| Note-The letter has "justified" (straight line both sides) margins and I have tried to preserve form,although some spacing is not exactly correct, an effort has been made to adhere to the original "look" of the letter as possible. The substance/content is maintained as received. The response to this letter is located HERE. |
| RONALD
D. COLEMAN ____ DIRECT DIAL NUMBER (973) 966-8244 RCOLEMAN@)PHKS.COM |
PITNEY, HARDIN, KIPP & SZUCH (MAIL TO) P.O. BOX 1945 MORRISTOWN, NEW JERSEY 07962-1945 ______ (DELIVERY TO) 200 CAMPUS DRIVE FLORHAM PARK, NEW JERSEY 07932-0950 (973) 9866300 |
|
| November 17,1999 | ||
BY ELECTRONIC MAIL AND CERTIFIED MAIL / R.R.R.
John Raymond Baker, D.C.
[address omitted by page author]Re: SELECTIVE INSURANCE
Dear Dr. Baker:
This firm represents Selective Insurance Group Inc. ( "Selective Insurance"), which
holds the trademark rights, including an incontestable registered trademark , in the mark
SELECTIVE INSURANCE. We write to advise you that your use of the trademarks and trade
name of Selective Insurance in the universal resource locator ("URL")
http://selectiveinsurance.homepage.com is likely to confuse the public regarding the origin of the
information on your website, and constitutes an infringement of Selective Insurance's SELECTIVE INSURANCE trademark as well as dilution of Selective Insurance's trademark rights under federal
and state law.
Selective Insurance demands that you cease the use of any domain name that is
confusingly similar to SELECTIVE INSURANCE within five (5) days of receipt of this letter.
In the event that you do not do so, Selective Insurance has authorized this office to institute an action
in the United State District Court seeking an injunction, money damages and attorneys' fees and
costs against you personally as well as against Homepage.com.Your website at the above URL also contains false, misleading and defamatory
statements about Selective Insurance. Selective Insurance hereby demands that you remove all such
statements from your website and advises you that if you do not do so, it may seek an injunction,[ Page author insert---please click here to see the second page]