Delhi High Court Temporarily Restrains Sphinx Worldbiz From Using “SHRM PRO” Mark In Trademark Suit By SHRM

The Delhi High Court has restrained Sphinx Worldbiz Ltd and a company it controls from using the “SHRM PRO” trademark for their services, granting an ex parte ad interim injunction in a trademark infringement suit filed by the Society for Human Resource Management (SHRM).

Justice Vikas Mahajan observed that the use of the mark by the two companies prima facie appeared to be non-bona fide and was causing confusion, deception and a false association among the public. The court noted that consumers could mistakenly believe the services originated from, were connected with, or were endorsed by SHRM.

The court also directed GoDaddy, Apple and Google to withdraw support and block or disable access to the website and mobile applications associated with the disputed mark.

SHRM is a human resources professional body that provides services including advocacy, consultancy, business research, professional networking and conferences.

The website shrmpro.com is operated by a company incorporated in September 2021 that operates under Sphinx Worldbiz's control. The mobile applications are named “SHRMpro” and “SHRMpro-geo”. GoDaddy.com LLC has been impleaded as the domain registrar and web-hosting provider, while Apple Inc, through Apple India, and Google LLC, through Google India, are involved because the applications are available on their respective platforms.

According to SHRM, the company operating under Sphinx Worldbiz applied to register “SHRM PRO” on October 14, 2021, less than a month after its incorporation. The application was filed on a “proposed to be used” basis.

SHRM opposed the application on June 11, 2024. It was recorded as abandoned on December 17, 2024, after the company failed to file a counter statement.

The company filed a fresh application for the word mark “SHRMpro” in Class 42 on October 7, 2025, claiming use since May 12, 2023. SHRM sent a cease-and-desist notice on October 30, 2025. The company refused to comply in its reply the following day.

SHRM also alleged that the website uses a blue-and-white colour scheme and visual presentation deceptively similar to its own. It further claimed that although shrmpro.com was registered in 2015, archived records showed no discernible use of the website until around late 2020.

The court held that SHRM had established a prima facie case for an ex parte ad interim injunction. It also found that the balance of convenience favoured granting relief and that SHRM would suffer irreparable loss and injury if the injunction were refused.

Until the next hearing, Sphinx Worldbiz, the company operating under its control and those acting on their behalf have been restrained from offering for sale, advertising, marketing, exporting, importing, displaying or otherwise dealing in services under “SHRM PRO” or marks identical or deceptively similar to SHRM's registered “SHRM”, “SHRM INDIA” and other formative trademarks, where such use amounts to infringement or passing off. The restraint applies to online and offline activity, including social media.

The matter will be heard by the Joint Registrar on December 2, 2026, and by the court on January 19, 2027.