KeatsGatien LLP Anthony M. Keats, Partner Emaii: tony@keatsgatien.com wow, kealsgatien.com June 29, 2017 President Kendall + Kylie 101 Japanese Village Plaza Los Angeles, CA 90012 Re: Kendall + Kylie: Dear Sir or Madam: -famous rock-and- and the estate of Ray Wners of the copyrights, trademarks, rights of publicity (including without limi jghts in and to the names, signatures, photographs, likenesses and iden “ of The Doors) and all intellectual property with the band and its 1 fer, the “Protected Property”), ommon law. The Doors are also ts of which they have retained and which are protected by federal law, state the owners of copyrights in numerous p enforce, @ by the Lanham Act 15 U.S.C. § 1114 In particular, th i trademark; 15 U.S.C. § 1125(a) regarding False et seq. regarding inf et seq.; Californi and Professions of publicity ar ; State statutory right statutory unfair competit ition law. f publicity; California Business and state common law rights s of U.S. trademark registrations for the mark THE DOORS \dard word mark format for t-shirts among other apparel items, aghied). Your use of the registered trademarks in commerce is likely to cause confusion, mistake, or to deceive consumers into believing that the Kendall + Kylie apparel was authorized by The Doors when no such authorization was sought or provided by The Doors. ‘The sale of the infringing apparel bearing the registered trademark of The Doors is likely to cause confusion, mistake, or to deceive consumers into believing that Kendall + Kylie is affiliated, connected, or associated with The Doors or that the apparel has been approved ofKendall + Kylie June 29, 2017 Page 2 or sponsored or originates with The Doors. The sale of the t-shirts was simply an act of unfair competition under both the federal Lanham Act as well as California's Busines Professions Code § 17200. Ata minimum, the gross unauthorized use of the famous THE DOOR: likely to cause dilution by tarnishment of the famous mark as such use in ¢o1 Kendall Jenner selfie harms the reputation of The Doors, particularly at fans of The Doors. This damage was already cognizable in the blog Kendall + Kylie product now found on social media, In addition to trademark infringement and unfail Mortison’s post-mortem right of publicity. ‘The supg over the iconic “Lion” portrait of the late Jim Morr d failure to recognize the rights of the estate of Mr. Mot the use of his likeness. of Kendall Jenner You are hereby put on notice that the and distribution of the Protected Property to p to purchase your commercial products cop ess and to induce consumers of the above-referenced rights. Doors and any third parties rotected Property to advertise, desist from manufacturing, advertising, and selling the id that you confirm by telephone or e-mail within twenty- ‘you complied with this demand. onfirm in writing within seven (7) days that you have immediately and jnently removed any reference to the Protected Property from your websites, are locations, if any, and any other marketing or promotional materials, brochures, catalogs, headings, search functions, ad words and product descriptions; 3. Identify all advertising materials on which the Protected Property has appeared; 4, Provide a full accounting of all proceeds received from the sale of goods in connection with your unauthorized use of the Protected Property; and, 5. Immediately recall all of the apparel bearing the Protected Property from all distributors, wholesalers, and retail outlets.Kendall + Kylie June 29, 2017 Page 3 Please immediately confirm that you have ceased your unauthorized reproduction, advertisement, use and distribution of the Protected Property. If we do not receive the requested immediate confirmation before July 1, 2017, we will recommend that our client consider taking further take legal action against you. This letter is not a complete statement of The Doors’ rights in connection with ‘matter, and nothing contained herein constitutes an express or implied waiver of a reserved. AMK:dvom EnclosuresTrademark Electronic Search System (TESS) Page I of 2 ® United States Patent and Trademark Office Home|Site Index| Search| FAQ| Glossary | Guides| Contacts| eBusiness | eBiz alerts|News|Help Trademarks > Trademark Electronic Search System (TESS) TESS was last updated on Thu Jun 29 05:00:48 EDT 2017 Ce ee eo oo Logout | Please logout when you are done to release system resource: Sian Jtist at Jor| Jump |torecora:[ Recor f 364 SEE EE e Internet Browser to return to TESS) Akg Goods and —_IC.009, us| Services & S: Musical sound recordings; Musical video recordings. ISE IN COMMERCE: 19670100 2.28 029 037 038 050. G & S: Posters; Calendars. FIRST USE: ‘COMMERCE: 19680000 9G & S: T-shirts; Hats. FIRST USE: 19680000. FIRST USE IN COMMERCE: 'S, AND/OR NUMBERS IN STYLIZED FORM Circle figures or designs including semi MISC Miscellaneous shaped designs code SHAPES. TRIANGLES Triangular shaped designs and marks including incomplete triangles 77236528 Filing Date July 23, 2007 Current Basis. 1A inal Filing Basis uw roles and incomplete circles January 8, 2008 Registration Neos 3401460 March 25, 2008 hitp://tmsearch.uspto. gov/bin/showfield?f=doc&state=4809 jSav9p.2.304 6/29/2017‘Trademark Electronic Search System (TESS) Page 2 of 2 Date Owner (REGISTRANT) The Doors John Densmore, a U.S. citizen; Robby Krieger, a U.S. citizen; Ray Manzarek, a U.S. citizen; the Estate of James Morrison, a California estate; and the Estate of Pamela Courson, a California estate PARTNERSHIP CALIFORNIA 8899 Beverly Blvd. Los Angeles CALIFORNIA 90048 Attorney of sore ‘Amthony M. Keats Prior Registrations 2412706:2576987 Description of Coioris not claimed as a feature of the mark, The mark consists of the stylized words| Mark Doors, Type of Mark TRADEMARK Register PRINCIPAL Affidavit Text SECT 15. SECT 8 (6-YR). LiveDead tye Indicator http://tmsearch.uspto. gov/bin/showfield?f=doc&state=4809 jSav9p.2.304 6/29/2017Trademark Electronic Search System (TESS) Page | of 2 ® United States Patent and Trademark Office Home| site index |Search] FAQ| Glossary | Guides | Contacts |eBusinass |=ie alerts|Naws [Help Trademarks > Trademark Electronic Search System (TESS) TESS was last updated on Thu Jun 29 05:00:48 EDT 2017 [Logout | Please logout when you are done to release system resources all [Stan Juice ae EE ET (0 tho return to TESS) Typed Drawing Word Mark THE DOORS Goods and _1C.025. US 022 039. G & S: Clothing, nat Services 19890900. FIRST USE IN COMME| Mark Drawing (1) rypcD DRAWING 9 Serial Number 75632268 Filing Date February 1, 199: Current Basis 1A Original Filing Basis Published for Internet Browser to 5. T-shirts and hats. FIRST USE , The the Estate of James Morrison, a California estate; John Densmore, a Krieger, a U.S. citizen; Ray Manzarek, a U.S. citizen; and the Estate of Pamela ia estate. PARTNERSHIP CALIFORNIA Penny Lambert Ziffren, Brittenham, & Fischer 1801 Century Park West Los Angeles CALIFORNIA 900676406 paorrey OF ANTHONY M. KEATS Type of Mark TRADEMARK Register PRINCIPAL Affidavit Text SECT 15. SECT 8 (6-YR). SECTION 8(10-YR) 20120611 Renewal 1ST RENEWAL 20120011 LivelDead Indicator a hitp://tmsearch.uspto. gov/bin/showfield?f=doc&state=4809;jSav9p.2.341 6/29/2017‘Trademark Electronic Search System (TESS) Page 2 of 2 Sr on SS Sr Se | OME | SITEINDEX| SEARCH | «BUSINESS | HELP | PRIVACY POLICY os hitp://tmscarch.uspto.gov/bin/showfield?f=doc&state=4809;j5av9p.2.341 6/29/2017