Dear Sir/Madam:
Nike is the world’s leading sports and fitness company. Since 1971, Nike has used its NIKE trademark in connection with a broad range of athletic footwear, apparel, and equipment. Nike owns numerous registrations worldwide for its NIKE trademark, including U.S trademark registrations nos. 1,153,938; 1,214,930; 1,243,248; 1,277,066; and 978,952. Indeed, our NIKE mark is one of the world’s most famous trademarks, and is widely recognized as identifying goods and services that emanate from Nike.
It has come to our attention that you are using a domain name that contains Nike’s world-famous NIKE trademark – adidasinike , info. This name is in no way affiliated with Nike. By using Nike’s NIKE trademark, you have engaged in trademark infringement and unfair competition. In addition to this misuse of Nike’s goodwill, Nike’s valued customers will likely be confused, or believe inaccurately that Nike endorses or is otherwise connected with you and any products or services you offer. It is very important to Nike to prevent the misleading use of our valuable trademark, and to protect the public from any such confusion.
Accordingly, Nike believes that your use of the domain name constitutes trademark infringement and unfair competition, and also violates the U.S. Anticybersquatting Consumer Protection Act ("ACPA"). These laws provide for causes for injunctive relief, monetary damages and attorney’s fees. Under the ACPA, you could be liable for up to $100,000 in statutory damages. Your actions also subject you to possible actions under the Uniform Domain Name Dispute Resolution Policy (“UDRP”).
Accordingly, we demand that you immediately:
1) Cease and desist from any further use of the infringing domain names and any other imitations or simulations of Nike’s name, trademarks or service marks;
2) Discontinue using Nike's trademark in your website domain name; and
3) Countersign and return to us a copy of this letter, confirming that you agree fully to comply, and are promptly complying, with the above demands. If you wish to settle this matter amicably, we must receive promptly your countersigned copy of this letter by March 28, 2012. Please fax this signed letter to NIKE Legal Grand Guard Department, 503.646.6926.
If you use, sell, or offer to sell the infringing domain names after your receipt of this notice, we will regard your actions as deliberate and willful violations of Nike's rights and the laws pointed out to you above. Until and unless we notify you in writing that this matter has been resolved, Nike reserves the right to take legal action against you without further notice.
We look forward to hearing from you.
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