>>42
Dear Sir:
Our firm represents Deckers Outdoor Corporation, 495-A South Fairview Ave., Goleta, CA, United States ("Deckers") in trademark and copyright matters. Deckes is known in the trade as UGG Australia and owns the UGG trademark for footwear, clothing, outerwear, bags, and other goods. UGG is a registered trademark in the United States (U.S. Reg. No. 3,050,925), China (Reg. No. 880518), and more than 70 other countries around the world. In the United States, the UGG mark was first used at least as early as December 28, 1979, and was first used in interstate commerce at least as early as December 28, 1979. Deckers maintains a website at uggaustralia.com where genuine UGG goods are sold using its UGG trademark, including UGG sheepskin boots,
I. Multiple images and/or text that appear on the website at ugg2all.com are unauthorized reproductions of Deckers' copyrighted works. Pursuant to 17 U.S.C. 512, we hereby request that you expeditiously remove the website located at ugg2all.com from your web search results for violations of United States Copyright law.
Pursuant to 17 U.S.C. 512(c)(3)(A)(ii), we hereby identify the following copyrighted works that are being infringed by the site at (note that this list is representative only -multiple others of Deckers' copyrighted works are being infringed by material found at
UGG Australia's Women's Nightfall (Image).
2. Pursuant to 17 U.S.C. 512(c)(3)(A)(iii), we hereby identify the following images and/or text on the website at , and provide the following representative list of materials on the website at that are infringing our clienf's copyrights:
UOG Australia's Women's Nightfall (Image).
Search query: "UGG boots"
Infringing webpage(s): <
http://ugg2all.com/>;
It is noted that several additional materials on the website at are infringing our client's copyrights. However, for the sake ofbrevity and in accordance with the provisions of 5I2(c), only a representative list has been provided.
3. Pursuant to 17 U.S.C. 5l2(c)(3)(A)(iv), we hereby provide the following contact information:
[redacted] GREER, BURNS & CRAIN, LTD. Suite 2500 300 S. Wacker Drive Chicago, IL 60606 Ph:[redacted] Email: [redacted]@gbclaw.net
4. The whois information for the website at indicates the e-mail address of the owner/administration is [redacted]@whoisprivacyprotect.com. The website also provides [redacted]@ugg2all.com.
5. I have a good faith belief that use of the copyrighted materials described above on the allegedly infringing webpages is not authorized by the copyright owner, its agent, or the law.
6. I swear, under penalty of perjury consistent with United States Code Title 17, Section 512, that the information in the notification is accurate and that I am the copyright owner or am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
In addition, investigation suggests that the website at is being used to sell counterfeit UGG goods from China and/or other foreign countries to consumers in the U.S. These counterfeit sales violate multiple U.S. laws, including Title 15 of the United States Code. 15 U.S.C. 1117(c)
For these reasons, we request the website at ugg2all.com be removed from the Google web search results. If you have any questions regarding this matter, pleas: contact us.
Yours truly,
GREER, BURNS & CRAIN, LTD.
[redacted]