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Can I complain about counterfeit trademarks if I am not the trademark owner?

Yes.

According to the provisions of the Trademark Law, when a case of infringement of the exclusive rights of a registered trademark occurs, the trademark registrant or interested party may file a lawsuit with the People's Court or request the industrial and commercial administrative department to handle it. Among them, interested parties include the licensee of the registered trademark license contract, the legal successor of the registered trademark property rights, etc.

According to the provisions of the Supreme People's Court's "Interpretations on Several Issues Concerning the Application of Law in the Trial of Civil Disputes over Trademarks", when a case of infringement of the exclusive right to use a registered trademark occurs, the licensee of the exclusive use license contract may file a lawsuit with the People's Court File a lawsuit. The licensee of an exclusive license contract shall have independent rights of action.