From: Valerie Emanuel <jemanuel@bellsouth.net>
Subject: Unauthorized Use of Registered Trademark
Dear Ms. Emanuel:
Our office represents Religious Technology Center ("RTC"), the
owner of the trademark and service mark "SCIENTOLOGY". The mark
"SCIENTOLOGY" is registered with the United States Patent and Trademark
Office under registration numbers 1,775,441; 1,540,928; 1,342, 353;
1,329,474; 1,318,717; 1,306,997; 898018. We have been informed that you
have registered this trademark in the following domain name:
"scientology-info.com"
(hereinafter referred to as "Infringing Domain").
Your registration of the Infringing Domain has caused your name to
be falsely associated with our client's registered mark as owner and
creates a likelihood of confusion as to source or sponsorship of this
web site, in violation of United States state and federal law, including
the Lanham Act, 17 U.S.C. section 1114 et seq., and various state and
foreign laws. As you may well be aware, the United States Legislature
recently passed the AntiCybersquatting Consumer Protection Act which
expressly prohibits the precise conduct in which you are now engaging
with regard to this domain name.
Accordingly, on behalf of our client, we hereby demand that you
immediately cease and desist from all uses of the Infringing Domain and
that you take immediate action to cancel your registration of the
Infringing Domain. We require a prompt response from you with a
statement of your agreement to comply with this demand.
You may contact me either by telephone, telefax or my e-mail
address at "AMPaquette@aol.com.
Sincerely,
(Note: She then sent a second e-mail, saying disregard first e-mail,
because the domain name was actually 'scientology-info.org'.)
Hello!
Let me start off by saying that I do not recognize your claimed 'legal
rights' in this matter. I do not recognize a word such as 'scientology'
as being copyrightable, any more than I would accept my church's claim
to copyright the term 'christian'. I also note that you have nothing to
say about my current ownership of the domain name
'scientology-kills.org'.
Let me also say how silly it is of you to send me e-mail, which can be
so easily forged, if this matter is of such importance to your
organization. You'd think a lawyer would have better sense, and would
use the proper channels--a certified letter, for instance. In the future
I won't reply to e-mail. Please make a note of that.
That being said, I seem to remember trying to register this domain name
some months ago--sometime last year, in fact. However, I have never paid
for this registration or received anything from whatever body currently
governs the registration of domain names on the Net. I also don't have
any current plans to further pursue the holding of this domain name.
Now, go away and stop bothering me.
Valerie Emanuel
http://www.scientology-kills.org
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Date: Wed, 26 Apr 2000 06:11:57 -0400
Date: Tue, 25 Apr 2000 19:23:57 EDT
From: AMPaquette@aol.com
To: jemanuel@bellsouth.net
CC: AMPaquette@aol.com
Ava Paquette
Moxon & Kobrin
3055 Wilshire Boulevard
Suite 900
Los Angeles, California 90010
Tel: (213) 487-4468
Fax: (213) 487-5385
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