<quote>
Dear Mr. Silto:
We represent Target Brands, Inc. ("TBI") in connection with its intellectual property matters. It has recently come to our attention that you have registered the domain name clubtarget.net.
as you may know, Target Corporation and its Target Stores division ("Target") have since 1962 operated in the United States a chain of Target retail stores, now numbering more than 1000 stores in 46 states of the United States. Target is in addition active in electronic commerce, operation an informational and on-line shopping site at [url]http://www.target.com.[/url]
Over the years, Target's stores and other commercial undertakings have developed a national and international reputation for quality and value. This well-deserved and hardearned reputation is reflected in the substantial and valuable body of goodwill symbolized by, among other things, the target mark, a commercial icon now owned by TBI and licensed exclusively to Target.
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As you might expect, TBI owns a number of United States service mark and trademark registrations for the word Target alone, the Bullseye desing alone, and the word TARGET together with the Bullseye desing, including U.S. Trademark Registration number --- therefore, currently protected under United States trademark, dilution, cybersquatting and unfair competition laws ---
Since you have chosen a domain name so similar to TBI's famous Target mark, trademark and related laws of the United States and other jurisdictions require that any use you make of clubtarget.net, including in particular any use directed to the United States, must be carefully designed and limited to avoid any risk that the public will be confused or misled into believing that your operations are in any way associated with Target or TBI. ---
We have reviewed the content now posted at clubtarget.net and do not believe that it is likely to cause confusion vis-á-vis Target/TBI or to dilute the distinctive quality of TBI's famous Target mark.
Nonetheless, to the extent that you may intend in the future to change the nature of the content posted at clubtarget.net, we can advise you that the likelihood of confusion, and therefore the likelihood that you will violate TBI's rights, will be greater to the extent your operations at clubtarget.net: (1) are directed to the United States; (2) are directed to the general public (as opposed to a specialized audience); (3) involve sales to retail consumers; (4) include display of a "Bullseye" or similar desing; and/or (5) present "Target" and/or a bullseye design in the distinctive bright red color that the public has come to associate with Target and its goods and services.
Thus, while we have no issue with the content now posted at clubtarget.net, you are now on notice of TBI's rights and of your obligations should you choose to change the use of clubtarget.net. ---
Your attention to this matter is appreciated.
Very truly yours,
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