September 20 2016
Dear Mr. Sweet:
We ___ Thauer Sports (“TS”), a leading manufacturer of professional athletic shoes. TS owns all trademark rights in the well-known ___ that adorns our products and sales and marketing materials. The mark is widely known and famous throughout this ___.
It has come to our ___ that you have registered the domain name “ts.nu.” This domain name ___ refers to TS. There appears to be no good faith reason for you to have registered this domain name, since you have no connection to TS.
If you have registered the domain name in bad faith, your actions may ___ you to the loss of your domain name as well as to civil ___ of up to $100,000 under the Anticybersquatting Consumer Protection ___. As your website currently offers athletic goods, your actions also ___ trademark ___ and/or dilution under the Trademark Act.
Accordingly, we seek your prompt written ___ that (1) you have ___ publication, distribution, transmission, or dissemination of any information, goods, or services under the name “ts.nu,” or any other name confusingly similar ___; and (2) you will either delete the domain name “ts.nu” from the domain name registry or immediately ___ the name to TS.
If we can have your ___ on these points, TS will be willing to consider this matter closed. Alternatively, we will commence an action at the World Intellectual Property Organization ___ to the Uniform Domain Name Dispute Resolution Policy, and a civil action, seeking injunctive relief, ___, and attorneys’ fees. Please respond by no later than 17 November 2016.
If we do not have your written agreement by that date, TS will commence legal proceedings without further ___.