As you know from my previous letter of February 4, 2014 I serve as intellectual property counsel to Haier Group Corporation and Haier America Trading, LLC.(“Haier”), the owner of inter alia,
the famous trademark and service mark HAIER.
My client continues to be extremely concerned about your unauthorized use of the domain name
HAIERBROTHERS.com (the “Domain”), which is confusingly similar to the HAIER registered
mark and to many of HAIER’s registered domain names. In connection with this site you
prominently make visual references to the Haier Kids characters which could be confusing as to
your relationship with the company.
My client has authorized us to prepare a complaint against you to be filed in federal district court
for trademark, false advertising, and brand Tarnishment. Given your silence on this matter, we
will be asking for damages to be assessed in view of your continued and willful infringement.
We must ask that you immediately and permanently cease and desist using this and any other
domain names that are confusingly similar to the mark HAIER, and assign the Domain to my
client. Further, we ask that you immediately and permanently cease and desist using any of
HAIER’s trademarks and service marks in any manner.
We look forward to receiving your written assurances, as outlined above, on or before March 7,
2014. This letter is without prejudice to any other claims of our client.
Sincerely,
[redacted]
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