Rolex
Complaint 220943 Details

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From: Tony D <(Personal Information Removed)>
To: [email protected]
Sent: Saturday, March 9, 2013 3:07 PM
Subject: Re: Rolex(Replica) Date Just VERY Nice W/Swiss Auto Movement Gold Tone 5% - $175 (Las Vegas)



Hi

Tell YOU what meet me at McDonald's off Boulder Hwy Las Vegas.
Provide YOUR PHONE First so you can be IDENTIFFIED.

Your address of OFFICE for Verificatgion.

The AD is EXPLICIT. This is a "Replica" Rolex, not being presented as a "ROLEX". Confused? Your Confused.

Once YOU PROVIDE information to substantiate "YOUR CONFUSION" I will UNCONFUE you by meeting YOU.
First I'll SEND YOUR INFOMRATION to ROLEX, but to Start I'll send a copy of this(for email trace to local authorities)

You wouldn't be trying to PULL SOME TYPE of SCAM would you.

SURE I'll GIVE YOU MY "REPLICA" Rolex.


From: Gaf Counsel <[email protected]>
To: [email protected]
Sent: Friday, March 8, 2013 1:25 PM
Subject: Rolex(Replica) Date Just VERY Nice W/Swiss Auto Movement Gold Tone 5% - $175 (Las Vegas)




http://lasvegas.craigslist.org/jwl/3665905836.html
To Whom It May Concern:

This firm is general counsel to Rolex Watch U.S.A., Inc. (“Rolex”), the owners of the federally registered Rolex Trademarks: ROLEX, PRESIDENT, SUBMARINER, YACHT-MASTER, DAYTONA, GMT-MASTER, DATEJUST and (Crown Device) (among others) (the “Rolex Trademarks”).

It has come to Rolex’s attention that you are illegally offering for sale and selling merchandise bearing counterfeit copies of the Rolex Trademarks (the “Illegal Merchandise”) on craigslist.org.

Your actions are likely to cause confusion and constitute trademark counterfeiting and infringement and dilution of Rolex’s intellectual property rights in violation of both federal and state laws. The penalties for such conduct are severe and may include injunctive relief, actual damages, statutory damages of up to $2,000,000 for each trademark that has been counterfeited, costs and attorneys’ fees.

On behalf of Rolex, we demand that you immediately cease and desist from any and all offering for sale, sale, distribution, importation, manufacture, advertisement, promotion and display of the Illegal Merchandise. We also demand that you do the following:


1. Surrender all Illegal Merchandise in your possession, custody or control.

2. Provide the identity of the source of the Illegal Merchandise.

3. Make payment to “Rolex Watch U.S.A., Inc.” by Cashier’s Check, Certified Check or Money Order for all damages and costs incurred by Rolex in connection with your illegal conduct, in the amount of $350USD.

We strongly urge you not to contact the supplier of the Illegal Merchandise or to take any other action which would interfere with our client’s ability to eliminate Illegal Merchandise from the marketplace and will hold you responsible for your complicity in any such actions to the maximum extent provided by law.

Please be advised that your failure to respond in writing or to comply with these demands before March 15, 2013, may result in Rolex taking legal action to enforce its rights. Please send all information, along with your payment, to the attention of the undersigned to the following address:

Gibney, Anthony & Flaherty, LLP
665 Fifth Avenue
New York, NY 10022
Attn: Rolex Enforcement

If you have any questions, please call (212) 705-9805.

This letter does not constitute an exhaustive list of Rolex claims or rights, all of which are hereby expressly reserved.

We await a response from you or your counsel.


Sincerely,

Gibney, Anthony & Flaherty, LLP


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