TRADEMARK CEASE AND DESIST - DOMAIN/WEBSITE (DELAWARE)

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 and services.

LEGAL BASIS

• Trademark infringement under the Lanham Act, 15 U.S.C. 1114 (registered marks) and 15 U.S.C. 1125(a) (likelihood of confusion), including initial interest confusion.
• Cybersquatting under the Anticybersquatting Consumer Protection Act, 15 U.S.C. 1125(d).
• Delaware unfair competition and trademark law, including Del. Code Ann. tit. 6, Section 3301 et seq. (as applicable).
• Violation of ICANN's UDRP: the domain is identical or confusingly similar to [MARK], Registrant lacks legitimate interest, and bad faith registration and 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 or 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 or URS complaint, registrar or 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 or 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.