This portion of the
www.raymond.cc website not only features prominent unauthorized use of our client’s KASPERSKY marks, but it also facilitates the unauthorized distribution of Kaspersky Anti-Virus software by providing the website's users with directions for procuring Kaspersky software free of charge (see the screenshot from this section of the website, attached). These actions are in no way authorized by our client, and we view that your continued use of Kaspersky’s intellectual property in this fashion constitutes infringement of Kaspersky’s exclusive copyright and trademark rights, and is thus a violation of United States federal copyright law and federal and state trademark law. As a result, you have caused and continue to cause significant damage to Kaspersky in Massachusetts, the location of its principal office.
Specifically, and without limitation, we demand that you take the following corrective actions immediately:
1. Cease all infringement of Kaspersky’s intellectual property rights, including without limitation the unauthorized display of Kaspersky trademarks on the above referenced web site;
2. Desist from any future infringement of Kaspersky’s intellectual property rights;
3. Indicate to us in writing by 5:00PM Eastern Time on November 21, 2008, that you agree to the actions specified above and have taken (with respect to the first demand) and will take (with respect to all other demands) such actions.