Cleveland Browns Football Company Attorneys Berwick, Pearlman & Mills
question owner or client of Internet Domain Name BrownsDogPound.com
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JAMES H. BERICK SAMUEL S. PEARLMAN OSBORNE MILLS, JR. WILLIAM M. MILLS PAUL J. SINGERMAN GARY S. DESBERG DANIEL G. BERICK EDMUND G. KAUNTZ LAURA D. NEMETH |
BERICK, PEARLMAN & MILLS 1350 EATON CENTER (216) 861-4900 E-mail: singerman@bericklaw.com |
GEORGE F. KARCH, JR. SENIOR COUNSEL CHRISTINE A. MURPHY ELLEN K. MEEHAN TERENCE L. THOMAS RAPHAEL J. OMERZA BRYAN H. FALK ALEXANDER G. BURLINGAME |
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April 13, 1999 CERTIFIED MAIL Web Site Communications Corporation Re: Cleveland Browns Football Company LLC Gentlemen: The undersigned and this office represent Cleveland Browns Football Company LLC. It has recently come to our attention that you have registered and either you or a client of yours intends to use the domain name BROWNSDOGPOUND.COM. The web site which you or your client intends to use would convey the impression that the proposed web site is related to or has been authorized or approved by the Cleveland Browns. The Cleveland Browns, over a long period of exclusive use and significant promotion, have acquired very strong rights in a number of trademarks, many of which are federally registered. The use of the Browns trademarks in connection with your proposed web site is of great concern to the Cleveland Browns. Please immediately cease and desist from any further use of the domain name BROWNSDOGPOUND.COM. We are certain you do not want to convey to members of the public the mistaken impression that you have in some way been authorized or empowered by the Browns to use its trademark or to trade off its goodwill. We feel certain that you believe in fair dealing and are desirous of avoiding any possible confusion in the mind of the public. Having brought this matter to your attention, we are certain that you will recognize the rights of the Cleveland Browns in its trademarks and will cooperate in bringing this matter to an amicable close. You should know that the Cleveland Browns have been extremely active in protecting their trademark rights, and it is not their intention to make an exception in this instance. Please advise the undersigned in writing within 30 days after your receipt of this letter of your intentions regarding the use of the domain name BROWNSDOGPOUND.COM. Sincerely,
Paul J. Singerman
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