UDRPro, LLC
Internet and Domain Name Lawyers
350 5th Avenue, 59th Floor
New York, NY 10118
Ph.:
310-499-8624
Fax:
646-200-5227
Alex Brunetti
Re: Trademark and Copyright Infringement –
FABIANOCARUANA.COM
Mr. Brunetti:
Please be advised that I represent Mr. Fabiano Caruana with respect to
intellectual
property-related matters.
As you are aware, Mr. Caruana is a world-renowned chess Grandmaster.
Mr.
Caruana’s notoriety and widespread media coverage regarding his
accomplishments in
the chess world date back to as early as 2003. In 2007, Mr. Caruana
became the youngest
Grandmaster in the history of Italy and the United States.
It has come to our attention that you registered and are
cybersquatting on the
domain
FABIANOCARUANA.COM, which is identical to my Client’s name. In
addition, you are using, without permission, copyrighted images of my
Client on your
website.
Your passive use of the domain name, and unauthorized use of my
Client’s
likeness to attract visitors to your website constitute an
infringement of our trademark
rights and copyrights. Your actions divert Internet users searching
for websites relating
to my Client to your own website, and you are preventing my Client
from exploiting the
domain name for himself.
Accordingly, we demand that you immediately transfer the domain name
FABIANOCARUANA.COM to my Client.
My Client is prepared to pursue all available legal remedies to
protect its
intellectual property rights, either before an international tribunal
at the World
Intellectual Property Organization in Geneva, Switzerland, and/or
through other legal
channels available under United States, Italian, and international
laws.
If I do not hear from you by Monday, August 27, 2012 to initiate this
domain
name transfer, we shall assume that you have no interest in an
amicable resolution. We
will then have no choice but to pursue our legal remedies.
Very truly yours,
Maulin V. Shah, Esq.
Attorney at Law