Request all to register your objection with the trademark Registrar as follows. Annexures attached.
@PiyushGoyal@PiyushGoyalOffc@CimGOI
To
The Registrar of Trade Marks (Head Office)
Trade Marks Registry,
Boudhik Sampada Bhawan, S.M. Road, Antop Hill, Mumbai – 400037
CC: Regional Office, Chennai
The Registrar of Trade Marks(Regional Office)
Intellectual Property Office Building, G.S.T Road, Guindy, Chennai - 600032
Date: January 15, 2026
Subject: Formal Representation under Sections 9 & 11 of the Trade Marks Act, 1999, Against Trademark Application Nos. 7355707, 7427983, and 7427962 (Mark: ERZL)
Respected Sir/Madam,
I, Dr. Sivaranjani Santosh, a Senior Paediatrician and public health advocate, submit this formal representation to urge the Registry to Refuse the registration of the mark "ERZL" and its stylized variants.
1. Context of Public Health Risk:
The drug "ORS" (Oral Rehydration Salts) is a life-saving medicine. Misbranding high-sugar beverages as "ORS" has led to severe clinical complications and can lead to child mortality. On 14th October 2025, the FSSAI decisively prohibited the use of "ORS" in any food/beverage name, citing consumer deception. This was further upheld by the Delhi High Court in orders dated 30th Oct and 12th Nov 2025.
2. Absolute Grounds for Refusal (Section 9(2)(a)):
The proposed mark "ERZL" is inherently deceptive. As shown in the attached Annexure, the "E" is stylized to visually mimic an "O," and "Z" acts as a mirror/phonetic substitute for "S." This is a mala fide design choice intended to mislead parents into associating the product with the life-saving drug "ORS."
3. Relative Grounds for Refusal (Section 11(1) & 11(3)):
The mark "ERZL" is deceptively similar to the brand identity of "ORSL," which is currently under regulatory and judicial restriction.
• Likelihood of Confusion: The applicant is using the same color scheme, font, and "trade dress" as the banned "ORSL" mark to retain brand memory.
• Bad Faith Adoption: Attempting to register a "mirror-image" mark to bypass a health-safety ban constitutes bad faith. This use is liable to be prevented by the Law of Passing Off.
4. Regulatory Prohibition & Judicial Affirmation:
a) The Food Safety and Standards Authority of India (FSSAI), vide its Order dated 14th October 2025 and subsequent clarification dated 15th October 2025, has decisively prohibited the use of the term "ORS" (standalone or as a prefix/suffix) in the branding of food products.
Critically, the Hon’ble Delhi High Court (in orders dated 30th Oct and 12th Nov 2025) refused to interfere with this ban or grant any relief to the manufacturers, specifically noting that such deceptive branding has a "deleterious effect and adverse health outcomes" for consumers. The court emphasized that the health of the public outweighs any commercial interest in the "ORSL" brand identity.
b) Matter is Sub-judice: Furthermore, the broader issue of misbranded sugary drinks is currently sub-judice before the Hon’ble Telangana High Court (PIL No. [Insert No.]). Granting the mark "ERZL"—which is a visual and phonetic imitation of the prohibited "ORSL"—would undermine the ongoing judicial proceedings and facilitate a "back-door" entry for a brand identity already deemed deceptive by the Delhi High Court and FSSAI.
Request: I request the Registry to issue an Examination Report with Objections under Sections 9 and 11 or use any provision they deem fit to ultimately refuse these applications to protect the public from deceptive medical branding.
Annexures-1. Comparison of Deceptive Similarity
2. The pictures of ORSL and ERZL
3. The trademarks with the Trademark numbers
Dr Sivaranjani Santosh
#orsl #erzl #kenvue #misbranding #misleading #jnj #johnsonjohnson
Who is to blame? The authorities for giving permission and allowing OTC sale, or the pharmacist handing them out without the prescription, or the parent? Victim is the baby, finally!
If you ask me, if a medicine is not to be given to some one below 4 years of age, permission should not be given in the first place for these drops. If it is a schedule H drug, OTC sale should not be allowed.
@MoHFW_INDIA
#maxtradrops #sinarestAFdrops #solvincolddrops #zyrtecdrops #sinarestdrops
There is nothing like 'cough syrup'. Cough can be because of a lot of congestion,bronchospasm, bronchiolitis, acid reflux, allergy or infection. It can be a habit cough, or due to inflammation of the throat or stress related. Address the underlying cause.
Syrups available in India in the name of cough syrups contain either decongestants like phenylephrine (whose side effects are mostly due to overdosing or wrong dosing - increase in heart rate, increase in blood pressure, and arrhythmias), or anti allergy medications like chlorpheniramine and cetirizine (overdosing can cause sedation and respiratory depression- less with Levocetirizine, though), mucus breaking drugs like ambroxol and guaifenesin, bronchodilators like levosalbutamol and Terbutaline(overdosing can cause tremors, increased heart rate and arrhythmias) and cough suppressants like dextromethorphan and codeine(which can cause severe respiratory depression when overdosed). We should not suppress the cough, as it might even help in expelling the germs out.
For every medicine there is a minimum age before which we can't give the medicine to the child, especially without the paediatricians's advice. For phenylephrine in India, it is now four years, though most guidelines say it is 2 years. For cetirizine, it is 6 months. In India the combination of Phenylephrine and Chlorpheniramine should not be used below 4 years of age.
If a medicine is prescribed by a doctor, If the right dose is given by a mother for a right indication, problems usually don’t happen. The problem of overdosing happens when the parents go and buy over-the-counter medications, and give them randomly without knowing the doses. So, don’t buy the so called cough syrups on your own and decide to give them to the children. If they have a cough, paediatricians are there to address the underlying cause for cough and prescribe the treatment depending on the age group, symptoms, and the etiology. Stick to the doses, read expiry date. Doctors should write the prescriptions clearly, mention composition and tell the parents not to repeat the prescription, explain to them about dangers of wrong dosing, overdosing and repetition of prescription.
First aid for cough mainly is compression with a warm cloth. In India many of them give steam directly. That is dangerous. If steam should be given, then the bathroom should be filled with the steam and the kid should be made to sit there.Don't give vicks,eucalyptus oil, Zindatilismath etc. In younger children they can cause seizures, and can worsen the cough and asthma symptoms.
If the nose is blocked, put one to two drops of saline nose drops (from the pharmacies) in each nostril. If the cough is severe, the kid is vomiting or coughing continuously, consult the doctor.
Drug regulators should avoid giving permission for drops and syrup with the same brand name, for unscientific combinations of medicines, for formulations with different components but the same brand name with a suffix or prefix. We need to have only a few standard brands or generic medicines with strong quality control. Form a panel of paediatricians for the same.
Also, Terbutaline and Levosalbutamol shouldn't be part of the combinations. We have specific indications for these medicines. Safer route of administration for Levosalbutamol is using a nebulizer or MDI with or with out spacer, only if advised by the paediatrician when the child has bronchospasm.
INFACT, AVOID COMBINATIONS!
Dr Sivaranjani Santosh
A chaotic scenario in international politics, driven by competing powers struggling for dominance and control.Donald Trump thanked Maria Corina Machado after the Venezuelan opposition leader “presented” president Trump with her Nobel Peace Prize.
Noble peace prize Medal in Hand!
You know about Rabies Vaccine. Right?
If you had taken Rabies vaccine by name Abhayrab, especially batch number KA24014 between Nov 2023 till date, please consult your doctor. You may have to repeat it, because a fake version of the vaccine was being given to some till the company realized the problem and took it away from the shelves in Jan 2025
@MoHFW_INDIA , Sir, please do issue an advisory. It's not enough that the fake version has been taken off the shelves. Those who have received the fake version need to be informed too, so that they take the vaccine again.
The perpetrators of this crime need to be brought to justice!
ବନ୍ଦେ ଉତ୍କଳ ଜନନୀ । ଉତ୍କଳ ଦିବସ ଉପଲକ୍ଷେ ଅନେକ ଅନେକ ଶୁଭେଛା ଓ ଶୁଭକାମନା।
Celebrating Utkal Divas, the pride of Odisha! Honoring the spirit of resilience, culture, and unity on this special day.
#UtkalDivas
Nowadays, business owners or CEOs are advocating 70-90-soon more hour workweeks on social media platforms for employees in India. India's relatively low labor costs and large, youthful workforce are often leveraged.
https://t.co/Z4Bv4QxxeR
@Olacabs On 15.11.2024, I booked an Ola ride from SC Bose International Airport to Badabazaar - Canning Street.I was charged Rs1267 but in Ola app showing Rs789.Plz justify.