June 10, 2014
BY U.S. MAIL AND EMAIL
Regisrant of http://www.kevynorr.com
c/o Domains by Proxy LLC
14747 N. Northsight Blvd.,
Suite 111, PNB 309
Scottsdale, Arizona 85260
Re: Unauthorized Use of Jones Day Service Mark
I write to you on behalf of Jones Day, a law firm with over 2500 lawyers on five continents, regarding your unauthorized use of Jones Day’s service mark on the website http://www.kevynorr.com including the statement that “Detroit’s economic coup d’etat has been brought to you by Jones Day”. Be advised that such use of Jones Day is an authorized and infringing use of Jones Day’s registered service marks. Jones Days has the exclusive rights to the service marks JONES DAYS and JONES DAYS and Design, including the rights registered in United States Service Mark Registration Nos. 2, 212, 877 and 2,316,539, copies of which are enclosed herewith.
These rights are valid, incontestable, and have not been granted to you to use in any manner whatsoever. Continued unauthorized use of these marks constitutes, at a minimum, service mark infringement, service mark dulution, and false description in violation of 15 U.S.C. 1051 et seq. and state law. To the extent that you claim that your use of Jones Day is “fair use” under the Copyright Act, please be advised that 17 U.S.C. 17 has no bearing or application to service mark infringement and false deception under the Lanham Act, 15 U.S.C. 1051 et seq.
Accordingly, we demand that you: (1) immediately remove Jones Day from kevynorr.com; and (2) refrain from any and all use of Jones Day or any mark confusingly similar thereto. Morever, we demand that you provide us wuth a written statement of your satisfaction of the firegoing demands within three days of the date of this letter. If you continue your improper conduct, Jones Day will avail itself of all legal and equitable remedies available, including the commencement of litigation without further notice. Your conduct will be closely monitored. You may contact the undersigned if you require any additional information.
Very Truly Yours,