Republic of the Philippines

Municipal Trial Court

Branch 5
Quezon City

Yellow Cab Food Corporation,

Plaintiff,
Civil Case No. 1211121
-versus- for:Trademark Infringement
and Unfair Competition

Christopher De Leon Baula,

Defendant,

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ANSWER

The defendant, through his counsel and unto this most honorable court, respectfully states that;

1. The defendant ADMITS the contents of paragraphs 2 and 4 of the complaint as far as his personal
circumstances are concerned;

2. He also ADMITS the allegations contained in paragraph 5 of the complaint regarding the use of the
service mark "Green Cab Pizza Haus" for his business, but DENIES the allegation that he uses a colorable
imitation of the plaintiff's registered service mark and trademark of "Yellow Cab Pizza Co."

3. That defendant is has no knowledge or information sufficient to form a belief regarding the truthfulness
of the allegations in paragraph 4 of the complaint;

4. He DENIES the allegations of the plaintiff in paragraph 7 of its complain that the defendant desires to
imitate complainant's designs. In fact, he used “Green” for it represents a good luck color as what was
told to them after consulting a feng shui expert taking into account their birthdays and birth years.
Likewise, he claims that the use of the word “Cab” was inspired by his job then as a cab driver.

5. That it came as a big surprise to the Baula spouses when Yellow Cab demanded them to stop using
the name Green Cab Pizza Haus for the supposed reason that the use of the same is allegedly a clear
infringement of their trade name, trademark and it was clearly an act constituting unfair competition.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that
judgment be rendered in favor of the defendant and that the complaint be dismissed with costs against
the complainant.

Other relief and remedies as may be deemed just and equitable under the premises are likewise prayed
for.

Quezon City, April 21, 2017.

ATTY. COLEEN JOYCE QUERO BAUTISTA

Counsel for the Defendant
Roll of Attorney No. 1211121
IBP No. 1211121/ Manila
PTR No. 073012-1211121/ Manila
EA Bldg, Timog Avenue
Quezon City