TIMELINE OF FACTS

 Sometime on August 2018, Market Researchers of IP2 Manila

Associates (“IP2 Manila”) Glenn B. Nicdao and Bernardo R.
Escobio met with an informant who introduced himself as a
machine operator at production facilities located in Malabon and
Bulacan areas which according to the informant are engaged in
manufacturing several counterfeit products of different brands,
including products of UP in the market.

 Also, according to the informant, the stores MARMON TRADING

and SYTHAN ROCHELLE BELO (“SRB”) are among those engaged
in the distribution of the finished products of the said production
facilities.
o Marmon Trading is located at Stall 1P-8, 1 st Floor, 999
Shopping Mall, Soler Street., Brgy. 293 Zone 028, Binondo
Manila.
o SRB is located at 1P-11, 1 st Floor, 999 Shopping Mall, Soler
Street., Brgy. 293 Zone 028, Binondo, Manila.

 On August 28, 2018, the Market Researchers of IP Manila,

together with the informant, visited Marmon Trading and SRB and
were able to purchase among others:
o Marmon Trading:
 1 600 ml. bottle of DOVE intensive lotion (P70)
o SRB:
 1 739ml. bottle of TRESEMME Keratin Shampoo
 1 box of Sunsilk Shampoo

 On August 29, 2018, the Market researchers of IP Manila together

with the Informant, went to the production facilities located in
Bulacan and Malabon, respectively.
o 1st visited was the production facility located at Purok 4,
Barangay Catacte, Bustos Bulacan.
o 2nd visited was the production facility located along Pulilan
Regional Road, Dampol 1, Pulilan Bulacan.
 On August 30, 2018, the Market researchers of IP Manila together
with the Informant and the latter’s assistant personnel visited the
production facility located at No. 89 Oak Street, Victoneta North
Subdivision, Brgy. Potrero, Malabon City.

 According to the informant, the said production facilities are

owned and operated by Susan Lu and/or Wan Er Zhang and/or
Ciying Wang and/or John Tamayo Tan and/or Harry Lim Gomez.

 Upon examination of the products obtained from the stores, it was

determined by the market researchers that the said products are
counterfeit products as compared to the original, they are much
cheaper and of poor quality in packaging and printing.

 as verified from the records of the DTI, it appears that John Roel
M. Sande is the registered owner of Marmon Trading, while SRB
and/or Mei Hong have no records.

 The said findings were reported to UP and thereafter the market

researchers were instructed by the former to immediately
coordinate with the proper government law enforcement agencies
in order to commence the appropriate criminal and civil action
against the aforementioned establishments and production
facilities.
 On September 2018, UP through CCC filed a formal letter-
complaint with the Director of the NBI, requesting for assistance in
investigating and apprehending the individuals involved in the
unauthorized production and/or distribution and/or sale of
counterfeit products which bear unauthorized reproductions of the
trademarks owned by UNILEVER N.V. and ACII.
o The case was assigned to S.I. III George R. Gabinete or the
NBI- Intellectual Property Rights Division (NBI-IPRD).
 The Market researchers of IP Manila, together with S.I. Gabinete
and the informant, went to the production facility located at No.
89 Oak Street, Victoneta North Subdivision, Brgy. Potrero, Malabon
City.
 Escobio, one of the Market researchers of IP Manila was
introduced by the informant as the latter’s relative who will
temporarily assist the former in his work. Escobio was able to
discretely take photographs.
 On the same day, the market researchers of IP Manila together
with S.I. Gabinete, visited the stores (MARMON TRADING and
SRB) in 999 Shopping Mall, they were able to purchase among
others:
o Marmon Trading:
 1 600 ml. bottle of DOVE Intensive Lotion
 1 739 ml. bottle of Tresemme Keratin Smooth
conditioner
o SRB:
 1 739 ml. bottle of Tresemme New Novveon
 1 739 ml. bottle of Tresemme Keratin Smooth
conditioner
 On October 10, 2018, the Market researchers of IP Manila,
together with SI Gabinete went to the production facility located at
Purok 4, Brgy. Catacte, Bustos Bulacan.
 The informant introduced Nicdao (one of the market researchers)
as his relative who will help him for the day. Nicdao was able to
discreetly take photographs.
 On the afternoon of the same day, they proceeded to the
production facility located at Pulilan Regional Road, Dampol 1,
Pulilan Bulacan. Again, Nicdao was introduced by the informant as
the latter’s relative who will help him for the day. Again, Nicdao
was able to discreetly take photographs.
 On December 6, 2018, the market researchers, together with S.I.
Gabinete and the informant revisited the stores in the 999
Shopping Mall.
o Marmon Trading:
o SRB:
 1 739 ml. bottle of Tresemme conditioner
 1 739 ml. bottle of Tresemme Keratin Shampoo
 1 box of Sunsilk Shampoo