BY EMAIL/SPEEDPOST A.D./HAND DELIVERY MZM/ZM//2020 11 February 2021 To, Broadcast Audience Research Council (“BARC”) Valencia, 4th Floor, Rajkamal Marg, 61, Dr S.S. Rao Road, Parel, Mumbai - 400 012 Email:
[email protected],
[email protected],
[email protected] Re : 1) Material Breach of End User License Agreements (“EULAs”) dated 03.12.2015, 08.12.2017 and 08.12.2020. 2) Internal Investigation Report, i.e. Report of Digital Forensics Services dated 24.07.2020 submitted to BARC by Acquisory Risk Consulting Pvt. Ltd. 3) C.C. NO. 484/PW/2020 (State of Maharashtra v. Vishal Ved Bhandari & Ors) (the “charge-sheet”) pending on the file of the Ld. Addl. Chief Metropolitan Magistrate, 37th Court, Esplanade, Mumbai. Sub : Illegal and fraudulent viewership data manipulation and tampering of Television Rating Points at the Broadcast Audience Research Council. Madam/Sirs, We are concerned for our clients Bennett Coleman & Company Ltd., (“BCCL/Our Clients”) who have instructed us to issue this legal notice to you (“Notice”), on account of the shocking illegal and fraudulent viewership manipulation and tampering of Television Audience Measurement and Television Rating Points (“TRP”) particularly, of our Clients’ channel “Times Now” (“Aggrieved Channel/Channel”) by Broadcast Audience Research Council (“BARC/you”) and under our Clients’ instructions, we hereby notify you as under: 1. Our Clients are a Company incorporated under the provisions of the Indian Companies Act, 1956 (“Companies Act”) having its registered office at The Times of India Building, Dr. Dadabhai Naoroji Road, Fort, Mumbai – 400001 and the Television Division’s Office at Trade House, Kamala Mill Compound, Senapati Bapat Marg, Lower Parel, Mumbai – 400 013.