so, we have to find something to do with our lives now... we have no
jobs
-silicon
my first cease and decist
June 18, 2001
VIA E-MAIL
transmission
RE: Notice of Infringement
Dear Project Administrator:
We represent America Online, Inc. (“AOL”), with respect to
its intellectual property matters. Our client is the owner
of federal Registration Nos. 2,423,368 and 2,423,367 for
its mark AIM (hereinafter, the “AIM Mark”) and operates the
most widely-used interactive online service in the world.
Our client has made extensive use of its AIM Mark in
interstate and international commerce in connection with
the advertising, promotion, and sale of its Internet and
computer-related goods and services. Due to our client’s
widespread use, advertising, and extensive marketing, its
AIM Mark has become very famous and many consumers
recognize the mark as a distinctive symbol of our client’s
goodwill.
Our client also uses the mark AIM.COM in connection with
providing information via computer networks. As a result,
consumers associate the mark AIM, when used in a software
name or internet related service, with our client’s high
quality products and services.
It has come to our attention that you are distributing an
online communication software product using the AIM Mark at
several web sites. Our client is concerned that your
unauthorized use of its famous AIM Mark in this manner is
likely to confuse consumers and, in addition, dilutes the
distinctive qualities of the AIM Mark. We assume you
similarly do not wish to mislead consumers and we request
that you discontinue use of any name(s) that incorporate
our client's marks, or marks confusingly similar to them.
Additionally, the proprietary software used to operate the
AIM service is owned solely by AOL and unauthorized
distribution of our client's software, or derivatives
thereof, is strictly prohibited. Our client would like to
resolve this matter amicably and has asked that we contact
you to confirm that you will cease using any names or marks
that infringe upon the AIM Mark. We also ask that you
contact us to discuss the possible copyright issues set
forth above. We hope you appreciate AOL's interest in
protecting its valuable intellectual property and we ask
that you respond to this letter by June 29, 2001. We look
forward to hearing from you and hope to resolve this matter
promptly.
James R. Davis, II
202/857-6169
davisr@arentfox.com
Arent Fox Kintner Plotkin & Kahn, PLLC
1050 Connecticut Avenue, NW
Washington, DC 20036-5339
Phone 202/857-6000
Fax 202/857-6395
www.arentfox.com
cc: Douglas R. Bush, Esq.
Fabricio Vayra, Esq.