Delhi High Court Bars “Star Smith” Name And Domain For Infringing A.O. Smith Trademarks

Justice Tejas Karia, passed the interim order on December 24, 2025, observing that the disputed trade name and domain name were deceptively similar to A.O. Smith's registered marks. The court said their use was likely to to confuse consumers, particularly because both sides sell identical and closely related products.

A.O. Smith told the Court that it has used “A.O. Smith” as its house mark internationally since 1874 and in India since 2006. The company said it owns multiple registered trademarks and long-standing domain names, including “www.aosmith.com” and “www.aosmithindia.com

The dispute arose after A.O. Smith discovered that Star Smith Export Pvt. Ltd. was using the trade name “Star Smith” and operating the domain name “www.starsmith.in” for identical goods. According to A.O. Smith, such use was intended to ride on its goodwill and mislead consumers.

The court noted that back in August 2022, it had already restrained the manufacture and sale of products using the marks “STARSMITH” and “STAR SMITH.” However, the questions surrounding the company's corporate name and its domain name were left open at the time and were later revived following a review order passed in October 2024.

Relying on its earlier findings, the court reiterated that “SMITH” is the dominant and essential part of A.O. Smith's trademarks. It observed that adopting the name “Star Smith” in 2020 for identical goods was, at least at this stage, dishonest.

“A clear case of infringement of the Plaintiffs' Trade Marks is made out. The Impugned Trade Marks are nearly identical, the class of consumers targeted by both parties directly overlaps, and the channels of trade are identical,” the Court observed.

The court also rejected the argument that the word “Smith” is generic or lacks distinctiveness. It noted that Star Smith Export Pvt. Ltd. had itself applied for trademark registrations containing the word “Smith,” and therefore could not argue that the term was incapable of exclusive protection.

It further found that the disputed domain name wholly incorporated the essential part of A.O. Smith's mark and was deceptively similar to its domain names.

“If a web search for the Plaintiffs' products using the Plaintiffs' Trade Marks, the initial interest confusion caused by the Impugned Domain Name may deceive and lure the web user to the website associated with the Impugned Domain Name. Even when the web users access the Impugned Domain Name they may find that it is not the Plaintiffs' platform, the Defendants have succeeded in luring users to their site thus, resulting in passing off,” the Court said.

Holding that A.O. Smith had made out a strong prima facie case, the court said the balance of convenience was in its favour and that continued use of the name and domain would cause irreparable harm to its goodwill.

The Court accordingly restrained Star Smith Export Pvt. Ltd. and anyone acting for it from using the trade name “Star Smith,” the disputed domain name, or any other name or website deceptively similar to “A.O. Smith,” in connection with geysers, water purifiers, RO systems, and other allied products.

Case Title: A.O. Smith Corporation and Anr. v. Star Smith Export Pvt. Ltd. and Anr.

Case Number: CS(COMM) 532/2022

For Plaintiff: Advocates Ranjan Narula, Shakti Nair & Parth Bajaj

For Defendants: Advocates Manoj Choudhan, Ujjwal Singh Parmer, Neha Raj Singh & Ridhi Krishna

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