TRADEMARK CEASE AND DESIST – DOMAIN/WEBSITE
To: [Registrant/Host/Email]
From: [Law Firm/Owner]
Date: [DATE]
Re: Unauthorized Use of [MARK] at [DOMAIN]
BACKGROUND
- Owner: [MARK OWNER].
- Mark(s): [MARK], Reg. No(s). [###], first use [DATE], covering [goods/services].
- Domain: [DOMAIN]; Registrar [REGISTRAR]; Whois info [if available].
- Use: [Describe use on site—title tags, logo use, meta tags, PPC ads, counterfeit goods].
- Goodwill: [OWNER] has invested substantial resources in building goodwill in the [MARK] mark since [DATE]; consumers associate [MARK] exclusively with [OWNER’s] goods/services.
LEGAL BASIS
- Trademark infringement under 15 U.S.C. § 1114 (registered marks) and § 1125(a) (likelihood of confusion), including initial interest confusion.
- Cybersquatting under the Anticybersquatting Consumer Protection Act, 15 U.S.C. § 1125(d) (ACPA).
- Violation of ICANN’s UDRP: the domain is identical/confusingly similar to [MARK], Registrant lacks legitimate interest, and bad faith registration/use is evidenced by [parking/ads/offer to sell/pattern of registrations/targeting customers].
DEMANDS
1) Cease all use of [MARK] or confusingly similar marks on the website, metadata, ads, and domains.
2) Transfer the domain [DOMAIN] to [OWNER] (offer cost reimbursement for transfer fee if desired).
3) Remove infringing content (screenshots/sections listed) and related social handles.
4) Provide written confirmation by [DATE] of compliance and agreement not to resume.
RESERVATION OF RIGHTS
- Owner reserves all rights, including UDRP/URS complaint, registrar/host takedown, injunctive relief, damages, and attorneys’ fees where available.
RESPONSE
- Send written confirmation to [CONTACT/EMAIL] by [DATE]. Absence of compliance may result in immediate pursuit of UDRP/URS and litigation. If you acquired this domain in good faith and are willing to transfer promptly, we are prepared to resolve this without further action.
ATTACHMENTS
- Exhibit A: Screenshots of [DOMAIN] (captured [DATE]).
- Exhibit B: Trademark registration certificate(s).
- Exhibit C: Whois records.