May 11, 2016
64 Waldingfield Lane
Sudborough C011 3TA
Dear Mr. Holder:
As you may be aware, for over 20 years, we at TransLegal (founded in Stockholm, Sweden in 1989) have been a provider of Legal English services and products including, inter alia, the translation of legal documents. TransLegal has grown to become the world leader in Legal English. Our in-house staff of lawyer-linguists is the largest in the world, providing a wide range of products and services to the international legal community including translations of legal documents, Legal English testing, online Legal English courses and resources, live seminars and training, and the publication of Legal English materials.
TransLegal’s Legal English products and services are used by lawyers and law students in over 100 countries. Specifically, the translation of legal documents has been, and continues to be, a major source of revenue for the company and a large part of our overall success as a leader in the field of Legal English.
In addition, the TRANSLEGAL trademark is widely known and famous throughout the world. We sell our services and products to numerous countries around the world through our website located at www.translegal.com. The TRANSLEGAL mark is the subject of numerous trademark registrations worldwide, including Community Trade Mark No. 0024235654 and US Trademark No. 2705355.
It has come to our attention that you have registered and are using the domain name www.mhtranslegal.com. In addition, on this site, you are using our TRANSLEGAL trademark in connection with the apparent offering for sale of translation services.
This domain name inherently refers to our company. There appears to be no good faith reason for you to have registered this domain name, since you have no connection to TransLegal.
Your actions may subject you to the loss of your domain name under the Uniform Domain Name Dispute Resolution Policy (“UDRP”) as well as to civil penalties of up to $100,000 under the Anticybersquatting Consumer Protection Act. As your website currently offers translation services, your actions also constitute trademark infringement and/or dilution under the laws of several countries, including the UK.
Accordingly, we seek your prompt written assurance that (1) you have ceased publication, distribution, transmission, or dissemination of any information, goods, or services under the TRANSLEGAL mark or any other name or mark confusingly similar thereto; (2) you will not use the TRANSLEGAL mark, or any mark confusingly similar thereto, in any manner in connection with any business you conduct or may be involved in; and (3) you will delete the domain name “www.mhtranslegal.com” from the relevant domain name registrar.
Given that you have perhaps infringed upon our rights inadvertently, we are writing this letter to you first (prior to engaging local counsel) in an effort to settle this matter without resorting to the pursuit of legal action. If we can have your agreement on these points, TransLegal will be willing to consider this matter closed.
However, if you fail to agree to the above or fail to respond, we reserve the right to commence an action at the World Intellectual Property Organization pursuant to the UDRP, and a civil action, seeking injunctive relief, damages, and attorneys’ fees. Upon receipt of this letter, you have now been put on notice and any subsequent use will clearly be in bad faith entitling TransLegal to increased damages for willful infringement.
We request that you respond to this letter no later than May 25, 2016.