RE: Trademark Infringement: GODADDY*.COM (Claim ID 758335)
Dear ***:
I write on behalf of Go Daddy Operating Company, LLC, ("Go Daddy") the owner of the well-known trademarks GO DADDY and GODADDY.COM. As you are no doubt aware, these trademarks are used to identify the world's largest ICANN-accredited domain name registrar and leading web hosting provider.
Go Daddy is the owner of numerous trademark registrations world-wide, including trademark registrations in China for GO DADDY, Registration Nos. 5142283, 5142284, 5142285, 5142286, 5142287 and 5142288, GO DADDY (戈达迪), Registration Nos. 7010990, 7010989, 7010988, 7010987 and 7010986, GO DADDY (找管家), Registration Nos. 5142505, 5142506, 5142507, 5142508, 5142509 and 5142510 and GODADDY.COM, Registration Nos. 5142302, 5142300, 5142361, 5142360, 5142362 and 5142359, as well as GO DADDY trademark registrations in the United States (Registration Nos. 2558989, 3669373, 3660490, 3753673, 3926559, 2945201, 2945200, 2904954, 2969916, 3672972, 3605479, 3672975, 3608456, 3860412 and 3156369) and other registrations world-wide (including Asia and the European Union).
Go Daddy has expended a considerable amount of resources to establish the strong consumer recognition associated with Go Daddy's famous marks, and we have continuously and extensively promoted these marks in connection with our services and products since 1999.
As a trademark owner, Go Daddy has the affirmative legal obligation to enforce its trademarks to ensure that our customers are not confused as to the source of Go Daddy products and services and to protect our valuable intellectual property from diminishment.
It has come to our attention that you have been using the GO DADDY mark in connection with your domain name, GODADDY*.COM (the "Domain Name"). Your use of our trademark in this manner violates Go Daddy's trademark rights and falsely suggests a connection to Go Daddy. In addition, Go Daddy is concerned that your use of our mark will result in dilution of the strength of the famous GO DADDY name, regardless of any similarity between the goods or services offered through your site. As your use of the GO DADDY mark would cause the public to associate the mark with a different source, the ability of the GO DADDY mark to serve as the unique identifier of Go Daddy's goods and services would be weakened if this use is permitted.
Your registration and use of the Domain Name is actionable under the ICANN Uniform Dispute Resolution Policy ("UDRP"), which you agreed to be bound by as a condition of your domain name registration. Penalties for trademark infringement and/or cyber-squatting include both injunctive and monetary relief, including statutory damages and forfeiture of the domain.
Accordingly, we demand that you agree to the following:
1. Immediately discontinue any and all use of the Domain Name;
2. Take immediate steps to transfer the Domain Name to us;
3. Identify and agree to transfer to us any other domain names registered by you that contain the term "Go Daddy" or any terms that are confusingly similar to "Go Daddy."
4. Immediately and permanently refrain from any use of the Go Daddy trademark, or any variation thereof that is likely to cause confusion or dilution.
5. Provide written assurances within 10 calendar days that you will cease your unauthorized use of this domain and transfer ownership of the Domain Name to us. When you transfer the domain name to Go Daddy, the registrant fields should read as follows:
First Name : Go Daddy
Last Name : Go Daddy
Email : [email protected]
Company Name : Go Daddy
Address1 : 14455 N. Hayden Road
Address 2 : Suite 226
City : Scottsdale
State or Providence : Arizona
Zip Code : 85260
Country : USA
Phone : (480) 505-8800
6. Inform Go Daddy, in an email sent to [email protected], of the measures that you have taken in this regard and agreeing not to use any trademarks or copyrights owned by Go Daddy without advance written consent of Go Daddy.
As a courtesy, we are willing to offer a new domain registration with Go Daddy in exchange for the transfer of the Domain Name.
We would appreciate receiving a response from you by November 19, 2012.
Please be advised that this letter is without prejudice to any of Go Daddy's rights or remedies. If you would like to discuss this matter, please do not hesitate to contact me.
Sincerely,
Carlos Becerra
Trademark Administration
Go Daddy Operating Company, LLC
(480) 366-3011
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发表于 2012-11-12 23:17:08
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