPOAct/1_30_1_TM-Act-1999.pdf
- Information Technology Act, 2000 – Section 79 (Intermediary Liability) – https://legislative.gov.in/sites/default/files/A2000-21.pdf
- Hindware Ltd. v. Grohe India Pvt. Ltd., CS(COMM) 591/2017 & 592/2017, Delhi High Court, 22 May 2026 – https://delhihighcourt.nic.in/app/showFileJudgment/59222052026SC5912017_203444.pdf
- Google LLC v. DRS Logistics (P) Ltd., 2023 SCC OnLine Del 4809, Delhi High Court Division Bench, 10 August 2023 – https://indiankanoon.org/doc/100370340/
- Google LLC v. MakeMyTrip (India) Private Limited, 2023 SCC OnLine Del 7965, Delhi High Court Division Bench, 14 December 2023 –https://indiankanoon.org/doc/142523116/
- Consim Info Pvt. Ltd. v. Google India Pvt. Ltd., 2013 (54) PTC 578 (Mad) – https://indiankanoon.org/doc/155459494/
- CJEU – Google France SARL v. Louis Vuitton Malletier SA, Case C-236/08 – https://curia.europa.eu/juris/liste.jsf?num=C-236/08
- WIPO – Overview of Keyword Advertising and Trademark Law –https://www.wipo.int/wipo_magazine/en/2010/05/article_0003.html
- IT Act 2000 – Intermediary Guidelines and Digital Media Ethics Code, 2021 – https://legislative.gov.in/sites/default/files/GSR139E.pdf
- Delhi High Court – IP Division judgments portal – https://delhihighcourt.nic.in
- CGPDTM – Trade Marks Registry official resources – https://ipindia.gov.in
- National IPR Policy, 2016 – DPIIT – https://dpiit.gov.in/sites/default/files/National_IPR_Policy_English.pdf
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