January 2, 2001
VIA ELECTRONIC MAIL (email@example.com)
CONFIRMATION VIA MAIL
Mr. David Young
Burbank, CA 91505
Dear Mr. Young:
NFL Properties, Inc. represents the National Football League and its member
teams with respect to all intellectual property matters. One of our member
teams, the Cincinnati Bengals, Inc. (the "Bengals") operates the official
team website, www.bengals.com <http://www.bengals.com>. The Bengals are the
copyright owner of the content on bengals.com, including the articles
written by Geoff Hobson.
It has come to our attention that you are operating a website under the
domain name "www.mikebrownsucks.com". For your information, you may not
copy copyrighted material from bengals.com. That would include the articles
written by Geoff Hobson and the transcripts from various press conferences.
Such conduct constitutes copyright infringement under Title 17 of the United
States Code. In fact, in light of the "mission" of your site, we find it
particularly egregious that you would use the property of the Bengals to
provide content for your site.
Further, your minor modifications to the Bengals' official team logo are
improper. The Bengal Tiger Head Design Mark is a registered and famous
trademark of the Bengals. As such, your modification of that logo and your
use of this mark on both your website and as a design on apparel product for
sale violate both federal and state laws.
Accordingly, we hereby demand that your company immediately cease and desist
from the unauthorized use of any of the Bengals' intellectual property
including copyrighted materials and trademark designs. Additionally, we
demand that you provide a full accounting with respect to all sales of
merchandise incorporating your facsimile of the Bengals Tiger Head Design
Mark, and the records documenting the same.
Please confirm in writing that you will: (1) remove all content from your
website that is owned by the Bengals; (2) remove all links to bengals.com,
and (3) remove the modified Bengals logo from your site and cease all sales
of product incorporating that design. Your prompt response is required in
order to expedite a non-judicial resolution of this matter. Please confirm
your compliance with the above demand and provide the requested accounting,
in writing, by January 16, 2001, or we will be compelled to take further
NFL PROPERTIES, INC.
David M. Proper
Legal and Business Affairs