New York NY 10036-5794
Mallory D. Levitt
Tel 212 258 6784
Fax 212 846 6193
August 30, 1996
Via Certified Mail
Return Receipt Requested
Mr. Joe Brown
Re: Infringements of STAR TREK Copyrights and Trademarks
Dear Mr. Brown:
I write as attorney for Paramount Pictures Corporation ("Paramount").
As you are, no doubt, aware, Paramount owns all of the rights to the television series entitled STAR TREK, STAR TREK: THE NEXT GENERATION, STAR TREK: DEEP SPACE NINE, STAR TREK: VOYAGER, and all theatrical releases relating thereto (collectively the "STAR TREK Properties"). These rights are protected by numerous copyrights trademarks in both the programs themselves and the characters, sets, and other elements appearing in those programs.
We have recently learned that you have posted various elements of the STAR TREK Properties on its site named Athena Star Trek at cen.uiuc.edu/~paron/athena/trek. Your posting of these items is an infringement of Paramount's rights in the STAR TREK Properties.
Paramount does not, of course, object to all materials posted on the Internet relating to the STAR TREK Properties. For example, Paramount does not object to the general discussion of "Star Trek" over the Internet. However, when such disscussions rise to the level of copying full transcripts or providing detailed summaries of the works, such transmissions are clear infringements of Paramounts's rights. Similarly, posting of copyrighted material such as photographs, artistic renditions of "Star Trek" characters or other properties, sound files, video clips, books or excerpts therefrom are likewise infringemnts of Paramount's rights.
Based upon the foregoing, we hereby demand that your confirm to us in writing within ten days of receipt of this letter that: (i) you have removed all infringing materials from your site, including all photographs and sound bytes; and (ii) you will refrain from posting any similar infringing material on the Internet or any other on-line service in the future.
The foregoing is without waiver of any and all rights of Paramount Pictures Corporation, all of which are expressly reserved herein.
Very truly yours,