Legal/Infringement Notices/5 August 2010
Dear Ms. Compton,
Thank you for your prompt response. The individual Personas are:
heidenh
Lipjan07
bernardirs
blacky2906
Carlo_Carerra
Norvin_R
rammstein91
lukyn
rlnds
Please let me know if you need any additional information.
Best regards,
From: Elizabeth Compton <ecompton@mozilla.com>
To: marina depietri <marina.depietri@us.redbull.com>
Date: 08/05/2010 12:17 PM
Subject: Re: WS 6.007.993 – US – Infringement of Red Bull’s Trademarks on Get
Dear Ms. Depietri,
We received your notice of alleged trademark infringement below. Please identify the individual Personas you are asking us to take down. Since search results can change over time and may include Personas that you don't believe infringe your rights, we need a definitive list of the specific Personas you have identified as infringing Red Bull's trademarks.
Upon receipt of this additional information we will take down the identified Personas.
Sincerely,
Liz Compton
Mozilla
Dear Mr. Anderson,
I am writing on behalf of Red Bull GmbH (“Red Bull”), the producer of the RED BULL energy drink which is distributed the United States. Red Bull owns various trademark registrations and common law rights in and to the famous RED BULL trademark and the trade dress depicted on the RED BULL energy drink can, including the single and double bull device. It recently came to our attention that the content on getpersonas.com – which is registered to the Mozilla Corporation – infringes Red Bull’s trademarks. Below please find the relevant information to address the infringements, and please let me know if you have any questions or need additional information.
(1) Please find my electronic signature below.
(2) The following trademarks which belong to Red Bull have been infringed: RED BULL word mark, RED BULL AIR RACE word mark, RED BULL LEIPZIG word mark, LA FORMULA UNA & device, and the single bull and double bull device (collectively, the “RED BULL Marks”).
(3) The infringing material consists of various themes that use the RED BULL Marks and can be found here: http://www.getpersonas.com/en-US/gallery/All/search?p=redbull&search.x=0&search.y=0.
(4) My contact information is as follows:
Marina Depietri, Esq.
Intellectual Property Attorney, North America
Red Bull GmbH/Red Bull North America, Inc.
1740 Stewart Street
Santa Monica, CA 90404 U.S.A.
Office: (310) 460-5804
Fax: (310) 309-5295
E-mail: marina.depietri@us.redbull.com
(5) I have a good faith belief that the infringing material described above is not authorized by Red Bull, its agent, or the law.
(6) I declare under penalty of perjury, that to the best of my knowledge, the above information is accurate and that I am authorized to act on behalf of Red Bull in requesting removal of the infringing material.
Do not hesitate to contact me if you have any questions. I look forward to hearing from you and receiving confirmation that the infringing material has been removed from GetPersonas.com.
