X69
Aug 2001
Administrator
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07-29-2003 Cease and Desist Letters
If anyone is a lawyer or knows a lawyer who would be interested in giving me legal advice please contact me ASAP. [email protected] Thanks
Letter #1
quote:
Re: Copyright Infringement at http://www.vcdquality.com
Dear Sir or Madam:
This letter is being written to you on behalf of Paramount Pictures Corporation (hereinafter "Paramount"). Paramount is the owner of rights in and to the "Lara Croft Tomb Raider: Cradle of Life" motion picture ("Tomb Raider 2 Motion Picture").
Paramount has recently discovered that you are hosting a web site with the Uniform Resource Locator address http://www.vcdquality.com ("Infringing Web Site") that is unlawfully reproducing and displaying unauthorized copies of Tomb Raider 2 Motion Picture. For instance, as of the date of this letter, unauthorized copies are displayed at the following jump sites:
http://www.vcdquality.com/info.php?id=16662
http://www.vcdquality.com/image.php?id=16662
http://www.vcdquality.com/nfo.php?id=16662
http://www.vcdquality.com/info.php?id=16581
http://www.vcdquality.com/image.php?id=16581
http://www.vcdquality.com/nfo.php?id=16581
http://www.vcdquality.com/info.php?id=16571
http://www.vcdquality.com/nfo.php?id=16571
The above jump sites are not an exhaustive list and represent only a small sampling of where unauthorized copies of Paramount's motion pictures are displayed on the Infringing Web Site hosted by X69.net.
Paramount has not granted X69.net, the listed owner of the Infringing Web Site, any right, title or license in the Tomb Raider 2 Motion Picture. Accordingly, the reproduction and display of the Tomb Raider 2 Motion Picture is wrongful and actionable misconduct in violation of Paramount's exclusive copyrights, and therefore constitutes, among other things, willful copyright infringement pursuant to 17 U.S.C ยง 501.
We, the undersigned, certify under penalty of perjury that we are an agent authorized to act on behalf of the owner of certain intellectual property rights, said owner being named Paramount. We have a good faith belief that the materials identified are not authorized by the Paramount, its agent, or the law and therefore infringe Paramount's rights.
In light of the above, Paramount hereby demands that X69.net immediately take down and/or block access to the Infringing Web Site located at http://www.vcdquality.com and all related jump sites/links where the Tomb Raider 2 Motion Picture are being reproduced and displayed.
If you have any questions regarding this matter, please contact me at the e-mail, telephone number or address set forth above.
Thank you for your anticipated cooperation in stopping the outrageous copyright infringement being carried out on a web site hosted by X69.net.
Finally, nothing contained in this letter is intended as, or may be deemed or construed to constitute, a waiver or relinquishment of any of Paramount's rights and remedies under the circumstances, all of which are hereby expressly reserved.
Very truly yours,
/s/
Dennis L. Wilson
Keats McFarland & Wilson LLP
cc: Paramount Pictures Corporation
I, ___________________________, hereby acknowledge that I have ceased offering and/or distributing unauthorized copies of the Paramount Motion Picture Properties and any other goods which infringe Paramount's rights in any of its motion picture properties; and have complied with (1)-(3) above.
_____________________________
Signature
_____________________________
Print Name
_____________________________
Date
Letter #2
quote:
RE: YOUR INFRINGEMENT OF PARAMOUNT PICTURES CORPORATION RIGHTS
Dear Sir or Madam:
This letter is being written to you on behalf of Paramount Pictures Corporation (hereinafter "Paramount"). Paramount is the owner of rights in and to the motion picture "Lara Croft Tomb Raider: Cradle of Life" ("Tomb Raider 2 Motion Picture"), and other numerous motion pictures, hereinafter collectively referred to as the "Paramount Motion Picture Properties".
Paramount has recently learned that you are offering and/or distributing unauthorized copies of Paramount Motion Picture Properties through your web site located at "http://www.vcdquality.com." You are hereby put on notice that the reproduction, transmission and/or distribution by you of unauthorized copies of the Paramount Motion Picture Properties constitutes copyright infringement.
Paramount hereby demands that you and all those who have acted in concert with you immediately cease any unauthorized copying, transmission, distribution and/or other utilization of any of its protected intellectual property, including any use of the Paramount Motion Picture Properties.
In addition to the foregoing, we request that you:
(1) voluntarily relinquish your unauthorized copies of the Paramount Motion Picture Properties to the undersigned at the address listed at the top of this letter;
(2) provide all information pertaining to the source from which you obtained your unauthorized copies of the Paramount Motion Picture Properties, including the source's name, address, phone number, web site address and e-mail address; and
(3) provide all information pertaining to any unauthorized copying, transmission, distribution and/or other utilization of the Paramount Motion Picture Properties, including source's name, address, phone number and e-mail address.
Should you not immediately do so, Paramount expressly reserves all of its rights to file a lawsuit against you to obtain damages for all past acts of infringement and an injunction to prevent any future infringement.
Please sign this letter in the space provided below, and return it with the above-requested materials to the undersigned before the close of business on August 4, 2003. If we do not receive your written confirmation before that date, we will be forced to recommend that Paramount immediately take further legal action.
This letter is not a complete statement of Paramount's rights in connection with this matter, and nothing contained herein constitutes an express or implied waiver of any rights, remedies, or defenses of Paramount in connection with this matter, all of which are expressly reserved.
Very truly yours,
/s/
Dennis L. Wilson
Keats McFarland & Wilson LLP
cc: Paramount Pictures Corporation
I, ___________________________, hereby acknowledge that I have ceased offering and/or distributing unauthorized copies of the Paramount Motion Picture Properties and any other goods which infringe Paramount's rights in any of its motion picture properties; and have complied with (1)-(3) above.
_____________________________
Signature
_____________________________
Print Name
_____________________________
Date
Last edited by X69 on 07-31-2003 at 01:38 AM
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07-30-2003 01:13 PM
