10/28/2015

VIA CERTIFIED REDDIT

MR. MALVECINO

[666] The DevilDogs

128 Zurvan Way

Zurvan Amp Station, Indar, 1337

Dear Mr. Malvecino:

This law firm represents Enquirer Publications, (“The Connery Enquirer”) in connection with its intellectual property rights. Your use of The Connery Enquirer is a violation of Enquirer Publication’s common law trademark rights, common law service mark rights, and trade name rights, and this letter constitutes Enquirer Publication’s demand that you cease and desist any and all use of these domain names. You should immediately forward this letter to your attorney.

Enquirer Publications is a family owned business offering satire and snarky wisecracks to consumers in r/Connery, r/Planetside, and throughout the interwebs. Enquirer Publications was registered as an Auraxian Corporation in February 2015 and has continually used “The Connery Enquirer” (the “Marks”) throughout Auraxis as its brand name since that time. Since its incorporation, Enquirer Publications has continually used the Marks in advertising campaigns and in the community, including through reddit. In addition, Enquirer Publications has been actively involved in the community in its efforts to further promote its brand including its sponsorship of various events, such as Connery Fight Night.. As a result of these efforts, Enquirer Publications’ customers, and the general public, have come to recognize Enquirer Publications as an established and shitposting business.

Recently, Enquirer Publications became aware of your use of the Connery Enquirer, which redirects visitors to your website. Under Auraxian law, common law trademark infringement occurs when a party utilizes a trade or service mark that creates a likelihood of consumer confusion. As you are undoubtedly aware, your domain names are exactly the same as Enquirer Publication’s Marks.

In just 1 day, Enquirer Publications has received a number of reports of actual consumer confusion. This presumably represents a small portion of consumers who are confused but never take the time to find another way to contact Enquirer Publications and report the confusion caused by your use of these domain names.

Enquirer Publications has several options under Auraxian law to enforce its legal rights in the Marks. If Enquirer Publications were to file a lawsuit against you, it would be entitled to seek: (1) preliminary and permanent injunctions; (2) actual monetary damages; (3) disgorging of any profits you have realized through your use of the Marks; (4) reimbursement of attorney’s fees required to prosecute a lawsuit against you; and (5) monetary damages for damage to Enquirer Publication’s goodwill in the market.

If you or your attorney have any questions, please feel free to contact me.

Sincerely,