Law Offices Stokes Lawrence, P.S. 800 fifth avenue suite 4000 Seattle Washington 98104-3179 ------------- Telephone: (206) 626-6000 Facsimile: (206) 464-1496 Email: [email protected]
October 17, 2000
VIA CERTIFIED MAIL/ RETURN RECEIPT REQUESTED
John Arbon The Liberty Belle Group 4207 East Balsam Avenue Mesa, AZ 85206 Re: <cphv.com>
Dear Mr. Arbon:
We represent Handgun Control, Inc. ("HCI")/Center
to Prevent Handgun Violence ("CPHV"). The records of
Due to the obvious similarity of the <cphv.com>
domain name to our client’s marks, consumers are very likely to
be As you may be aware, there are new laws and procedures
in place to protect a service mark owner from infringement through domain
name use. The Anticybersquatting
Consumer Protection Act of 1999, Pub. L. No. 106-133 (the "ACPA"),
provides for injunctive relief and statutory damages for infringing
domain name registrations and use. Additionally, the Internet Corporation for Assigned Names
and Numbers has recently adopted the Uniform Domain Name Dispute Resolution
Policy (the "UDRP").
The UDRP permits a service mark owner to invoke an administrative
proceeding to compel the transfer of an infringing domain name. Should HCI/CPHV be forced to bring claims against
The Liberty Belle Group under section 43(a) of the Lanham Act, If The Liberty Belle Group does not cease using
the <cphv.com> domain name and immediately agree to transfer it
to its rightful owner, HCI/CPHV is prepared to pursue all remedies at
law and equity to protect its marks.
If we do not
Very truly yours, Stokes Lawrence, P.S. Alison F. Ivey
cc: Bruce Gryiewski, Washington Ceasefire Rachana Bhowmik, Handgun Control, Inc./Center to Prevent Handgun Violence |