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Under instruction and on behalf of our client, Mr.Christo.

P, residing at No 1, RVL Nagar, Varadaraja Puram Coimbatore 641015, we issue the following reply to your notice dated 15.2.2012.

1. At the out set our client denies all the allegations made in the notice as false, baseless and concocted by abuse of your clients dominant position, except those specifically admitted herein. 2. Our client denies the allegation that he has approached you client for availing any services, not only Broadband Internet / land connection . Our client states that it is your client has approached our client even after his refusal to entertain your executives trained to cheat innocent public taking advantage of their busy schedule. Our client further states that it is your client who has the habit of disturbing innocents at their busy schedules and force them to affix their signature without their knowledge by misrepresentation through trained frauds in the guise of marketing/ sales executives with an undertaking that the copy of those papers would be supplied to our client at the time of welcome kit, but never furnish the same. Our client states that he never furnished any details to your client as alleged in your notice, but, on the contrary, your client was able to collect them through your clients technical capability from various sources as your client is in the habit of transpiring the data of millions of innocents including our clients phone number, date of birth, PAN and other personal data unauthorisedly, illegally and without our clients permission or knowledge.

3. Our client states that he never signed anything in the form of an agreement, if any such agreement is there it should be a forged one and our client reserves his right to initiate appropriate legal action both civil and criminal. Even assuming without admitting that there exists any such agreement as alleged by your client, why any copy of the same was not furnished to him. Our client states that your client has shown him the television clips and advertisements claiming your client has state of art technology and customer friendly, but on the contrary, the facilities provided by your client are not upto the mark and lead our client to land in problem. Our client states that still, he used to make payments as demanded by your client. Our client state that at one pint of time the broad band and land line were not properly working for example,

intermittent disconnection in line , internet, dead slow speed lead him to make a complaint with your customer care. Our client states that when there was no response even after three days our client was practically paralysed and as a result refused to pay until the bill is reduced in proportion to the inferior quality of services rendered by your client as against his promise of market leaders. Our clients states that when facts are so your client is attempting to brand him as defaulter and such act of your client squarely amount to abuse of dominant position. 4. Our client states that your client instead of satisfying the customer by resolving the problem, adopted coercive methods to extract money for the services not availed by our client. Our client further states that such an act of your client amount not only to deficiency of service but also amount to abuse of dominant position both attracts legal sanctions. Our client states that your clients allegation that he has taken earnest efforts through phone call would expose that none can call over an unworking telephone or internet. Our client denies the allegation that our client has been wantonly and wilfully evading payments and staying away from your clients contact in order to achieve wrongful gain and our client states that it is your client by abusing their dominant position through trained thugs wantonly and wilfully achieved wrongful gain for and caused wrongful loss to him besides putting him in themselves

mental agony . Our client states that such act of your client is highly arbitrary, unlawful and against all canons of law. In these facts and circumstances, we have received peremptory instruction to initiate appropriate legal action civil, criminal , consumer and competition laws. However, we here by give your client an opportunity to withdraw the legal notice and seek unconditional apology for causing such illegal demands and also give an undertaking that your client will not disturb in any manner hence forth within a week from the date of this notice failing which we have no option but to initiate appropriate legal action both civil and criminal at your cost and consequence thereof

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