Delhi HC on E-Commerce Trademark Infringement: Lifestyle Equities v. Amazon

Delhi High Court on E-Commerce Trademark Infringement

The Delhi High Court’s judgment in Lifestyle Equities CV & Lifestyle Licensing B.V. v. Amazon Technologies, Inc. marks a significant milestone in trademark infringement law in India, especially for cases involving e-commerce platforms and private label brands. This ruling addresses liability for “e-infringement” and reaffirms that brand owners exercising substantial control over their trademarks cannot escape accountability for misuse, even when sales occur through third parties.

Background of the Case

The dispute centers on the Beverly Hills Polo Club (BHPC) trademark, depicting a horse and rider holding a polo stick, in use globally since 1982 and in India since 2007. Lifestyle Equities CV and Lifestyle Licensing B.V. own and license the brand, which is sold in over 60 countries and known in India for its premium positioning.

In India, BHPC products—clothing, accessories, perfumes—are sold through official licensees, authorized retailers, and online marketplaces, enjoying significant brand recognition and a loyal consumer base.

The Infringement Claim

This case involves allegations of trademark infringement in e-commerce against Amazon’s in-house clothing brand Symbol. In 2020, BHPC owners found Symbol using a logo they claimed was deceptively similar to the BHPC trademark.

Symbol products were sold online by Cloudtail India Pvt. Ltd. on Amazon.in, operated by Amazon Seller Services Pvt. Ltd. The plaintiffs alleged consumer confusion, brand dilution, and reputational harm, particularly since Symbol products were priced ₹300–₹400 versus BHPC’s ₹3,000–₹5,000.

Understanding E-Infringement

E-infringement occurs when a brand’s name or logo is copied to sell products online, often via major e-commerce platforms. Unlike physical retail, online sales involve layers of brand owners, third-party sellers, platform operators, and logistics providers, making liability harder to assign.

In this case, both BHPC and Symbol logos featured a horse-and-rider motif on clothing. The Court found them confusingly similar and noted the stark price gap could mislead consumers and damage BHPC’s goodwill. The Court stressed that the digital nature of sales does not absolve platforms from liability for selling infringing products.

Court’s Findings

The Trademark License and Distribution Agreement between Amazon Technologies Inc. and Cloudtail India Pvt. Ltd. revealed that Amazon retained substantial control over the Symbol brand.

Amazon’s detailed brand guidelines covered trademark usage, product quality, branding, and marketing strategy, showing it actively managed Symbol rather than acting as a passive brand owner.

The Court held Amazon liable for the infringing Symbol logo. Cloudtail admitted infringement, ceased sales, and paid ₹4,78,484 in damages. Amazon Seller Services was treated as an intermediary and removed after complying with takedown requests. The Court criticized efforts to appear independent while operating in an integrated structure under Amazon’s oversight.

Precedent for Trademark Accountability

This judgment is a landmark in online trademark enforcement in India. The Court ruled that ownership or control over a brand creates legal responsibility for infringement, even if another party makes the sale.

For e-commerce platforms with private labels, the decision highlights the risk of replicating established trademarks. Corporate structures cannot shield companies from liability when they exercise brand oversight and control.

Conclusion & IP Compliance

The Lifestyle Equities v. Amazon ruling reinforces that in e-commerce, ownership and control bring responsibility. Brand owners and online platforms must:

• Strengthen IP compliance measures

• Monitor brand usage across all channels

• Safeguard brand integrity in competitive online markets

As online retail grows, so does the need for proactive accountability. This case is both a warning to infringers and a reminder for all stakeholders to protect intellectual property rights in the digital space.