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* Golden Globes 2014: Sandra Bullock. Emma
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* lessica Alba Is White Hot At The People's
Choice Awards
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Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 28 of 47
Top 10 | 10 Best Albums of' 13: Nick Catucci's Picks | Photo 10 of 10 | EW.com Page 4 of 4
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Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 29 of 47
joogle Play is giving away 'Yeezus' and top singles from 2013 | The Verge Page 1 of 1
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TRENDING NOW
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T-Mobile will pay you upto $3o toleave your existing carrier NEW ARTICLES
CULTURE ENTERTAINMENT GOOD DIAL
Google Hay isgiving away 'Tgezus'
and top angles frcm 2a3
By Jacob Kastrenakes (http://www.theverge.c0in/users/Jac0b%20Kastrenakes) o n December 27, 20131 0 : 4 3 a m E m a i l (mailto:j acob.kastrenakesisitheverge.com) @j ake_k
(https:/ / tMtter.com/ mtent/ user?screen_name=j ake_k)
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Watch TMobile CEO John
Legere's CES 2014 press
conference in just QBT S
minutes Google's making it easy to catch up on some of the best music of the year. As part of what
it's calling Play Picks 2013
(https://play.google.com/store/music/collection/series_overview_theme_201041b_dis_play_picks)
it's offering Kanye West's (http://www.theverge.eom/a/the-verge-50/kanye-west) Yeezus
and Chvrches' The Bones of What You Believe free for a limited time it's also giving
them the superlatives album and breakout-artist of the year, respectively. Alongside the
two albums, Google's also offering 20 singles for free, including Arcade Fire's "Reflektor,"
Drake's "Started From The Bottom," and Disclosure's "When A Fire Starts To Burn". While
they're all free, there is one small catch: you'll have to give Google your credit card
number, even though you aren't paying.
Nokia briigs foldersto
Windows Bione with its
Lumia Black rollout
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Watch allof The Verge's
CES video here p
With Play Music getting a bigger emphasis than ever
(http://www.theverge.com/2013/5/15/4333464/google-takes-o n-spotify-with-google-play-
music-all-access) this year, it's no surprise to see Google looking to attract new customers
with some of the top music around. And once you've got your credit card in the store,
Google is happy to point to plenty of other deals offered as part of Play Picks for you to buy
next. Lorde's Pure Heroine, Janelle Monde's (http://www.theverge.com/a/the-verge-
50/janelle-monae) The Electric Lady, Danny Brown's Old, and Katy Perry's Prism are
LATEST MEDIA
P layback: TMobile's CIS
2014 press conference h
just o\erfive minutes
ittp ://www.theverge.com/2013/12/27/5247628/google-play-offering-kanye-west-chrvches-new-albums-free 119/ 201 <
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 30 of 47
joogle Play is giving away 'Yeezus' and top singles from 2013 | The Verge
Spotify, now may be your be s t chance to catch up on the year's biggest hits.
Updat e: Googl e tells us that different promotions are being offered in different regions.
Cust omers should be able t o s e e what promotion is available to them at the Music on
Googl e Play homepage (https://play. google. com/store/music).
Page 2 of 1'
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RELATED ITEMS MUSIC FREE KANVEWEST DEAL GOOGLE PUY YEEZUS CHVRCHES PLAY nCKS
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22 minutes ago by Karan Deshmukh
(http^/www.theverge.conyusers/Karan%20Deshnukh)
3 comments
META (HTTP://WWW.THEVERGE.COM/FORUMS/HETA)
Ford Sync t ddngove r tKs si t e f or me
about 2 hours ago by MosqultoControl
(http://www.theverge.conVusers/MosquitoControl)
3 comments
OFF-TOPIC I CHIT-CHAT lHTrP://WVW.THEVERGE.COM/FORUMS/OFF-
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about 3 hours ago by vSpolntO
(httpJ/www.theverge.corrfusers/vSpointO) 6 comments
APPLE CORE (HTTP://WWW.THEVERGE.COM/FORUMS/APPLE-CORE)
Anti -Appl e Propaganda B ai Issue?
about 3 hours ago by Wetware.
(httpJ/www.theverge.com'users/Wetware.) 18 comments
MICRQSOFTTRIBE|HTTP://WWW.THEVERGE.COM/FORUMS/MICROSOFT-
TRIBE)
The be s t 2in-i wi ndo ws 8 devi ce f or t he price.
about 3 hours ago by harshpwd
(http^/www.theverge.comfusers/harshpwd) 1 comment
ittp://www.theverge.com/2013/12/27/5247628/google-play-^^ 1/9/201'
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 31 of 47
EXH IBIT C
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 32 of 47
Int. Q.: 9
Prior U.S. Qs.: 21, 23, 26, 36, and 38
Reg. No. 3,648,799
United States Patent and Trademark Office Registered June 30,2009
TRADEMARK
PRINCIPAL REGISTER
SSOTl f Si P
MASCOTTE H OLDINGS, INC. (CALIFORNIA
CORPORATION)
410 PARK AVE., 10TH FLOOR
C/0 PRYOR CASH MAN LLP
NEW YORK, NY 10022
FIRST USE 2-0-2004; IN COMMERCE 2-0-2004.
TH E MARK CONSISTS OF STANDARD CH AR-
ACTERS WITH OUT CLAM TO ANY PARTICULAR
FONT, STYLE, SIZE, OR COLOR.
FOR: MUSICAL SOUND RECORDINGS; AUDIO-
VISUAL RECORDINGS, NAMELY, COMPACT
DISCS, TAPE CASSETTES, AUDIO CASSETTES,
AUDIO TAPES, AUDIO DISCS, RECORDS, CD-
ROMS, VIDEO TAPES, VIDEO CASSETTES, VIDEO
DISCS, DVDS, DATS, MP3S, AND LASER DISCS,
ALL FEATURING MUSIC; DOWNLOADABLE MU-
SICAL SOUND RECORDINGS; DOWNLOADABLE
VIDEO RECORDINGS FEATURING MUSIC; SUN-
GLASSES, IN CLASS 9 (U.S. CLS. 21,23, 26, 36 AND
TH E NAME "KANYE WEST' IDENTIFIES A LIV-
ING INDIVIDUAL WH OSE CONSENT IS OF RE-
CORD.
SN 78-499,390, FILED 10-13-2004.
JOH N WILKE, EXAMINING ATTORNEY
38).
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 33 of 47
Int. CI.: 16
Prior U.S. Qs.: 2, 5,22,23,29, 37, 38, and 50
Reg. No. 3,648,800
United States Patent and Trademark Office Registered June 30,2009
TRADEMARK
PRINCIPAL REGISTER
KANlflSlST
MASCOTTE H OLDINGS, INC. (CALIFORNIA
CORPORATION)
C/O KELLOGG AND ANDELSON ACCOUNTANCY
CORPORATION, 14724 VENTURA BOULE-
VARD2ND FLOOR2ND FLOOR
SH ERMAN OAKS, CA 91403
FOR; POSTERS; PH OTOGRAPH IC PRINTS; PH O-
TOGRAPH S , I N CLASS 16 (U.S. CLS. 2,5,22,23,29,37,
38 AND 50).
FIRST USE 2-0-2004; IN COMMERCE 2-0-2004.
TH E MARK CONSISTS OF STANDARD CH AR-
ACTERS WITH OUT CLAIM TO ANY PARTICULAR
FONT, STYLE, SIZE, OR COLOR.
TH E NAME "KANYE WEST" IDENTIFIES A LIV-
ING INDIVIDUAL WH OSE CONSENT IS OF RE-
CORD.
SN 78-499,402, FILED 10-13-2004.
JOH N WILKE, EXAMINING ATTORNEY
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 34 of 47
Lit. CL: 25
Prior U.S. C3s.: 22 and 39
United States Patent and Trademark Office
Reg. No. 3,648,801
Registered June 30, 2009
TRADEMARK
PRINCIPAL REGISTER
KANYEWEST
MASCOTTE H OLDINGS, INC. (CALIFORNIA
CORPORATION)
C/O KELLOGG AND ANDELSON ACCOUNTANCY
CORPORATION, 14724 VENTURA BOULE-
VARD2ND FLOOR2ND FLOOR
SH ERMAN OAKS, CA 91403
TH E MARK CONSISTS OF STANDARD CH AR-
ACTERS WITH OUT CLAIM TO ANY PARTICULAR
FONT, STYLE, SIZE, OR COLOR.
TH E NAME "KANYE WEST" IDENTIFIES A LIV-
ING INDIVIDUAL WH OSE CONSENT IS OF RE-
CORD.
FOR; CLOTH ING, NAMELY, T-SH IRTS, TANK
TOPS, SWEAT SH ORTS, IN CLASS 25 (U.S. CLS. 22
AND 39).
FIRST USE 2-0-2004; IN COMMERCE 2-0-2004.
SN 78-499,409, FILED 10-13-2004.
JOH N WILKE, EXAMINING ATTORNEY
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 35 of 47
Int CI.: 26
Prior U.S. Os.: 37, 39, 40,42, and 50
Reg. No. 3,648,802
United States Patent and Trademark Office Registered June 30,2009
TRADEMARK
PRINCIPAL REGISTER
Ml r a Wi W
MASCOTTE H OLDINGS, INC. (CALIFORNIA
CORPORATION)
C/O KELLOGG AND ANDELSON ACCT. CORP.
14724 VENTURA BOULEVARD, 2ND FLOOR
SH ERMAN OAJKS, CA 91403
TH E MARK CONSISTS OF STANDARD CH AR-
ACTERS 'WITH OUT CLAIM TO ANY PARTICULAR
FONT, STYLE, SIZE, OR COLOR.
TH E NAME "KANYE WEST" IDENTIFIES A LIV-
ING INDIVIDUAL WH OSE CONSENT IS OF RE-
CORD.
FOR; ORNAIvIENTAL NOVELTY BUTTONS, IN
CLASS 26 (U.S. CLS. 37, 39,40,42 AND 50). SN 78-499,411, FILED 10-13-2004.
JOH N WILKE, EXAMINING ATTORNEY
FIRST USE 4-16-2008; IN COMMERCE 4-16-2008.
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 36 of 47
Int. Q.: 35
Prior U.S. Cls.: 100,101, and 102
United States Patent and Trademark Office
Reg. No. 3,648,803
Registered June 30, 2009
SERVICE MARK
PRINCIPAL REGISTER
TCSv a f - j ui :
MASCOTTE H OLDINGS, INC. (CALIFORNIA
CORPORATION)
C/O KELLOGG AND ANDELSON ACCT. CORP.
14724 VENTURA BOULEVARD, 2ND FLOOR
SH ERMAN OAKS, CA 91403
FOR; ON-LINE ORDERING SERVICES AND ON-
LINE RETAIL STORE SERVICES, ELECTRONIC
RETAILING SERVICES VIA COMPUTERS, AND
RETAIL STORE SERVICES AVAILABLE TH ROUGH
COMPUTER COMMUNICATIONS, ALL OF TH E
AFORESAID FEATURING RECORDED PRODUCT,
MUSIC RELATED ITEMS, CLOTH ING AND AC-
CESSORIES TH EREFOR, PRINTED PROMOTION-
AL MATTER SUCH AS POSTERS, BOOKS AND
PUBLICATIONS, NOVELTY ITEMS AND ORNA-
MENTS, IN CLASS 35 (U.S. CLS. 100,101 AND 102).
FIRST USE 2-0-2004; IN COMMERCE 2-0-2004.
TH E MARK CONSISTS OF STANDARD CH AR-
ACTERS WITH OUT CLAIM TO ANY PARTICULAR
FONT, STYLE, SIZE, OR COLOR.
TH E NAME "KANYE WEST" IDENTIFIES A LIV-
ING INDIVIDUAL WH OSE CONSENT IS OF RE-
CORD.
SN 78-499,413, FILED 10-13-2004.
JOH N WUJKE, EXAMINING ATTORNEY
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 37 of 47
Int. CI.: 41
Prior U.S. Os.: 100,101, and 107
Reg. No. 3,648,804
United States Patent and Trademark Office Registered June 30,2009
SERVICE MARK
PRINCIPAL REGISTER
i Pf f f EWBi f '
MASCOTTE H OLDINGS, INC. (CALIFORNIA
CORPORATION)
C/O KELLOGG & ANDELSON ACCOUNTANCY
CORP.
14724 VENTURA BOULEVARD, 2ND FLOOR
SH ERMAN OAJCS, CA 91403
CAL VIDEOS, PH OTOGRAPH S, AND OTH ER MUL-
TIMEDIA MATERIALS; ENTERTAINMENT
SERVICES, NAMELY, PROVIDING PRERECOR-
DED MUSIC, ALL ONLINE VIA A GLOBAL COM-
PUTER NETWORK; ENTERTAINMENT IN TH E
NATURE OF TRAVELING TOURS FEATURING
MUSIC, IN CLASS 41 (U.S. CLS. 100, 101 AND 107).
FOR: MUSIC COMPOSITION AND TRANSCRIP-
TtON FOR OTH ERS; ENTERTAINMENT IN TH E
NATURE OF A LIVE MUSICAL PERFORMER,
MUSICAL BAND OR MUSICAL GROUP; ENTER-
TAINMENT I N TH E NATURE OF LIVE PERFOR-
MANCES BY A MUSICAL ARTIST, MUSICAL
GROUP OR MUSICAL BAND; ENTERTAINMENT
IN TH E NATURE OF VISUAL AND AUDIO PER-
FORMANCES BY A MUSICAL ARTIST, MUSICAL
GROUP AND MUSICAL BAND; ENTERTAIN-
MENT, NAMELY, LIVE MUSIC CONCERTS; EN-
TERTAI NMENT, NAMELY, PERSONAL
APPEARANCES BY A MUSICIAN, MUSICAL
GROUP OR MUSICAL BAND; ENTERTAINMENT
SERVICES, NAMELY, PROVIDING A WEB SITE
FEATURING MUSICAL PERFORMANCES, MUSI-
FIRST USE 8-0-2004; IN COMMERCE 8-0-2004.
TH E MARK CONSISTS OF STANDARD CH AR-
ACTERS WITH OUT CLAIM TO ANY PARTICULAR
FONT, STYLE, SIZE, OR COLOR.
TH E NAME "KANYE WEST' IDENTIFIES A LIV-
ING INDIVIDUAL WH OSE CONSENT IS OF RE-
CORD.
SN 78-499,414, FILED 10-13-2004.
JOH N WILKE, EXAMINING ATTORNEY
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 38 of 47
EXH IBIT D
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 39 of 47
Kjarberg^^an^S.
REDACTED
From: Matthew Mellon <777menon@,gmail.com<mailto:777mellon@.grnail.com>>
Date: January 5, 2014 at 9:09:13 PM EST
To: Michael Guido <mgmdo@ccgglaw.com<mailto:mgiiido@ccgglaw.com>>
Subject: Fwd: Kanye West Legal council Michael Guido
Forwarded message
From: Coinye West <coinvewest@gmail.com<mailto:coinvewest@gmail.com>>
Date: Sat, Jan 4, 2014 at 6:54 PM
Subject: Re: Kanye "West Legal council Michael Guido
To: Matthew Mellon <777meUon@gmail.com<mailto:777rnel1nn@gTn3i1.cnrn>>
i
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 40 of 47
I dont know. I don't want to inconvenience him. A simple few second video of him telling us he
wants coinyes would suffice, but i understand you might be concerned about that hitting the
media. As I'm well aware you guys are going to try and get my identity I'm not comfortable with
a phone call, and skype would be too slow through the proxies i use.
I'm totally willing to discuss things with you guys. In email, or on IRC which is internet relay
chat. I can give, you the step by step to get connected if you dont have access to a geek when its
time to talk. It's just that before we actually risk ruining the currency by "printing" a crapload of
it to give to kanye, I'm going to need some kind of proof its actually going to him, by getting
some sort of verification from the man himself.
Thank you
On 1/4/2014 4:39 PM, Matthew Mellon wrote:
How would like to Kanye to confirm that?
On Sat, Jan 4,2014 at 6:35 PM, Coinye West
<coinvewest@,gmail.com<mailto:coinvewest@,smail.com>> wrote:
I didn't say yes. Someone else with access to this email said yes. I'm not talking on any telephone
and neither is anyone else involved.
If you want to talk, contact me in email. We're anonymous and we're keeping it that way.
Also, I'm not giving up a single millionth of a percent until i get some kind of verification that
kanye actually knows a deal is being made. I still don't trust you, and I sure as hell don't trust
lawyers.
On 1/4/2014 4:16 PM, Matthew Mellon wrote:
I am happy to talk prior to 10:00am.. Let me know I can give you the lay of the land..
+19174599067<tel:
<
yo2B19174599067>
On Sat, Jan 4,2014 at 6:03 PM, Coinye West
<coinvewest@gmail.com<mailto:coinvewest@gmail.com wrote:
Yes.
On Sat, Jan 4, 2014 at 3:00 PM, Matthew Mellon
<777mellon@gmaiLcom<mailto:777mellon@gmail.com wrote:
I am happy to speak then.. Coinye shall I patch you in?
On Sat, Jan 4, 2014 at 3:38 AM, Michael Guido
<mmiido@,ccgglaw.com<mailto:mguido@.ccgglaw.com>> wrote:
Ok. As you know I am 10 hours ahead of NY. And boarding a plane now. I will be free at
2
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 41 of 47
about 10 am my time tomorrow which will be about 11:30pm my time Saturday evening. Is that
something that can work?
On Jan 4,2014, at 1:15 PM, "Matthew Mellon"
<Matthew@coinapex.com<mailto:Matthew@coinapex.com>> wrote:
Hi Michael:
Coinye has requested to speak to you directly being Kanye West's legal council.
Best,
Matthew
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Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 42 of 47
"CONFIDENTIAL"
Information Classification: Confidential
The information contained in this e-mail, and any attachment, is confidential and is intended
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Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 43 of 47
EXHIBIT E
Case 1:14-cv-00250-AT Document 1-1 Filed 01/14/14 Page 44 of 47
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M PRYOR CASHMAN LLP New York J Los Angeles
WW.piyorcashmkLCOm 7 Times Square, New York, NY 10036-< 5569 Tel: 212-4214100 Fax:212-326-0806
Brad D. Rose
P artner
Direct Tei;2l2-326-0?75
Direct Fsoc 212-79S-6369
bfose@ptj
,
orcashtn an.com
January 6, 2014
VIA E-MAIL fcoin vewestfcdamail. com]
Re: Infringement of KAYNE WEST Mark and Other Violations
Dear Sir or Madam:
This law firm acts as litigation counsel for Kanye West and his affiliated companies. As
' > film
director and fashion designer, to name just a few of Mn West's endeavors. Mr. West has won
twenty-one Grammy Awards, making him one of the most awarded artists of all-time. He has
been named one of the 100 most influential people by Time magazine and is routinely listed by
Forbes as one of the most successful people in the world.
Mr. West's tremendous success and notoriety has catapulted the KANYE WEST brand
into a commercial asset of incalculable value. In addition to his common law rights, Mr. West
and services as well as several pending applications. See, e.g., U.S. Reg. Nos. 3,648,799;
3,648,800; 3,648,801; 3,648,802; 3,648,803; and 3,648,804. Without doubt, the KANYE WEST
mark is famous and is entitled the broadest protection under the law.
We write to you concerning your unauthorized use of the COINYE WEST mark in
connection with a purported cryptocurrency that may be available on January 11, 2014. We have
recently learned that you are promoting the COINYE WEST cryptocurrency through the
<coinvewest.com> website, on Facebook at <facebook.com/coinvewest> and on Twitter at
<twitter.com/CoihveWest>. The COINYE WEST mark is substantially similar to the KANYE
WEST mark in sight, sound, meaning and commercial impression. Interviews with the founders
of the COINYE WEST cryptocurrency leave no doubt that your clear intent is to trade upon the
goodwill associated with die KANYE WEST mark and Mr. West's international fame and
notoriety. In particular, several news sources have quoted the developers as stating "We chose
Kanye because of his trendsetting abilities and his originality," and also that you have decided to
remain anonymous "in case Kanye gets pissed off." Such statements support a Ending that your
infrmgement is blatant and willful.
Given Mr. West's wide-ranging entrepreneurial accomplishments, consumers are likely
to mistakenly believe that Mr. West is the source of your services or is, at the very least,
affiliated with, or has sponsored or endorsed the cryptocurrency. The likelihood that consumers
will be confused is heightened by the unauthorized use of an image of Mr. West on the coin:
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% PRYOR CASHMAN LLP
January 6,2014
Page 2 of 3
MM
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Your actions constitute, zrer alia, willful trademark infringement, unfair competition,
infnngement.
misappropriation of Mr. West's music videos embedded in the <coinyewest.com> website.
Your actions also violate Mr. West's right of publicity under state law, which subjects you to
further liability.
Mr. West takes these violations of his intellectual property very seriously and seeks to
resolve: this matter without resort to litigation including filing an. application for a temporary
restraining order. Accordingly, please immediately confirm that you and all of your affiliated
companies, employees, consultants, agents and representatives will immediately:
versions of that mark including COINYE;
2. cease and desist from any and all development, sale, distribution and
promotion of any and all products and services in connection with the mark
KAIsfYE WEST, or any names or marks confusingly similar to KANYE
WEST, including, but not limited to, the COINYE WEST and COINYE
marks;
3. cease and desist from any and all use of Mr. West's copyrighted material
including his music videos;
4. deactivate the website located at <coiiivewest.com>> unlock the domain
name to allow it to be transferred and provide us with the authorization
code to facilitate such transfer;
5. deactivate all social media accounts created and/or used in connection with
the COINYE WEST mark, including, but not limited to, the Facebook
account located at <facebook.com/coinvewest> and the Twitter account
located at <twitter. com/CoinveWest>: and
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HPRYOR CASHMAN LLP
January 6,. 2014
Page 3 of 3
6.
IT.,
product or service.
p.m. E.S.T. on January 6. 2014, your intent to comply prpinptly with our demands, failing
4 * ^.1 |Y ... ^ j i.r: i|..' ; . ' . . it "i * !' -J! - ii* J*-'- >17'
including treble damages, attorney's fees and costs.
large of your infringing actions and pursue all legal remedies against any business that accepts the
purported COINYE WEST currency. Specifically, Mr, West will pursue claims of contributory
trademark infringement and contributory unfair competition, among others, against any entity that
accepts or exchanges the COINYE WEST currency.
Should you wish to discuss any aspect of this matter, we suggest that you have your legal
representative contact the undersigned before the above-referenced deadline.
The foregoing is not intended as a comprehensive statement of our client's rights or position,
and nothing herein shall be deemed to be a waiver of any of our client's rights at law or in equity.
Very truly yours,
Brad D, Rose
cc: Michael Guido, Esq.
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