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ScientologyRulz.com receives cease and desist letter

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BarbaraSc...@gmail.com

unread,
Jul 8, 2008, 9:50:13 PM7/8/08
to
Subject: Unauthorized Use of Registered Trademark
Date: Tue, 8 JUNE 2008
From: <AMPaq...@aol.com>
To: Barbara Schwarz
barbarasc...@gmail.com

Dear Barbara Schwarz,

Our office represents Religious Technology Center ("RTC"), the owner
of the federally registered trademark and service mark "SCIENTOLOGY".
The "SCIENTOLOGY" mark is registered with the United States Patent and
Trademark Office under registration numbers 1,755,441; 1,540,928;
1,342,353; 1,329,474; 1,318,717; 1,306,997; and 0898018. "SCIENTOLOGY"
is also registered as a trade and service mark in numerous countries
throughout the world under registration numbers B 119,381; 153,974;
180,601; B 153,085; B 153,086; 180600. We also represent the Church of
Scientology International ("CSI"), which is the licensee of the
"Scientology" trademark.

We have been advised that you have registered a domain name with
Yahoo, Inc., a United States domain registrar and agreed, through
Yahoo's Registration Agreement, Governing Law and Jurisdiction for
Disputes, to submit to the jurisdiction of Bellevue, Washington,
regarding the following domain name:

"Scientologyrulz.com"

You are hereby on notice that the registration and use of this domain
name in this fashion has caused your name to be falsely associated
with our client's registered mark, SCIENTOLOGY, as owner and creates a
likelihood of confusion as to the source or sponsorship of this domain
name in violation of United States state and federal law, including
the Lanham Act, 15 U.S.C. 1125(a).

The fact that you have added "rulz" after "Scientology" does not
protect you from trademark infringement. Dully noted that attempts at
hiding under the use of humor or "parody" to protect you from
trademark infringement have also failed. In order for a website to be
humorous or fall under the classification of "parody" it first must be
funny, which this site clearly is not. Huish Detergents, Inc. v.
Orange Glo Intern, Inc., 2002 WL 32157171 (D.Utah 2002) (holding that
minor differences in spelling and variations and arrangements of
letters was insufficient to protect against trademark infringement);
Salton, Inc. v. Cornwall Corporation, 477 F.Supp. 975 (D.C.N.J. 1979)
(holding that, even though not completely identical, defendant's term
was so like the plaintiff's in form, spelling, and sound as to
constitute trademark infringement). The adoption of the term
"Scientologyrulz" is so like the federally registered trademark
"Scientology" in form, spelling and sound as to constitute
infringement pursuant to the Lanham TradeMark Act, 15 U.S.C. 1114.
AMF v. Sleekcraft Boats, 599 F.2d 341 (9th Cir. 1979); G.D. Searle &
Company v. Chas. Pfizer & Company, 265 F.2d 385 (7th Cir. 1959).
According to UrbanDictionary.com, the definition of "rulz" is: An
incorrect way to spell rules. Most commonly written by the lazy,
dyslexic, and just plain old Down Syndrome victims
http://www.urbandictionary.com/define.php?term=rulz

Likewise, our client's registered trademark of "SCIENTOLOGY" is 11
letters and most importantly an "Ology". Your site is "likely to cause
confusion, or to cause mistake, or to deceive as to the affiliation,
connection, or association of such person with another person, or as
to the origin, sponsorship, or approval of his or her goods, services,
or commercial activities by another person." No one is going to
actually believe that Scientology "rulz". ex. America Online, Inc. v.
IMS, 24 F.Supp.2d 548, 551 (E.D.Va. 1998). Could someone say that
Scientology rulz? Maybe? Probably not. Though in your arrogance and
lul-ful ways, the "rulz" aspect of the site does not come across. Our
lawyers proved this by closely reviewing the site. Not one of us
laughed or chuckled even once.

The Anticybersquatting Consumer Protection Act ("ACPA") is also
implicated by your registration of this domain name. Shields v.
Zuccarini, 254 F.3d 476 (3rd Cit. 2001). Statutory damages can be
awarded for violation of the Act in an amount not less than $1,000 and
not more than $100,000 for each domain name. 15 U.S.C. Section
1117(d). The court in Shields imposed a $30,000 statutory damage award
against a cybersquatter under the Act. All your base are belong to us.

Pretty please, we ask that you cease and desist use of this domain
name and transfer it to our client, CSI. We are willing to pay for
your registration and transfer fees incurred in this matter.

I look forward to hearing from you.

Sincerely,
Ava Paquette
Moxon & Kobrin
3055 Wilshire Boulevard
Suite 900
Los Angeles, California 90010
Tel: (213) 487-4468
Fax: (213) 487-5385

Fredric L. Rice

unread,
Jul 8, 2008, 10:07:36 PM7/8/08
to
BarbaraSc...@gmail.com wrote:
>Subject: Unauthorized Use of Registered Trademark
>Date: Tue, 8 JUNE 2008
>From: <AMPaq...@aol.com>
>To: Barbara Schwarz
>barbarasc...@gmail.com
>Dear Barbara Schwarz,
>Our office represents Religious Technology Center ("RTC"), the owner
>of the federally registered trademark and service mark "SCIENTOLOGY".
>The "SCIENTOLOGY" mark is registered with the United States Patent and

If this is legitimate, the insane cunts Ava and Kobrin have not
learned a thing since 1993. The Lanham Act protects tradmark
usage fully, and the insane criminals have repeatedly been informed
of the fact, not only by human rights activists but by judges.

Insane Scientology criminals. Utterly fucking insane criminals.

---

Cudgel

unread,
Jul 8, 2008, 11:05:07 PM7/8/08
to
Dear Ava:

As it has been proven time and time again that scientologists (and
especially their attorneys) have no sense of humor, your statement that
scientologyrulz.com is not funny is by and of itself hilarious.

Go fuck the dwarf or something. I'm certain that he's feeling lonely just
about now. He'll feel even worse after the 12th...

BarbaraSc...@gmail.com wrote in news:fb28e653-9901-4fcc-9cd8-
c6d76b...@c58g2000hsc.googlegroups.com:

> m

barb

unread,
Jul 9, 2008, 3:16:50 AM7/9/08
to

"All your base are belong to us." Indeed. Now let's sit back and see who
gets pwned by this parodic Avagram, shall we?
--
Barb "That's Captain Barbossa to you!"
Chaplain, ARSCC (wdne)
It's Poodlin' Time!

“I think that the protections that we enjoy for freedom of worship exist
so long as we don’t step over the line. When religious worship and
belief cross over into things like fraud, victimization of others and
the disruption of the political arena, that protection is no longer
appropriate.”

--Robert Goff
Professor Emeritus, UCSC

barb

unread,
Jul 9, 2008, 3:17:13 AM7/9/08
to
OH CUZ! PWNED!!!

barb

unread,
Jul 9, 2008, 3:18:38 AM7/9/08
to
AAAOOOWWW, AND THERE'S ANOTHER ONE PWNED!!

C'mon man, do you really think Ava would put "all your base are belong
to us" in an official letter?

That's two! Who's next?

Android Cat

unread,
Jul 9, 2008, 7:14:09 AM7/9/08
to
barb wrote:
> BarbaraSc...@gmail.com wrote:
>> Subject: Unauthorized Use of Registered Trademark

>> Pretty please, we ask that you cease and desist use of this domain


>> name and transfer it to our client, CSI. We are willing to pay for
>> your registration and transfer fees incurred in this matter.
>>
>> I look forward to hearing from you.
>>
>> Sincerely,
>> Ava Paquette
>> Moxon & Kobrin
>> 3055 Wilshire Boulevard
>> Suite 900
>> Los Angeles, California 90010
>> Tel: (213) 487-4468
>> Fax: (213) 487-5385
>
> "All your base are belong to us." Indeed. Now let's sit back and see
> who gets pwned by this parodic Avagram, shall we?

"Pretty please" and "I look forward to hearing from you" had me rolling on
the floor laughing.

--
Ron of that ilk.

shellb...@gmail.com

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Jul 9, 2008, 8:53:46 AM7/9/08
to
On Jul 9, 12:58 am, BarbaraSchwarzR...@gmail.com wrote:
> Subject: Unauthorized Use of Registered Trademark
> Date: Tue, 8 JUNE 2008
> From: <AMPaque...@aol.com>
> To: Barbara Schwarz
> barbaraschwarzr...@gmail.com
>
> Dear Barbara Schwarz,
>

>Governing Law and Jurisdiction for
> Disputes, to submit to the jurisdiction of Bellevue, Washington,
> regarding the following domain name:
>
> "Scientologyrulz.com"
>

<<snip>>


>
> The fact that you have added "rulz" after "Scientology" does not
> protect you from trademark infringement. Dully noted that attempts at
> hiding under the use of humor or "parody" to protect you from
> trademark infringement have also failed. In order for a website to be
> humorous or fall under the classification of "parody" it first must be
> funny, which this site clearly is not. Huish Detergents, Inc. v.
> Orange Glo Intern, Inc., 2002 WL 32157171 (D.Utah 2002) (holding that
> minor differences in spelling and variations and arrangements of
> letters was insufficient to protect against trademark infringement);
> Salton, Inc. v. Cornwall Corporation, 477 F.Supp. 975 (D.C.N.J. 1979)
> (holding that, even though not completely identical, defendant's term
> was so like the plaintiff's in form, spelling, and sound as to
> constitute trademark infringement). The adoption of the term
> "Scientologyrulz" is so like the federally registered trademark
> "Scientology" in form, spelling and sound as to constitute
> infringement pursuant to the Lanham TradeMark Act, 15 U.S.C. 1114.
> AMF v. Sleekcraft Boats, 599 F.2d 341 (9th Cir. 1979); G.D. Searle &
> Company v. Chas. Pfizer & Company, 265 F.2d 385 (7th Cir. 1959).
> According to UrbanDictionary.com, the definition of "rulz" is: An
> incorrect way to spell rules. Most commonly written by the lazy,
> dyslexic, and just plain old Down Syndrome victimshttp://www.urbandictionary.com/define.php?term=rulz
>

Not real! Not real take down letter is not real. Is FUNNY! Not
possible for Scilons to be funny!

Fredric L. Rice

unread,
Jul 9, 2008, 10:35:50 AM7/9/08
to
barb <xenu...@netscape.net> wrote:

>C'mon man, do you really think Ava would put "all your base are belong
>to us" in an official letter?

I didn't read the thing -- I never read any of the insane email that
Apa sends out. If I had read it, I wouldn't have fallen for it.

---

kennethno...@gmail.com

unread,
Jul 9, 2008, 7:04:59 PM7/9/08
to
On Jul 8, 6:50 pm, BarbaraSchwarzR...@gmail.com wrote:

> According to UrbanDictionary.com, the definition of "rulz" is: An
> incorrect way to spell rules. Most commonly written by the lazy,
> dyslexic, and just plain old Down Syndrome victimshttp://www.urbandictionary.com/define.php?term=rulz
>


I like Ava's reference to UrbanDictionary.com. Scientology rulz!


--
Scientology Rulz!
http://www.scientologyrulz.com

kennethno...@gmail.com

unread,
Jul 10, 2008, 1:20:36 AM7/10/08
to
On Jul 8, 6:50 pm, BarbaraSchwarzR...@gmail.com wrote:
[snip]

Likewise, our client's registered trademark of "SCIENTOLOGY" is 11
letters and most importantly an "Ology".

Ava makes a good point here. heh

BarbaraSc...@gmail.com

unread,
Jul 10, 2008, 9:12:54 PM7/10/08
to
Subject: Re: Unauthorized Use of Registered Trademark
Date: Thursday, 10 JULY 2008
From: Barbara Schwarz
barbarasc...@gmail.com
To: <AMPaq...@aol.com>

Dear Ava,

I like your letter. It was awsome!

I'm a Scientologist too, just like you. I love Scientology, I wish it
was inside of me. Welp, I'm sad you don't like my websight. I tryd
hard to make it good. Mabe you can tell me how to make it better and I
will. Please dont put me in the RPF again. It's cold and I'm scared
easy. Maybe you can say hi to my parents too. I miss them. Dont tell
anyone I told you that thogh. Thanks.

Hey, you now this info, how gay is Tom Cruise? Like, what I mean, is
he a top or a botom? I gess wat I'm trying to say is does he like to
catch or is he a picher? I think he likes to catch. He seems to me
like a big girl. Wen he maried Katie as a coverup I thought it was a
good idea. We don't want any dirty faggots in Scientology. Keep them
queers over in the cathlic church is wut I say.

Ok - I gotta go trick some more people into joining with those stress
tess or whatever the fuck you guys want to call it. Haha, they don't
do nuthing except get my stats good.

Sinserly,

Barbara Schwarz
SLC library
210 East 400 South
Salt Lake City UT 84111
Tel: (801) 524-8200

Fredric L. Rice

unread,
Jul 10, 2008, 9:33:40 PM7/10/08
to
kennethno...@gmail.com wrote:
>On Jul 8, 6:50 pm, BarbaraSchwarzR...@gmail.com wrote:
>[snip]
>Likewise, our client's registered trademark of "SCIENTOLOGY" is 11
>letters and most importantly an "Ology".
>Ava makes a good point here. heh

It's the most sane thing the deranged criminal ever wrote.

---

kennethno...@gmail.com

unread,
Jul 11, 2008, 10:38:23 PM7/11/08
to
On Jul 10, 6:33 pm, fr...@skeptictank.org (Fredric L. Rice) wrote:


I need a picture of Ava Paquette. Anyone have one?

I have this hot picture of Helena Kobrin http://www.scientomogy.com/scientology_lawyers.jpg,
but that's not gonna work.

obsce...@live.com

unread,
Jul 11, 2008, 10:59:57 PM7/11/08
to
On Jul 12, 3:38 am, kennethnoisewat...@gmail.com wrote:

> I need a picture of Ava Paquette.  Anyone have one?
>
> I have this hot picture of Helena Kobrin
> http://www.scientomogy.com/scientology_lawyers.jpg,
> but that's not gonna work.

Holy crap.

The Cult likes their birds fugly.

Out_Of_The_Dark

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Jul 12, 2008, 1:18:16 AM7/12/08
to
On Jul 9, 3:18 am, barb <xenub...@netscape.net> wrote:
> Cudgel wrote:
> > Dear Ava:
>
> > As it has been proven time and time again that scientologists (and
> > especially their attorneys) have no sense of humor, your statement that
> > scientologyrulz.com is not funny is by and of itself hilarious.
>
> > Go fuck the dwarf or something. I'm certain that he's feeling lonely just
> > about now.  He'll feel even worse after the 12th...
>
> > BarbaraSchwarzR...@gmail.com wrote in news:fb28e653-9901-4fcc-9cd8-
> > c6d76b7d0...@c58g2000hsc.googlegroups.com:

>
> >> m
>
> AAAOOOWWW, AND THERE'S ANOTHER ONE PWNED!!
>
> C'mon man, do you really think Ava would put "all your base are belong
> to us" in an official letter?
>
> That's two! Who's next?
>
> --
> Barb "That's Captain Barbossa to you!"
> Chaplain, ARSCC (wdne)
> It's Poodlin' Time!
>
> “I think that the protections that we enjoy for freedom of worship exist
> so long as we don’t step over the line. When religious worship and
> belief cross over into things like fraud, victimization of others and
> the disruption of the political arena, that protection is no longer
> appropriate.”
>
>                 --Robert Goff
>                 Professor Emeritus, UCSC- Hide quoted text -
>
> - Show quoted text -

lol!

Fredric L. Rice

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Jul 13, 2008, 1:23:47 PM7/13/08
to
kennethno...@gmail.com wrote:

>I need a picture of Ava Paquette. Anyone have one?

I have its finger prints, will that help?

---
I mock up my own Body Thetans

kennethno...@gmail.com

unread,
Jul 13, 2008, 4:30:49 PM7/13/08
to
On Jul 13, 10:23 am, fr...@skeptictank.org (Fredric L. Rice) wrote:


That's crazy there's no Ava pictures out there. Really? Her name is
on everything. Helena or Moxon doesn't even really send stuff out
anymore, it's all Ava.

A picture of Ava in a bikini or lingerie would be preferred, but
whatever.

Miserable Dwarf

unread,
Jul 14, 2008, 1:21:24 AM7/14/08
to

i found a rare photo of Ms. Paquette from her college reunion:
http://entertainment.webshots.com/photo/1018514451012167632tovRPBzJKf

kennethno...@gmail.com

unread,
Jul 15, 2008, 3:03:07 AM7/15/08
to
On Jul 13, 10:21 pm, Miserable Dwarf <Miscavige.Sucks.D...@gmail.com>
wrote:

LOL! She's hot.

Scientology kicks ass!
http://www.scientologyrulz.com/scientology_cult_suckerpunch.php

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