ABDUL KARIM KHAN COMPANY (Advocates, Ban'islers, and Legal l[IonsullaattsII Suite No: 1103. Kasliif Centre. Ill-Iain Sharah-e-Faisal. Karachi. Cell: Fmai]: imdailaliadvf?emailcom. akkcadyncalcsl?gmail?im May 13. 21315 WITHDLIT FREJU DICE if?lo EMAIL: Fall: Tea House Through its chief editor Re: LEGAL NDTIGE FDR El DAMAGES UP TD PHR Edi] MILLIDN Addresses. Under instructions and at the behest of our client hills Mast Private Limited {hereinafter referred to as our ?client"}. we have to 1luv-rite to you and address you as under: 1 . That. through the circulation of defamatory contenti?article originally published by International New ~fork Times titled "Falte Diplomas. Real Clash: Pakistani Company Asset Heaps Millions" {"Impugned Article"). you. the Addresses. have further imputed our client's reputation and have circulated and republished false. fictitious and defamatory allegations against our client. whereby a man of prudent and reasonable thought may have drawn judgment against the character lreputeir dispositions of our client in a manner that offends the very fabric and principles upon which our client bases its upright values and standards. The circulating the defamatory content are reproduced herein below: htbxi'lpaldeahouseneb'Em 5H Eibregk-the-intern et-re port-on-a ita ot-by-n? That. it is clarified that 111a original source of the Irnpugned Article is. the International New ?r?orlt Times has been put under notice of defamation in all the concerned jurisdictions 1iril'ierever our client's reputation has been affected and is facing serious legal repercussions for publishing and originating very serious nature of defamatory and libelous allegations against our client. Tour act of circulating the same defamatory content. amounts to libel for republication of the defamatory content. 1 a 3-. That. our client has vehemently denied all the allegations raised in the impugned article for being false and fictitious. Whereas. the detailed official response released by our client can be seen at the official response of our client is suf?ciently substantiated with required evidence and removes all the doubts created by the defamatory article. Conli'ary to the allegations. our client provides a comprehensive education management system that bene?ts diverse bodies of students and caters to all types of educational institutions?online and traditional. It is a 360 degree solution for students and faculty around the globe. available on multiple educational platforms being its core capability. Furthermore. lIElur Client?s Dnline Education Management System is World's Leader outside North America and our client is now collaborating with other renowned education groups in the USA to provide its Education Management System and is poised to be a major player in the online education industry of USA by 2013. That at the very outset the premise and content of the circulated defamatory article is categorically denied and you are called upon to substantiate your malicious allegations through cogent and legally sound and recognizable proof. documentary and r? or otherwise- That it is pertinent to bring into your notice that our client has recently ventured in the media industry of Pakistan under the name of by announcing a complete media enterprise. Since. its adventure in the media industry. few competitor media houses has started an illegal. unwarranted and unfounded criticism at our client with the intention to primarily misguide the media professionals and keep them away from joining this new channel- In pursuance thereof, many defamatory articles were published from time to time and our client has seriously pursued all the matters through the courts of law. In result thereof. few media houses are restrained through courts restraining orders from publishing any defamatory item against our client which may be detrimental to its repute. That. in an exemplary display of poor journalistic skills and yellow journalism. the author of the imPUQned article quoted references from several imaginary employees to corroborate accusations made out of thin air. None of these accusations have been substantiated with any real proof. Search engines have been used to type ?falte degrees? and whatever have turned up have been portrayed as evidence. Additionally. no proof has been given linkng any of these sites and allegations to our client and widely recognized names such as that of John Kerry have been used to increase the impact of the story. In fact the writer himself admits that when he approached these universities. they denied having any linlts with our client. Furthermore. in a glaring display of bias. he didn?t even mention the fact that all these previous published allegations have been more than adequately addressed by our client eartier in the civil suit QUEENS filed against GED and others- Cine aspect that stands very clear from all this is that a personal grudge has been displayed by the writer. Parallels Iaded with negativity have been drawn with the portrayal of positive Pal-tistan and also including references to the Silicon Valley as if offering 13 facilities [El i3 SDt?l?tEthit?tg that WE Shduld DE about when it is our pnde. its a result of the circulation, our client and his reputation have been severer damaged by the circulation of your harnful and damaging statements. No monetary compensation can repair the wrong caused upon our client hv vour unlavdul acts, howeven the estimated loss occurred till now has reached PHR SIZIEI Million and is grovving everv minute- The contents oflhe instant Notice are without prejudice to our client's rights and I or privileges guaranteed to them under the law. You are, therefore, called upon throth the instant Notice to immediater take down the links wlmin 24 hours from receipt of this Notice and extend an unconditional apology and retraction, for your illegal, defamatory, slanderous and malicious actions, through the same medium. Hereon on receipt of Hits Notice, vou are advised to act in accordance herewith Within 24 hours tailing which he have definitive instruction to initiate Chril as well as criminal proceedings against vou in UK, UAE, US and allianv jurisdictions applying in the circumstances of the case. We Iool-tfonnrard to hearing fromvou as a matter of urgency. ABDUL Wild KHAN at CD advocates E: Eta rriste rs The Client sis