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"The only thing necessary for the triumph of evil is for good men to do nothing"
Edmund Burke

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Name of victim
Address of victim

Re: Coach, Inc

Dear (Victim):

            This firm is counsel to Coach, Inc. and Coach Services, Inc.(herein collectively referred to as “Coach”), with respect to certain intellectual property matters. Coach is the owner of the federally-registered (sic) “COACH” trademark, among others (the “Coach Trademarks”).

            It has recently come to our attention that you are illegally offering for sale and selling merchandise bearing counterfeits of the Coach Trademarks (the “Illegal Merchandise”) on

            Such action is likely to cause confusion and constitutes trademark counterfeiting, infringement and dilution of our client's intellectual property rights. Your conduct violates federal and state trademark laws. As a result, you may be held liable for trademark counterfeiting and infringement. 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 attorney fees.

            Therefore, 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 immediately:

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 “Coach, Inc.” by Cashier's Check, Certified Check or Money Order, for all damages and costs incurred by our clients in connection with your illegal conduct, in the amount of $300.

We strongly urge you not to contact the supplier of the Illegal Merchandise or take any other action which would interfere with Coach'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 complete the information below and return it along with the Illegal Merchandise and payment to the undersigned at: Gibney, Anthony & Flaherty, LLP, 665 Fifth Avenue, New York, NY 10022.

You hereby warrant and represent that:

1. Your seller ID is ____________________

2. All the Illegal Merchandise has been withdrawn from and all other venues and you have surrendered all Illegal Merchandise in your possession or control to the undersigned counsel for Coach.

3. You sold _____________ pieces of Illegal Merchandise and your profits from these sales were $____________________.

4. Your supplier(s) for the Illegal Merchandise and its (their) contact information is:

5. You will never again advertise, manufacture, offer for sale, sell or otherwise distribute the Merchandise that infringes upon Coach's rights in any venue, including but not limited to,

6. You have made monetary payment of $300 to Coach, either by certified check or money order, made payable to “Coach, Inc” based upon your profits and Coach's attorney fees and costs in connection with your sale of the Illegal merchandise.

IN WITNESS WHEREOF, you agree to the forgoing.

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Please be advices that your failure to respond or to comply with these demands before (insert date) may result in Coach taking legal action to enforce their rights, all of which are hereby expressly reserved.