Decision

Decision on Botanica Ltd

Updated 21 July 2023

Companies Act 2006

In the matter of application No. 3294 by Botanica Agriculture and Extraction Ltd for a change to the company name of Botanica Ltd, company registration no. 12562150

1. Company 12562150 (바카라 사이트渢he primary respondent바카라 사이트�) was incorporated on 17 April 2020 with the name Botanica Ltd. On 29 September 2020, an application was made to this Tribunal under section 69 of the Companies Act 2006 (바카라 사이트渢he Act바카라 사이트�). Although we shall return to the identity of the applicant later in this decision, we note that box 3 of the Form CNA1 which reads: 바카라 사이트淣ame and address of the applicant바카라 사이트�, was completed in the following manner:

Sembu Gbla 바카라 사이트� Botanica Agriculture and Extraction Ltd, 17 Trafalgar Road, Clacton-on-Sea, Essex, United Kingdom, CO15 1LR.

2. Section 69 of the Act states:

(1) A person (바카라 사이트渢he applicant바카라 사이트�) may object to a company바카라 사이트檚 registered name on the ground바카라 사이트�

(a) that it is the same as a name associated with the applicant in which he has goodwill, or

(b) that it is sufficiently similar to such a name that its use in the United Kingdom would be likely to mislead by suggesting a connection between the company and the applicant.

(2) The objection must be made by application to a company names adjudicator (see section 70).

(3) The company concerned shall be the primary respondent to the application.

Any of its members or directors may be joined as respondents.

(4) If the ground specified in subsection (1)(a) or (b) is established, it is for the respondents to show바카라 사이트�

(a) that the name was registered before the commencement of the activities on which the applicant relies to show goodwill; or

(b) that the company바카라 사이트�

(i) is operating under the name, or

(ii) is proposing to do so and has incurred substantial start-up costs in preparation, or

(iii) was formerly operating under the name and is now dormant; or

(c) that the name was registered in the ordinary course of a company formation business and the company is available for sale to the applicant on the standard terms of that business; or

(d) that the name was adopted in good faith; or

(e) that the interests of the applicant are not adversely affected to any significant extent.

If none of these is shown, the objection shall be upheld.

(5) If the facts mentioned in subsection 4(a), (b) or (c) are established, the objection shall nevertheless be upheld if the applicant shows that the main purpose of the respondents (or any of them) in registering the name was to obtain money (or other consideration) from the applicant or prevent him from registering the name. (6) If the objection is not upheld under subsection (4) or (5), it shall be dismissed.

(7) In this section 바카라 사이트済oodwill바카라 사이트� includes reputation of any description.바카라 사이트�

3. In the application (completed by Mr Sembu Gbla), it was requested that the primary respondent바카라 사이트檚 secretaries/directors, namely Aman Dulay, Atul Sharma and Sandeep Singh Varaich be joined to the proceedings under the provisions of section 69(3) of the Act. The named individuals were given notice of this request and an opportunity to comment or to object. As the Tribunal received no comments or objections they were joined to the proceedings as co-respondents on 4 February 2021 and made jointly and severally liable with the primary respondent for costs.

4. In response to question 10 on the Form CNA1 which reads, 바카라 사이트淲hat is the name associated with you which has caused you to make this application?바카라 사이트�, it is stated:

Botanica Agriculture and Extraction Ltd is the full name of our company, the company has also recently registered Botanica Pharmacueitics [sic] Ltd due to the threat posed by the formation of Botanica Ltd.

5. In relation to 바카라 사이트済oodwill or reputation바카라 사이트� (question 11 on the Form CNA1), it is stated:

The company has worked extremely hard to develop a strong brand reputation and good social presence. We are now registered in four countries and counting, and are recognised by our trading name (which is the prefix of our full name) Botanica. The company has research partnerships pending with the University of Westminster life science department and UCL. These are, of course, relationships we worked very hard to develop and do not wish to jeopardise. We are also working very hard to acquire various licences abroad which will benifit [sic] our UK based business tremendously, the situation at present however remains highly sensative [sic] and any ambiguity such as this may cause irreparable damage to our brand which has taken many years to develop.

6. It is stated that that the field of business in which the names relied upon have goodwill/reputation is:

Life sciences, pharmaceutical preperation [sic], cultivation of medicinal crops.

7. it is stated that the company name is objected to because:

Careful investigation has revealed severe concerns about the credibility, integrity and conduct of the defendants as they both display some very perculiar [sic] online activity. A company Mr Sharma was recently appointed director of Sappire Independant Finance Limited has overdue accounts even though the appointment was only made this year. Scott Thomas Findlay who was supposedly born in June 1988 resigned on the 3rd of July 2020 and was replaced by Mr Sharma. What is most peculiar about this is that the two gentleman seem to share the same personal address. Which of course may give rise to the consideration that this name, may in fact simply be an allias [sic] used by Mr Sharma. Scott Thomas Findlay was actually a rifleman in the Auckland war who died in September 1916. Sandeep Singh is the director of another company, Property No.6- which in 5 years has only reported losses, on the 1st of September he started another business, the spice fox, which is in the catering industry. The true occupation of this individual is not known in addition to being involved in catering this individual has also declared himself a property investor and now a pharmacist. Most respectfully, above is the clear activity of fraudsters, as such the company wishes to have no affiliation with any persons concered [sic].

8. In response to questions 15 and 16 on the Form CNA1 which read 바카라 사이트淲hat action do you want the Tribunal to take?바카라 사이트� and 바카라 사이트淧lease provide any other relevant information you may have that you consider relevant to this application바카라 사이트� respectively, it is stated:

For Botanica Ltd to be dissolved or instructed to change their name so that the defendants are not able to claim association with our group. Botanica Ltd appearing as dissolved on the register is also not ideal as this may give rise to further confusion where our brand name is concerned. With this being said a complete removal of the listing would be ideal so as to avoid any confusion in the future. It would indeed be bizzare for there to be two pharmaceutical companies, both based in the UK, both called Botanica. Furthermore, the above may lead to a situation where an automatic assumption is made, whereby Botanica Ltd is considered to be part of our group. For obvious reasons, it is crutial [sic] for the company to mitigate any chance of this being possible for the opportunists. We are also very concerned that they may continue carrying out their fraudulent activities while using our name and we have no means of doing anything to prohibit them from what they are doing. The action of them forming Botanica Ltd is considered by us to be a case of Corporate Idententity [sic] Fraud.

And:

It is our clear understanding that the individuals concerned are opportunists who registered Botanica Ltd after seeing us online, with the intention of trying to use our brand name/reputation for their financial gain and/or to prevent us from later acquiring the name for ourselves. With respect I believe it would certainly seem to be an ill willed move on their part in either case.

9. It is stated that costs are being sought and in response to question 7 on the Form CNA1 which reads:

Did you warn the company that if it did not change its name that you would start legal proceedings against it? If 바카라 사이트測es바카라 사이트�, when did you warn the company?,

it is further stated:

We have not made any contact with the individuals due to several highly concerning truths which have been discovered about them. We have appealed with Companys [sic] House and recently heard back from a case manager in the breaches team. Unfortunately however, there were some complications with regard to instructing a change of name under section 67(1).

The defence

10. On 17 December 2020, the primary respondent filed a notice of defence (signed by Atul Sharma). Mr Sharma states:

바카라 사이트� Every statement made by Mr Sembu Gbla is inaccurate, unjustified and some instances contradictory based on how he seems to interpretate [sic] his areas of concern. We deny every part of his claim.

We are very disappointed to have received correspondence from the claimant, specifically as to how you can make a charge for filing a defence when we followed all legal channels in setting up our company. There is no evidence of any wrong doing, and the allegations raised.

Prior to setting up the company, companies house was researched to determine the name of our company was available, and we have set about the usual and legal process in setting up this company. The names and addresses filed are accurate with no wrong doing having taken place바카라 사이트�바카라 사이트�

11. Mr Sharma asks for a range of allegations made in the Form CNA1 which relate, broadly speaking, to the business being relied upon and the claims made in relation to, inter alia, himself and Messrs. Varaich and Findlay to be proved. Attached to the Form CNA2 are four appendices, to which we shall return below. Insofar as the business being relied upon is concerned, we note that the primary respondent asks for proof of the following:

바카라 사이트�1). Registrations details of the 4 countries they are working in, as Botanica with dates preceding the 12th Nov 2019 if possible.

2) Proof of pending Partnership with Westminster University and ULC under the name of Botanica, Email trails with date and or such proof would be sufficient. Any sensitive information can be censored.

3) Contact details for a person with significant authority to prove a pending partnership is in the pipeline as Botanica.

4) Proof of strong social presence as Botanica with a time stamp. Preferably for dates preceding 12th Nov 2019 and for the years of brand building?바카라 사이트�.

12. In its Notice of Defence, the primary respondent indicates that it is relying upon defences based upon sections 69(4)(a), (c), (d) and (e) of the Act. It further indicates that it is claiming its costs.

13. In these proceedings, both parties represent themselves. The only evidence filed during the evidence rounds was from Mr Gbla. However, as this Tribunal routinely looks for guidance to case law developed in trade mark proceedings to assist it, given the comments of the Appointed Person, Mr Daniel Alexander Q.C., in 바카라 사이트淪IMMONS바카라 사이트� trade mark (BL-O-468-12) and as the Form CNA2 was signed by Mr Sharma who is a secretary/director of the primary respondent, we intend to treat his pleadings and the appendices attached to that Form as evidence.

14. The parties were asked if they wanted a decision to be made following a hearing or from the papers. Neither party requested a hearing, nor did they elect to file written submissions in lieu of attendance.

Evidence

The primary respondent바카라 사이트檚 evidence

15. The following appendices were attached to the Form CNA2:

1 바카라 사이트� this consists of details obtained from Companies House in relation to Botanica Agriculture and Extraction Ltd. This shows that company no. 11020673 was originally incorporated under the name ACAS INTERNATIONAL LTD with the change to its current name being agreed by special resolution on 11 November 2019;

2 바카라 사이트� of this exhibit Mr Sharma states: 바카라 사이트淭here is a website under the name of www.botanicamedicare.co.uk which is linked to his companies. That website is not live and is under construction, which is to be made live in JAN 2021, as suggested by the page바카라 사이트�.바카라 사이트�

The page provided from the website mentioned contains a printing date of 17 December 2020. It contains the word 바카라 사이트淏otanica바카라 사이트� at the top left hand side of the page and the following text: 바카라 사이트淭his website is under construction and will be live in January 2021 - Thank you for visiting바카라 사이트� and 바카라 사이트淏otanica MediCare a devision of Botanica Pharmaceutics goes by the trading name Botanica, and forms part of the Botanica Agriculture and Extraction Ltd (UK) Group, registered in England and W바카라 사이트�Companies Act 2006. Companies House Registration No. 11020673. Copyright 漏 2020. All rights reserved바카라 사이트�;

3 바카라 사이트� is said to be a page from botanicamedicare바카라 사이트檚 Instagram account. It contains a printing date of 17 December 2020 and looks like this:

4 바카라 사이트� in relation to this page (which also contains a printing date of 17 December 2020), Mr Sharma states:

Furthermore after checking the domain for www.botanicamedicare.co.uk. It states that the domain is was only brought recently as there is no recent date of when this domain was brought or made active yet. Which yet again makes me question the integrity and legitimacy of this claim바카라 사이트�[all sic].

Mr Gbla바카라 사이트檚 evidence

16. This consists of a witness statement, dated 30 March 2021. Mr Gbla is a director of Botanica Agriculture and Extraction Ltd. He confirms the source of information in his statement is 바카라 사이트減ersonal knowledge & company records.바카라 사이트� A good deal of this statement contains submissions rather than evidence of fact. Although we will only record evidence of fact here, for the avoidance of doubt, we have read the statement and will bear its contents in mind when reaching a conclusion. Insofar as appendix 2 to the Form CNA2 is concerned (in relation to the domain name botanicamedicare.co.uk), Mr Gbla explains that this 바카라 사이트渋s an old domain no longer is use바카라 사이트�, adding that botanicapharmaceutics.co.uk. is the new domain name.

17. In relation to the Instagram account, he states:

6. The reputation to which we refer is one which has been established with prospective clients in our field. Relevant consumers to our business will be licensed pharmaceutical manufacturers only and as such, the company has no interest in developing a presence directed toward members of the general public.

18. Exhibit 1 consists of details obtained from the Companies House website in relation to Botanica Agriculture and Extraction Ltd and to company no. 12899845 바카라 사이트淏otanica Pharmaceutics Ltd바카라 사이트� which was incorporated on 23 September 2020. We note that Mr Gbla is a director of both companies.

19. Exhibit 2 is said to provide 바카라 사이트淐onfirmation of incorporation in the Netherlands (complete)바카라 사이트�. The page provided (the source of which is described as 바카라 사이트淓mail from Westerdok Notary바카라 사이트�) is addressed to Mr Gbla, is dated 19 November 2020 and includes the following: 바카라 사이트淵our company is established and registered바카라 사이트�바카라 사이트�. The page provided refers to 바카라 사이트�바카라 사이트�Botanica Pharmaceutics B.V.바카라 사이트�

20. Exhibit 3 (from the Corporate Affairs Commission, Sierra Leone), indicates that 바카라 사이트淏otanica Agriculture and Extraction Limited바카라 사이트� was registered in Sierra Leone on 3 September 2020.

21. Exhibit 4 consists of what appears to be part of a contract between Botanica Agriculture and Extraction Ltd (with an address in the UK) and a lawyer (whose name has been redacted) in relation to a:

바카라 사이트淟egal opinion on the German legal framework and preconditions for import of medical cannabis, international obligations, EU-GMP, contact with BfArM etc.바카라 사이트�

Also provided is what is described as a 바카라 사이트渞etainer invoice바카라 사이트� dated 26 August 2020 (in the amount of 鈧�2500) issued to Botanica Agriculture and Extraction Ltd (at an address in the UK), in relation to 바카라 사이트渙ur fees contract바카라 사이트�from 26th of August 2020, 10h, as from 8/26/20.바카라 사이트�

22. Exhibit 5 consists of an email exchange between 바카라 사이트淪embu Gbla Botanica바카라 사이트� and an individual from a 바카라 사이트淧ortuguese Law firm바카라 사이트� (whose name has been redacted). It appears that Mr Gbla바카라 사이트檚 email was dated 3 November 2020. It reads:

Dear xxx thanks for this. It was indeed a pleasure talking with you. We look forward to working with you also and will be in touch in due course.

23. The response from the unnamed individual (which appears to be dated 3 February 2021) reads:

바카라 사이트� Dear Sembu,

I hope you are doing well. I wonder if you have any developments on your decision to incorporate in Portugal바카라 사이트�바카라 사이트�.

Mr Gbla adds that this process was 바카라 사이트�바카라 사이트�delayed by Covid-19.바카라 사이트�

24. Exhibit 6 consists of an email exchange between Mr Gbla and a 바카라 사이트淪enior Lecturer in Molecular Pathology바카라 사이트� at the University of Westminster whose name has been redacted. The title of the email exchange is 바카라 사이트淯niversity of Westminster 바카라 사이트� Research partnership proposal.바카라 사이트�

25. On 26 February 2020 Mr Gbla wrote to the unnamed individual stating:

Dear Dr xxxx. Please find attached correspondence which we hope will be of interest to you바카라 사이트�바카라 사이트�

26. The unnamed individual responded to Mr Gbla on the same date stating:

바카라 사이트� Dear Sembu,

Thank you for the email, this sounds a good opportunity and I am copying our office for research partnerships in at this point to discuss further바카라 사이트�바카라 사이트�

27. Exhibit 7 consists of what Mr Gbla describes as 바카라 사이트渙ur brand logo.바카라 사이트� The two undated images provided consist of the word 바카라 사이트淏otanica바카라 사이트� presented in title case in the colour blue and the same word presented in the colour white against a blue rectangular background.

28. That concludes our summary of the evidence filed to the extent we consider necessary.

Decision

The identity of the applicant

29. As we mentioned earlier, both parties in these proceedings are unrepresented. For the sake of convenience, we remind ourselves that box 3 of the Form CNA1 which reads: 바카라 사이트淣ame and address of the applicant바카라 사이트� was completed in the following manner:

Sembu Gbla 바카라 사이트� Botanica Agriculture and Extraction Ltd, 17 Trafalgar Road, Clacton-on-Sea, Essex, United Kingdom, CO15 1LR.

30. We note that in its correspondence to the parties, the Tribunal has identified the applicant as being 바카라 사이트淪embu Gbla바카라 사이트�. However, we further note that the Form CNA1 includes the following phrases: 바카라 사이트淭he company has worked extremely hard바카라 사이트�바카라 사이트� (question 11), 바카라 사이트淭he company has research partnerships바카라 사이트�바카라 사이트�, (question 11), 바카라 사이트渋t is crutial [sic] for the company to mitigate바카라 사이트�바카라 사이트� (question 15) and 바카라 사이트渋s considered by us to be a case of corporate Idententity [sic] fraud바카라 사이트�바카라 사이트� (question 15). We have added the underlining. Consequently, when considered as a totality, we are satisfied that as Mr Gbla completed the Form CNA1 (and as he is an officer of Botanica Agriculture and Extraction Ltd), it is palpably clear that the applicant in these proceedings is Botanica Agriculture and Extraction Ltd and not Mr Gbla personally. It is upon that basis we intend to proceed.

31. If the primary respondent defends the application, as here, the applicant must establish that it has goodwill or reputation in relation to a name that is the same, or sufficiently similar, to that of the primary respondent바카라 사이트檚 name suggesting a connection between the applicant and the primary respondent. If this burden is fulfilled, it is then necessary to consider if the primary respondent can rely upon defences under section 69(4) of the Act.

32. Before proceeding, we think a chronology of what appear to be the key events in these proceedings may be helpful. This, in our view, is as follows:

Chronology

18 October 2017 바카라 사이트� applicant incorporated in the UK as ACAS INTERNATIONAL LTD;

11 November 2019 바카라 사이트� applicant바카라 사이트檚 name changed to Botanica Agriculture and Extraction Ltd;

26 February 2020 바카라 사이트� email exchange with the University of Westminster regarding a research partnership proposal;

17 April 2020 바카라 사이트� Botanica Ltd incorporated in the UK i.e. the primary respondent;

August 2020 바카라 사이트� agreement between Botanica Agriculture and Extraction Ltd and a German lawyer;

3 September 2020 바카라 사이트� Botanica Agriculture and Extraction Limited registered in Sierra Leone;

23 September 2020 바카라 사이트� Botanica Pharmaceutics Ltd incorporated in the UK;

3 November 2020 바카라 사이트� initial enquiries regarding incorporation in Portugal;

19 November 2020 바카라 사이트� Botanica Pharmaceutics B.V. incorporated in the Netherlands.

What names is the applicant relying upon?

33. In its application, the applicant identifies Botanica Agriculture and Extraction Ltd and Botanica Pharmacueitics Ltd as the names which has caused it to make its application. Notwithstanding the misspelling, we are satisfied given the information provided in exhibit 1 to Mr Gbla바카라 사이트檚 statement, that this should have read Botanica Pharmaceutics Ltd. The applicant also states:

Botanica Agriculture and Extraction Ltd is the full name of our company바카라 사이트�바카라 사이트� (response to question 10);

And:

We are now registered in four countries and counting, and are recognised by our trading name (which is the prefix of our full name) Botanica바카라 사이트�바카라 사이트� (response to question 11).

34. Having reviewed the evidence as a totality, it is clear that the applicant should also have identified 바카라 사이트淏otanica바카라 사이트� solus when it responded to question 10. However, it appears that the primary respondent was fully aware of this when, in its Form CNA2, it asked for proof the applicant is working 바카라 사이트渁s Botanica바카라 사이트�, 바카라 사이트渦nder the name of Botanica바카라 사이트�바카라 사이트�, 바카라 사이트渋s in the pipeline as Botanica바카라 사이트� and has 바카라 사이트渟trong social presence as Botanica.바카라 사이트� As a consequence, we shall proceed on the basis that the applicant is also relying upon the word 바카라 사이트淏otanica바카라 사이트� solus. The applicant must show that it had a goodwill or reputation at the date mentioned which is associated with one or other of the names indicated.

Does the applicant have the necessary goodwill/reputation?

35. The relevant date is the date of incorporation of the primary respondent which, in this case, is 17 April 2020. Section 69(7) of the Act defines goodwill as a 바카라 사이트渞eputation of any description바카라 사이트�. Consequently, in the terms of the Act it is not limited to Lord Macnaghten바카라 사이트檚 classic definition in IRC v Muller & Co바카라 사이트檚 Margerine Ltd [1901] AC 217: 바카라 사이트淲hat is goodwill? It is a thing very easy to describe, very difficult to define. It is the benefit and advantage of the good name, reputation, and connection of a business. It is the attractive force which brings in custom. It is the one thing which distinguishes an old-established business from a new business at its first start.바카라 사이트�

36. In relation to establishing a goodwill/reputation, as we mentioned earlier, this Tribunal routinely looks for guidance to case law developed in trade mark proceedings. In such proceedings, it is well-established that goodwill of more than a trivial nature, even if it is small, is capable of protection (Stacey v 2020 Communications [1991] FSR 49 refers). In his evidence, Mr Gbla states:

9바카라 사이트�the initial establishment of our brand with the formation of Botanica Agriculture and Extraction바카라 사이트�

37. That, in our view, is an admission that there was no use of any of the names being relied upon (particularly Botanica solus) prior to the date the applicant changed its name from ACAS INTERNATIONAL LTD to its current name i.e. 11 November 2019. However, even if such use had been made, as no evidence has been provided in this regard, it is not a matter upon which the applicant may now rely. Thus, it appears that at best, the applicant바카라 사이트檚 use of some of the names being relied upon commenced only five months before the primary respondent was incorporated in April 2020.

38. We note that the primary respondent requested certain evidence in its notice of defence. We also note that the applicant questioned the legitimacy of the primary respondent바카라 사이트檚 request for information about 바카라 사이트渢he affairs of our brand바카라 사이트�. Whilst it is true that the respondent(s) cannot dictate the evidence which should be filed by the applicant, there remains a burden on the applicant to establish before the Tribunal that it has goodwill/reputation in one or more of the names being relied upon. Whilst that is a relatively low hurdle, we would normally expect to see that prior to the relevant date the applicant had made outward-facing use of one or more of the names being relied upon, together with, for example, an indication of the number and types of customers the applicant enjoyed, turnover figures achieved and promotional efforts.

39. Although the applicant has provided evidence to show that it has arranged for various companies to be incorporated which contain the word 바카라 사이트淏otanica바카라 사이트� and has engaged a lawyer in Germany, as one can see from the above chronology, all the evidence in this regard is from after the relevant date. In addition, the evidence filed by the primary respondent which relates to a website which was not to be made operational under January 2021 and an Instagram account when can only be dated from December 2020, does not assist the applicant in establishing a goodwill/reputation in one or other of the names being relied upon at the relevant date.

40. As far as we can tell, the only evidence that has been provided that can be dated prior to the relevant date is the redacted email exchange between Mr Gbla and an individual at the University of Westminster regarding a 바카라 사이트淩esearch partnership proposal바카라 사이트� (exhibit 6), which is dated 26 February 2020. Although this exhibit contains an upper case letter 바카라 사이트淏바카라 사이트� on the left hand side of the page, it does not appear to contain any references to any of the names being relied upon. Nor does it indicate the nature of the proposed research partnership. However, even if it did, without more, a single example of use of this nature falls a long way short of meeting even the relatively low hurdle necessary for the applicant to establish that at the relevant date it had goodwill/reputation in the name 바카라 사이트淏otanica바카라 사이트� solus or any of the other names being relied upon.

41. Without the necessary goodwill/reputation, the application falls at the first hurdle and is dismissed accordingly.

Outcome

42. The application has failed and, subject to any successful appeal, the primary respondent바카라 사이트檚 name will remain as Botanica Ltd.

Costs

43. As the primary respondent has been successful, it is entitled to a contribution towards it costs, based upon the scale of costs published in paragraph 10.1 of the Practice Direction which, we note, contains the following:

Those without representation will normally receive 50% of the above but will receive the full expenses.

44. Proceeding on that basis, the primary responded is entitled to an award in the amount of 拢350 i.e. 拢200 in respect of its reviewing of the application and the preparation of its defence and 拢150 in respect of the official fee associated with that defence.

45. We order Botanica Agriculture and Extraction Ltd to pay to Botanica Ltd the sum of 拢350 within 21 days of the expiry of the appeal period, or within 21 days of the final determination of this case if any appeal against this decision is unsuccessful. Under section 74(1) of the Act, an appeal can only be made in relation to the decision to dismiss the application; there is no right of appeal in relation to costs.

46. Any notice of appeal against this decision must be given within one month of the date of this decision. Appeal is to the High Court in England, Wales and Northern Ireland and to the Court of Session in Scotland.

47. The company adjudicator must be advised if an appeal is lodged, so that implementation of the order is suspended.

Dated 3 November 2021

Christopher Bowen
Teresa Perks
Heather Harrison
Company Names
Adjudicator