Background
Sporta Technologies Pvt. Ltd. is the proprietor of the registered trademark DREAM 11, one of India’s most widely used fantasy sports platforms. The platform, launched in 2012, has over 200 million registered users and holds registered trademarks for DREAM 11 and associated marks.
The defendants were operating a platform and associated online presence under the name AMERICANDREAM 11. The plaintiff approached the Delhi High Court and contended that AMERICANDREAM 11 deceptively resembled its registered mark and used it in connection with similar fantasy sports and gaming services.
Counsel for the plaintiff drew the Court’s attention to substantial evidence that the defendants, despite claiming to operate exclusively in the United States and Canada, were actively targeting Indian users. This included social media posts in Hindi, use of Dream11-sponsored cricket jerseys in promotional material, a user interface similar to the plaintiff’s platform, and marketing that created the impression of an association with or alternative version of the Dream11 platform.
The core allegation was not merely that the name was similar. It was that the defendants were using that name to create a false impression of connection with the plaintiff’s platform, specifically to attract Indian users to an offshore real-money gaming service that operated outside India’s regulatory framework.
Defendants’ Undertaking
Appearing on advance service, counsel for the defendants informed the Court that the defendants were willing to cease use of the impugned mark. The Court recorded the undertaking and directed the defendants to remain bound by it.
The undertaking covered cessation of use of AMERICANDREAM 11, its logo, and any deceptively similar variant of DREAM 11 across the following:
- Use as a trademark or trade name,
- Use as a domain name,
- Any form of use on social media,
- Use as part of email addresses,
- Any other manner amounting to infringement of the plaintiff’s mark in India,
- Offering any mobile application using the name DREAM 11 in India Geo-blocking of www.americandream11.us so that it is not accessible from India.
On 13 November 2025, the Delhi High Court issued interim directions in CS(COMM) 1220/2025 after Sporta Technologies Pvt. Ltd., proprietor of the “DREAM 11” mark, sought urgent relief against the defendants’ use of “AMERICANDREAM 11.” The plaintiff filed the application under Section 151 CPC, seeking exemption from pre‑institution mediation.
Social Media Use and Takedown Direction
Counsel for the plaintiff drew the Court’s attention to use of the DREAM 11 mark on social media pages and profiles on Facebook, X, LinkedIn and Instagram. Counsel for the defendants stated that he had no instructions regarding the takedown of such pages, posts, or profiles.
In view of the undertaking already given by the defendants regarding discontinuation of the impugned mark and geo-blocking of the website, the Court directed that until the next date of hearing the defendants shall:
- take down or block all social media pages and profiles; and
- cease all use of the marks AMERICANDREAM 11, its logo, and any deceptively similar variant of DREAM 11
on any platform, including but not limited to Facebook, X, LinkedIn and Instagram.
Reference to Mediation and Next Date
At the request of counsel for the defendants, and with consent of both sides, the Court referred the parties to the Delhi High Court Mediation and Conciliation Centre (DHCMCC) to explore the possibility of a mutually agreeable settlement in relation to the reliefs claimed in the suit and in the application under Order XXXIX Rules 1 and 2 CPC.
The parties were directed to appear before the DHCMCC on 17 November 2025. The application (I.A. No. 28229/2025) was disposed of, and CS(COMM) 1220/2025 along with I.A. Nos. 28228/2025, 28230/2025, 28231/2025 and 28232/2025 have been listed for further hearing on 18 December 2025.
What this Order Establishes
The order is an interim directions order, not a final determination on the merits. It reflects several principles that are well-established in Indian trademark jurisprudence and that apply directly to cross-border digital brand disputes.
1. Territorial registration extends to digital and offshore use targeting India
A registered Indian trademark is not limited in its protection to physical goods sold in India. Where a foreign platform uses a deceptively similar mark in a manner that targets Indian users through digital channels, that use constitutes infringement within the jurisdiction. The defendants’ claim that they operated only in the US and Canada did not insulate them from Indian trademark law where their digital presence was demonstrably directed at the Indian market.
2. Geo-blocking is a recognised interim remedy in digital trademark disputes
The Court’s acceptance of geo-blocking of the defendants’ website as an appropriate relief, ensuring that the site is inaccessible from India, reflects the evolution of Indian courts’ approach to digital enforcement. A website that is technically hosted abroad but accessible in India and targeted at Indian users can be addressed through geo-blocking as an interim measure.
3. Social media use is within the scope of trademark infringement
The Court directed the defendants to take down or block all social media pages and profiles bearing the infringing mark, consistent with its approach in prior Dream11 matters and broader Indian trademark jurisprudence on online use. Social media presence using an infringing mark, including pages, posts, and profiles, constitutes use in commerce and falls squarely within the plaintiff’s rights.
4. Undertakings given before court have binding force
The defendants’ counsel appeared on advance service and gave undertakings in court. Once recorded, those undertakings have the same force as directions of the Court. Breach of an undertaking given to a court in proceedings of this nature can attract contempt proceedings. The practical effect of the undertaking was to provide the plaintiff with immediate, binding relief without requiring the Court to determine the full merits at this stage.
Conclusion
Sporta Technologies v. Defendants is a clean example of Indian trademark enforcement in a cross-border digital context. The Court drew the relevant line not at the physical border of India but at the point at which a foreign operator’s digital presence targeted Indian users using a mark deceptively similar to a registered Indian trademark.
The interim directions, including the recorded undertaking, the social media takedown order, and the geo-blocking direction, represent the full interim toolkit that Indian courts deploy in digital trademark disputes. The matter proceeds on the merits. What the 13 November 2025 order demonstrates is the speed and comprehensiveness with which that toolkit can be activated when the facts support it.
Governing Law
Trade Marks Act, 1999: Section 29, Section 31, Section 134 | Code of Civil Procedure, 1908: Section 151, Order XXXIX Rules 1 and 2 | Delhi High Court (Original Side) Rules
