Delhi High Court Extends Injunction to Newly Discovered Rogue Websites in Play Games 24X7 Pvt. Ltd. v. WWW10XBETTCOM & Ors.

Summary

In the matter of Play Games 24X7 Private Limited V WWW10XBETTCOM & Ors., the Delhi High Court on 10 July 2025 permitted the addition of new ‘rogue’ websites and domain name registrars as parties, to an ongoing trademark infringement case of the plaintiff’s widely played fantasy sports software “MY11CIRCLE.” The Court extended the ex parte ad interim injunction (7 August 2024) granted to defend My11Cirlce against new Respondents. The Court also granted ad interim reliefs of blocking and regulating the disclosure of subscriber information to the defendants to stop unlawful betting.

Case Timeline

• 07 August 2024 – Court grants ex parte ad interim injunction in favour of the Plaintiff against Defendant Nos. 1–14, with liberty to move for similar relief against any newly discovered infringing entities.
• Post-August 2024 – Plaintiff discovers additional rogue websites and domain names infringing its “MY11CIRCLE” trademark.
• 10 July 2025 –
  • Court allows impleadment of defendants nos. 28–35.
  • Interim injunction extended to cover these parties.
  • Blocking and disclosure directions issued.
• 19 September 2025 – Date fixed before the Joint Registrar for marking exhibits.
• 13 October 2025 – Next date of hearing before the Court.

Issue Raised

Whether newly identified rogue websites and their associated domain name registrars, engaged in infringing and unlawful betting activities using the “MY11CIRCLE” mark, should be impleaded in the ongoing proceedings and subjected to the existing injunction orders.

Arguments

Plaintiff’s Arguments

• The August 2024 injunction order expressly allowed the Plaintiff to seek similar relief against subsequently discovered infringers.
• Newly discovered defendants (28–32) are engaged in:
  • Creating dummy websites using the “MY11CIRCLE” mark to mislead users.
  • Redirecting users to unlawful betting platforms.
  • Replicating the Plaintiff’s trademark in domain names to promote competing and illegal gaming services.
• Defendants nos. 33–35 are the domain name registrars enabling the operation of these infringing websites.
• Urgent action is required to prevent ongoing harm to the Plaintiff’s trademark, goodwill, and business interests.

Defendants’ Arguments

• • At this stage, no appearance or submissions have been recorded as no notice was issued to the Defendants who were already impleaded due to the nature of the case.

Judgment

Hon’ble Justice Saurabh Banerjee allowed the impleadment of Defendants nos. 28–35 and extended the 07 August 2024 interim injunction to them. The Court ordered:

1. Restraint Order – Defendants nos. 28–32 and all associated persons restrained from using “MY11CIRCLE” or any deceptively similar mark/domain/logo in any form.
2. Blocking Orders –
   • Defendants nos. 15–20 and 33–35 to suspend/block the identified domain names.
   • Defendants nos. 24–25 to block infringing websites and any John Doe websites upon notification by the Plaintiff.
3. Disclosure – Defendants nos. 33–35 to furnish Basic Subscriber Information and account details of Defendants nos. 28–32 in sealed cover.
4. Procedural Directions – Summons issued, written statements and replications timelines fixed, inspection protocols set, and costs warning for unjustified denials of documents.

Analysis

This order demonstrates once again how proactive the Delhi High Court is with dealing issues of IP infringement in the online space, particularly in the betting and gaming segments. The Court effectively used the ‘dynamic injunction’ strategy brought forth in earlier cases where they allowed Plaintiffs to bring new infringers under the scope of an existing order without the need to file a new suit.

The Court balanced broader enforcement when they granted the injunction not just to the website content infringers but also the domain registrars who are the facilitators of the websites. The order is also useful in providing enforcers of IP rights a method of tracing anonymous infringers which is a well-known issue in online enforcement. The decision also shows judges increasingly thinking that in IP infringement matters involving rogue websites, delayed periods of giving notice are not practical as infringers may relocate to other jurisdictions.