1. Elly is the owner of a chain of fish head curry restaurants called The Fishy Fish ("TFF"). From a single outlet in Little India in 2010, it has since expanded with additional three outlets in the north, east and south regions of Singapore and has won consecutive awards from 2018 to 2020 as Singapore's finest fish head curry restaurant. TFF is known in the market by its logo and slogan "Feel Flames". Feel Flames Th Fishy Fish 2. TFF's signature dish is its special flaming hot fish curry, "The Flame" which is marinated and cooked with a special curry paste that is a closely guarded secret of TFF. Elly is currently in discussion with her publisher to publish her original work "The Art of Flaming Fish" - a first of its kind instructional manual on how to prepare the perfect curry paste by using various fire-clay oven cooking techniques. 3. In 2016, Suresh was employed as the Head Chef of TFF. In the first two (2) years as Head Chef, Suresh managed to improve on TFF's signature dish. Further to a local documentary on the brand, he became known as the face of TFF and its celebrity chef. Suresh also helped Elly to finalise the manuscript for "The Art of Flaming Fish" by providing the photos and artwork cover as well as minor editorial changes to the manual which were non- substantive in nature. 4. TFF enjoyed one of its most profitable years in 2018, generating profits of $4.6 million, which was a $1.2 million increase in profits from the previous year. 5. In January 2020, Elly and Suresh had a falling out. This resulted in Suresh resigning from TFF.6. On 1 November 2020, Suresh opened a new restaurant in Siglap called The Fried Fish and used a logo similar to TFF, with the only differences being that the fish is horizontal with a crown and uses the slogan "Feel Fire". Feel Fire The Fried Fish 7. The Fried Fish also serves the same signature dish as TFF. Suresh has plans to open three other outlets in the same areas where TFF's outlets are located. Suresh has also recently contracted with a local book publisher to publish 10,000 copies of the instructional manual that he previously helped Elly to complete, but under the title "Suresh's Art of Flaming Fish". 8. Elly notices that TFF's business revenue has been dismal since the opening of Suresh's restaurant. Elly checks with her existing customers and many of them inform her that they have been going to The Fried Fish restaurant, as they were under the impression that it is a new TFF outlet. Elly also stumbles onto Suresh's new book at a local bookstore. Elly is extremely furious by Suresh's betrayal and feels that the years of building the TFF brand is being destroyed. 9. Separately, to boost sales, Elly also decided to promote her signature dish to boost TFF's sales at a discounted price. TFF's website read as follows: - December's Special Enjoy our fantastic signature special flaming hot fish curry with fresh fish, "The Flame" at $20 (U.P $50). Valid for Deliveries only.10. In mid-December 2020, due to overwhelming demand and a spike in global prices of fresh fish, Elly decided to replace the fresh fish with frozen fish. She obtained the frozen fish from a supplier Mr Sim that she had not worked with before. However, someone in the industry had told Elly that Mr Sim may not be selling fish that should be frozen in accordance with regulations and the conditions that the fish were kept in were not up to standard. Given Elly's desperation and lack of budget to procure the fresh fish, using Mr Sim's frozen fish like it could breathe life back into TFF's flailing situation. 11. However, Elly's customers picked up on the change in the fish and sent in numerous complaints. Many of them demanded a full refund. 12. On one occasion, Ken, Elly's delivery personnel, was tasked to deliver some orders of TFF's signature dish to Ahmad home for a special dinner with his wife, Siti. Ken had overslept in TFF's delivery van and had forgotten to keep the signature dish in the van's heated apparatus designed to keep food fresh and bacteria free. He was required to deliver the dish within two (2) hours from the preparation, but because he overslept, it was also delivered more than four (4) hours late. As a result, Ahmad wife Siti fell sick and unwell because the signature dish contained high levels of bacterial contamination. Siti's wife was hospitalised and she incurred medical expenses. 13. Elly is worried if these customers have legal remedies against TFF. Elly admits that her management of her staff, the hygiene standard and the food at TFF may have fallen below acceptable standards as she has been too engrossed with managing her flailing business