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