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Scott et al - more info. from Felipe Foy as mentioned in my last email.
Also, as I mentioned to Justin yesterday, we have taken the precaution of registering the following four domain names for Enron Metals (for possible use, until we 'retrieve' enronmetals.com and enronmetals.co.uk from Peter Quine. This was also done to preclude further cybersquatting): enron-metals.com enron-metals.co.uk enronmetals.net enronmetals.org (Also, FYI to internal folks, note that Felipe Foy's team in London is now co-ordinating registration of all domain names Enron-wide to ensure consistency and central tracking. We are trying to ensure that prior to any new domain name registrations by Enron that we first talk to Legal and Tax to ensure there are no trademark infringement issues or tax liability issues (particular for foreign jurisdiction registrations, e.g. registering enrononline.de for Germany). Please let me know if you require further information or have any concerns with any of this. Thank you, Paul Goddard +44-207-783-2310 ---------------------- Forwarded by Paul Goddard/EU/Enron on 18/10/2000 08:40 --------------------------- Felipe Foy@ECT 18/10/2000 07:37 To: Paul Goddard/EU/Enron@Enron cc: Subject: Domain Registration FYI ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- Felipe Foy 07/12/2000 04:28 PM To: Daniel Moore/LON/ECT@ECT cc: Nelson Bibby/LON/ECT@ECT, EEL eBusiness Infrastructure, Barry Sangster/LON/ECT@ECT Subject: Re: Enronmetals Daniel, With regard to the e-mail below. 1. The enronmetals.co.uk is owned by what do we do? 2. enronmetals.net.uk is not a valid tlid. 3. .org.uk can be registered 4. Another one to check who it is. 5. .net can be registered. 6. .org can be registered. Could you please confirm the domains are correct and what you want to do about .net.uk. Regards Felipe ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- Felipe Foy 07/20/2000 07:06 AM To: sbrown@velaw.com cc: Nelson Bibby/LON/ECT@ECT, Michael Slade/LON/ECT@ECT, EEL eBusiness Infrastructure Subject: Domain Names Scott, Thanks for the phone call and as promised here are some details. 1. My e-mail address is felipe.foy@enron.com, telephone 020 7783 7941. 2. My Director is Nelson Bibby and his e-mail is nelson.bibby@enron.com, telephone 020 7783 6766. 3. My contact in Legal in London is Michael Slade, telephone 020 7783 7433. The two domains in question are enronmetals.com enronmetals.co.uk As per the telephone conversation you will be keeping me informed of what happens over the next few months. Regards Felipe ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- Michael Slade 07/20/2000 09:03 AM To: Felipe Foy/LON/ECT@ECT cc: Subject: Re: Domain Names Thanks Felipe Please keep me copied in Mike Felipe Foy 20/07/2000 07:06 To: sbrown@velaw.com cc: Nelson Bibby/LON/ECT@ECT, Michael Slade/LON/ECT@ECT, EEL eBusiness Infrastructure Subject: Domain Names Scott, Thanks for the phone call and as promised here are some details. 1. My e-mail address is felipe.foy@enron.com, telephone 020 7783 7941. 2. My Director is Nelson Bibby and his e-mail is nelson.bibby@enron.com, telephone 020 7783 6766. 3. My contact in Legal in London is Michael Slade, telephone 020 7783 7433. The two domains in question are enronmetals.com enronmetals.co.uk As per the telephone conversation you will be keeping me informed of what happens over the next few months. Regards Felipe ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- Felipe Foy 07/27/2000 08:26 AM To: Barry Sangster/LON/ECT@ECT cc: Daniel Moore/LON/ECT@ECT, Nelson Bibby/LON/ECT@ECT Subject: EnronMetals Barry, As per Nelson's request, here are the screen shots of the site. I have set my browser up to notify to me if there are any changes. www.enronmetals.com www.enronmetals.co.uk Regards Felipe ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- "Brown, W. Scott" <sbrown@velaw.com< 08/07/2000 04:18 AM To: "'Justin.Boyd@enron.com'" <Justin.Boyd@enron.com< cc: "Mark E. Holsworth (E-mail)" <Mark.Holsworth@enron.com<, "Felipe Foy (E-mail)" <felipe.foy@enron.com< Subject: RE: enron.metals.com Justin, I sent a cease and desist letter to Mr. Peter Quine when I first heard of this matter. He was given until last Friday to respond to me regarding the matter. I have not heard from him and the next step is to initiate an arbitration proceeding in the US as to the enronmetals.com domain name. This procedure is relatively inexpensive and swift, in that we should expect a ruling within 60 days of filing. To help me establish the needed showing of bad faith on the part of Mr. Quine, could you please send me an e-mail with all the relevants facts regarding the cybersquatting of the domain name. Unfortunately, there is not a similar proceeding available for the enronmetals.com.uk domain name. That domain name will involve a legal proceeding in the UK, and I believe it could be quite lengthy. My initial thought was to proceed with the arbitration proceeding in the US first, and then deal with .com.uk domain name laterm if necessary. Please let me know if you wish for me to proceed in a different manner. scott -----Original Message----- From: Justin.Boyd@enron.com [mailto:Justin.Boyd@enron.com] Sent: Sunday, August 06, 2000 6:02 AM To: sbrown@velaw.com Subject: Re: enron.metals.com scott - if you could keep me posted as to progress on an ongonig basis thanks justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 06/08/2000 13:08 --------------------------- From: Mark Holsworth@ENRON on 04/08/2000 13:48 CDT To: Justin Boyd/LON/ECT@ECT, sbrown@velaw.com cc: Subject: Re: enron.metals.com (Document link: Database 'Justin Boyd', View '($Inbox)') I am copying this to Scott Brown. He is supposed to be handling this matter. Justin Boyd@ECT To: cc: 08/04/2000 Subject: 04:10 AM Mark, Would be grateful if you could update me and Barry as to the status of the action taken against the individual who has registered the above as a domain name Thanks Justin ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- Barry Sangster 08/07/2000 08:03 AM To: Felipe Foy/LON/ECT@ECT cc: Nelson Bibby/LON/ECT@ECT, Justin Boyd/LON/ECT@ECT Subject: RE: enron.metals.com Please submit brief fact file. Thanks BS ---------------------- Forwarded by Barry Sangster/LON/ECT on 07/08/2000 08:03 --------------------------- Justin Boyd 07/08/2000 07:57 To: Barry Sangster/LON/ECT@ECT cc: Subject: RE: enron.metals.com Barry Could you provide me with the facts Thanks. Justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 07/08/2000 07:59 --------------------------- Enron Capital & Trade Resources Corp. From: "Brown, W. Scott" <sbrown@velaw.com< 07/08/2000 04:18 To: "'Justin.Boyd@enron.com'" <Justin.Boyd@enron.com< cc: "Mark E. Holsworth (E-mail)" <Mark.Holsworth@enron.com<, "Felipe Foy (E-mail)" <felipe.foy@enron.com< Subject: RE: enron.metals.com Justin, I sent a cease and desist letter to Mr. Peter Quine when I first heard of this matter. He was given until last Friday to respond to me regarding the matter. I have not heard from him and the next step is to initiate an arbitration proceeding in the US as to the enronmetals.com domain name. This procedure is relatively inexpensive and swift, in that we should expect a ruling within 60 days of filing. To help me establish the needed showing of bad faith on the part of Mr. Quine, could you please send me an e-mail with all the relevants facts regarding the cybersquatting of the domain name. Unfortunately, there is not a similar proceeding available for the enronmetals.com.uk domain name. That domain name will involve a legal proceeding in the UK, and I believe it could be quite lengthy. My initial thought was to proceed with the arbitration proceeding in the US first, and then deal with .com.uk domain name laterm if necessary. Please let me know if you wish for me to proceed in a different manner. scott -----Original Message----- From: Justin.Boyd@enron.com [mailto:Justin.Boyd@enron.com] Sent: Sunday, August 06, 2000 6:02 AM To: sbrown@velaw.com Subject: Re: enron.metals.com scott - if you could keep me posted as to progress on an ongonig basis thanks justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 06/08/2000 13:08 --------------------------- From: Mark Holsworth@ENRON on 04/08/2000 13:48 CDT To: Justin Boyd/LON/ECT@ECT, sbrown@velaw.com cc: Subject: Re: enron.metals.com (Document link: Database 'Justin Boyd', View '($Inbox)') I am copying this to Scott Brown. He is supposed to be handling this matter. Justin Boyd@ECT To: cc: 08/04/2000 Subject: 04:10 AM Mark, Would be grateful if you could update me and Barry as to the status of the action taken against the individual who has registered the above as a domain name Thanks Justin ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- Felipe Foy 08/09/2000 11:31 AM To: Barry Sangster/LON/ECT@ECT cc: Subject: RE: enron.metals.com Barry, Sorry with the delay in answering. All the stuff I have been dealing with has been copied to yourself. Do you just want me to re-send these with dates. Regards Felipe Enron Information Technology From: Barry Sangster 08/07/2000 08:03 AM To: Felipe Foy/LON/ECT@ECT cc: Nelson Bibby/LON/ECT@ECT, Justin Boyd/LON/ECT@ECT Subject: RE: enron.metals.com Please submit brief fact file. Thanks BS ---------------------- Forwarded by Barry Sangster/LON/ECT on 07/08/2000 08:03 --------------------------- Justin Boyd 07/08/2000 07:57 To: Barry Sangster/LON/ECT@ECT cc: Subject: RE: enron.metals.com Barry Could you provide me with the facts Thanks. Justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 07/08/2000 07:59 --------------------------- Enron Capital & Trade Resources Corp. From: "Brown, W. Scott" <sbrown@velaw.com< 07/08/2000 04:18 To: "'Justin.Boyd@enron.com'" <Justin.Boyd@enron.com< cc: "Mark E. Holsworth (E-mail)" <Mark.Holsworth@enron.com<, "Felipe Foy (E-mail)" <felipe.foy@enron.com< Subject: RE: enron.metals.com Justin, I sent a cease and desist letter to Mr. Peter Quine when I first heard of this matter. He was given until last Friday to respond to me regarding the matter. I have not heard from him and the next step is to initiate an arbitration proceeding in the US as to the enronmetals.com domain name. This procedure is relatively inexpensive and swift, in that we should expect a ruling within 60 days of filing. To help me establish the needed showing of bad faith on the part of Mr. Quine, could you please send me an e-mail with all the relevants facts regarding the cybersquatting of the domain name. Unfortunately, there is not a similar proceeding available for the enronmetals.com.uk domain name. That domain name will involve a legal proceeding in the UK, and I believe it could be quite lengthy. My initial thought was to proceed with the arbitration proceeding in the US first, and then deal with .com.uk domain name laterm if necessary. Please let me know if you wish for me to proceed in a different manner. scott -----Original Message----- From: Justin.Boyd@enron.com [mailto:Justin.Boyd@enron.com] Sent: Sunday, August 06, 2000 6:02 AM To: sbrown@velaw.com Subject: Re: enron.metals.com scott - if you could keep me posted as to progress on an ongonig basis thanks justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 06/08/2000 13:08 --------------------------- From: Mark Holsworth@ENRON on 04/08/2000 13:48 CDT To: Justin Boyd/LON/ECT@ECT, sbrown@velaw.com cc: Subject: Re: enron.metals.com (Document link: Database 'Justin Boyd', View '($Inbox)') I am copying this to Scott Brown. He is supposed to be handling this matter. Justin Boyd@ECT To: cc: 08/04/2000 Subject: 04:10 AM Mark, Would be grateful if you could update me and Barry as to the status of the action taken against the individual who has registered the above as a domain name Thanks Justin ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- "Brown, W. Scott" <sbrown@velaw.com< 08/29/2000 10:50 PM To: "Justin Boyd (E-mail)" <Justin.Boyd@enron.com< cc: "Felipe Foy (E-mail)" <felipe.foy@enron.com<, "Mark E. Holsworth (E-mail)" <Mark.Holsworth@enron.com< Subject: FW: enron.metals.com Justin, To update you on the enronmetals domain name matter, attached please find a copy of a fax I received from Peter Quine and my responsive e-mail to him. Since Mr. Quine has not responded back to me, we will proceed with the arbitration proceeding. In that regard, could you please provide with me a brief summary of the relevant facts so that we may prepare the necessary arbitration pleadings. thanks, scott -----Original Message----- From: Brown, W. Scott Sent: Sunday, August 06, 2000 10:19 PM To: 'Justin.Boyd@enron.com' Cc: Mark E. Holsworth (E-mail); Felipe Foy (E-mail) Subject: RE: enron.metals.com Justin, I sent a cease and desist letter to Mr. Peter Quine when I first heard of this matter. He was given until last Friday to respond to me regarding the matter. I have not heard from him and the next step is to initiate an arbitration proceeding in the US as to the enronmetals.com domain name. This procedure is relatively inexpensive and swift, in that we should expect a ruling within 60 days of filing. To help me establish the needed showing of bad faith on the part of Mr. Quine, could you please send me an e-mail with all the relevants facts regarding the cybersquatting of the domain name. Unfortunately, there is not a similar proceeding available for the enronmetals.com.uk domain name. That domain name will involve a legal proceeding in the UK, and I believe it could be quite lengthy. My initial thought was to proceed with the arbitration proceeding in the US first, and then deal with .com.uk domain name laterm if necessary. Please let me know if you wish for me to proceed in a different manner. scott -----Original Message----- From: Justin.Boyd@enron.com [mailto:Justin.Boyd@enron.com] Sent: Sunday, August 06, 2000 6:02 AM To: sbrown@velaw.com Subject: Re: enron.metals.com scott - if you could keep me posted as to progress on an ongonig basis thanks justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 06/08/2000 13:08 --------------------------- From: Mark Holsworth@ENRON on 04/08/2000 13:48 CDT To: Justin Boyd/LON/ECT@ECT, sbrown@velaw.com cc: Subject: Re: enron.metals.com (Document link: Database 'Justin Boyd', View '($Inbox)') I am copying this to Scott Brown. He is supposed to be handling this matter. Justin Boyd@ECT To: cc: 08/04/2000 Subject: 04:10 AM Mark, Would be grateful if you could update me and Barry as to the status of the action taken against the individual who has registered the above as a domain name Thanks Justin ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- "Brown, W. Scott" <sbrown@velaw.com< 08/29/2000 11:00 PM To: "Justin Boyd (E-mail)" <Justin.Boyd@enron.com< cc: "Felipe Foy (E-mail)" <felipe.foy@enron.com<, "Mark E. Holsworth (E-mail)" <Mark.Holsworth@enron.com< Subject: FW: enron.metals.com Sorry, here are the attachments. -----Original Message----- From: Brown, W. Scott Sent: Tuesday, August 29, 2000 4:50 PM To: Justin Boyd (E-mail) Cc: Felipe Foy (E-mail); Mark E. Holsworth (E-mail) Subject: FW: enron.metals.com Justin, To update you on the enronmetals domain name matter, attached please find a copy of a fax I received from Peter Quine and my responsive e-mail to him. Since Mr. Quine has not responded back to me, we will proceed with the arbitration proceeding. In that regard, could you please provide with me a brief summary of the relevant facts so that we may prepare the necessary arbitration pleadings. thanks, scott -----Original Message----- From: Brown, W. Scott Sent: Sunday, August 06, 2000 10:19 PM To: 'Justin.Boyd@enron.com' Cc: Mark E. Holsworth (E-mail); Felipe Foy (E-mail) Subject: RE: enron.metals.com Justin, I sent a cease and desist letter to Mr. Peter Quine when I first heard of this matter. He was given until last Friday to respond to me regarding the matter. I have not heard from him and the next step is to initiate an arbitration proceeding in the US as to the enronmetals.com domain name. This procedure is relatively inexpensive and swift, in that we should expect a ruling within 60 days of filing. To help me establish the needed showing of bad faith on the part of Mr. Quine, could you please send me an e-mail with all the relevants facts regarding the cybersquatting of the domain name. Unfortunately, there is not a similar proceeding available for the enronmetals.com.uk domain name. That domain name will involve a legal proceeding in the UK, and I believe it could be quite lengthy. My initial thought was to proceed with the arbitration proceeding in the US first, and then deal with .com.uk domain name laterm if necessary. Please let me know if you wish for me to proceed in a different manner. scott -----Original Message----- From: Justin.Boyd@enron.com [mailto:Justin.Boyd@enron.com] Sent: Sunday, August 06, 2000 6:02 AM To: sbrown@velaw.com Subject: Re: enron.metals.com scott - if you could keep me posted as to progress on an ongonig basis thanks justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 06/08/2000 13:08 --------------------------- From: Mark Holsworth@ENRON on 04/08/2000 13:48 CDT To: Justin Boyd/LON/ECT@ECT, sbrown@velaw.com cc: Subject: Re: enron.metals.com (Document link: Database 'Justin Boyd', View '($Inbox)') I am copying this to Scott Brown. He is supposed to be handling this matter. Justin Boyd@ECT To: cc: 08/04/2000 Subject: 04:10 AM Mark, Would be grateful if you could update me and Barry as to the status of the action taken against the individual who has registered the above as a domain name Thanks Justin - QUINE.TIF ----- Message-ID: <543317BA1813D411A28A0050DA0DEF0B27B771@EXCHANGE_HOU< From: "Brown, W. Scott" <sbrown@velaw.com< To: "'Peter Quine (E-mail)'" <peter@yesyes.com< Subject: Infringement of Enron Corp.'s trade names and intellectual proper ty Date: Tue, 22 Aug 2000 13:32:00 -0500 X-Mailer: Internet Mail Service (5.5.2650.21) <<...OLE_Obj...<< ATTORNEYS AT LAW VINSON & ELKINS L.L.P. Writer's Phone: (713) 758-1105 E-mail: sbrown@velaw.com Writer's Fax: (713) 615-5803 Web: www.velaw.com August 22, 2000 VIA E-MAIL peter@yesyes.com Mr. Peter Quine 9 Park Crescent Brighton e.Sussex BN23HA UK Re: Enron Corp. Dear Mr. Quine: Reference is made to your letter of 7 August 2000. I appreciate your reassurance that it was not your intention to infringe my client's trade names and intellectual property rights. Correspondingly, let me say that I am very aware of all the legal aspects of domain name registration, having worked in this area for quite some time, and I can assure you that the intentional registration of a domain name that includes the trade name or trademark of a third party is an infringement of the rights of such third party. There has been a great deal of litigation in the United States, and I suspect in many other countries as well, regarding such wrongful activities. I am confident that your independent investigations in such matters will support my comments. As I mentioned above, I appreciate the reassurance stated in your letter and my initial letter was not intended to reflect upon your reputation or integrity or method of doing business. However, my client has authorized me to take any and all action necessary to quickly secure the enronmetals.com and enronmetals.com.uk domain names. Consequently, please send me a return e-mail stating whether or not you intend to promptly transfer those domain names to Enron Corp. Very truly yours, /wsb/ W. Scott Brown 0803:4494 Houston:304801.1 ----- Forwarded by Felipe Foy/LON/ECT on 10/18/2000 07:34 AM ----- Barry Sangster 08/30/2000 08:34 AM To: Amita Gosalia/LON/ECT@ECT, Daniel Moore/LON/ECT@ECT, Robert Campbell/LON/ECT@ECT, Mark Pickering/LON/ECT@ECT, Nelson Bibby/LON/ECT@ECT, Felipe Foy/LON/ECT@ECT cc: Subject: FW: enron.metals.com fyi ---------------------- Forwarded by Barry Sangster/LON/ECT on 30/08/2000 08:34 --------------------------- Justin Boyd 30/08/2000 07:39 To: Barry Sangster/LON/ECT@ECT cc: Subject: FW: enron.metals.com barry - please would you let me have the relevant details since we're taking this further forward Thanks. Justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 30/08/2000 07:40 --------------------------- Enron Capital & Trade Resources Corp. From: "Brown, W. Scott" <sbrown@velaw.com< 29/08/2000 23:00 To: "Justin Boyd (E-mail)" <Justin.Boyd@enron.com< cc: "Felipe Foy (E-mail)" <felipe.foy@enron.com<, "Mark E. Holsworth (E-mail)" <Mark.Holsworth@enron.com< Subject: FW: enron.metals.com Sorry, here are the attachments. -----Original Message----- From: Brown, W. Scott Sent: Tuesday, August 29, 2000 4:50 PM To: Justin Boyd (E-mail) Cc: Felipe Foy (E-mail); Mark E. Holsworth (E-mail) Subject: FW: enron.metals.com Justin, To update you on the enronmetals domain name matter, attached please find a copy of a fax I received from Peter Quine and my responsive e-mail to him. Since Mr. Quine has not responded back to me, we will proceed with the arbitration proceeding. In that regard, could you please provide with me a brief summary of the relevant facts so that we may prepare the necessary arbitration pleadings. thanks, scott -----Original Message----- From: Brown, W. Scott Sent: Sunday, August 06, 2000 10:19 PM To: 'Justin.Boyd@enron.com' Cc: Mark E. Holsworth (E-mail); Felipe Foy (E-mail) Subject: RE: enron.metals.com Justin, I sent a cease and desist letter to Mr. Peter Quine when I first heard of this matter. He was given until last Friday to respond to me regarding the matter. I have not heard from him and the next step is to initiate an arbitration proceeding in the US as to the enronmetals.com domain name. This procedure is relatively inexpensive and swift, in that we should expect a ruling within 60 days of filing. To help me establish the needed showing of bad faith on the part of Mr. Quine, could you please send me an e-mail with all the relevants facts regarding the cybersquatting of the domain name. Unfortunately, there is not a similar proceeding available for the enronmetals.com.uk domain name. That domain name will involve a legal proceeding in the UK, and I believe it could be quite lengthy. My initial thought was to proceed with the arbitration proceeding in the US first, and then deal with .com.uk domain name laterm if necessary. Please let me know if you wish for me to proceed in a different manner. scott -----Original Message----- From: Justin.Boyd@enron.com [mailto:Justin.Boyd@enron.com] Sent: Sunday, August 06, 2000 6:02 AM To: sbrown@velaw.com Subject: Re: enron.metals.com scott - if you could keep me posted as to progress on an ongonig basis thanks justin ---------------------- Forwarded by Justin Boyd/LON/ECT on 06/08/2000 13:08 --------------------------- From: Mark Holsworth@ENRON on 04/08/2000 13:48 CDT To: Justin Boyd/LON/ECT@ECT, sbrown@velaw.com cc: Subject: Re: enron.metals.com (Document link: Database 'Justin Boyd', View '($Inbox)') I am copying this to Scott Brown. He is supposed to be handling this matter. Justin Boyd@ECT To: cc: 08/04/2000 Subject: 04:10 AM Mark, Would be grateful if you could update me and Barry as to the status of the action taken against the individual who has registered the above as a domain name Thanks Justin - QUINE.TIF ----- Message-ID: <543317BA1813D411A28A0050DA0DEF0B27B771@EXCHANGE_HOU< From: "Brown, W. Scott" <sbrown@velaw.com< To: "'Peter Quine (E-mail)'" <peter@yesyes.com< Subject: Infringement of Enron Corp.'s trade names and intellectual proper ty Date: Tue, 22 Aug 2000 13:32:00 -0500 X-Mailer: Internet Mail Service (5.5.2650.21) <<...OLE_Obj...<< ATTORNEYS AT LAW VINSON & ELKINS L.L.P. Writer's Phone: (713) 758-1105 E-mail: sbrown@velaw.com Writer's Fax: (713) 615-5803 Web: www.velaw.com August 22, 2000 VIA E-MAIL peter@yesyes.com Mr. Peter Quine 9 Park Crescent Brighton e.Sussex BN23HA UK Re: Enron Corp. Dear Mr. Quine: Reference is made to your letter of 7 August 2000. I appreciate your reassurance that it was not your intention to infringe my client's trade names and intellectual property rights. Correspondingly, let me say that I am very aware of all the legal aspects of domain name registration, having worked in this area for quite some time, and I can assure you that the intentional registration of a domain name that includes the trade name or trademark of a third party is an infringement of the rights of such third party. There has been a great deal of litigation in the United States, and I suspect in many other countries as well, regarding such wrongful activities. I am confident that your independent investigations in such matters will support my comments. As I mentioned above, I appreciate the reassurance stated in your letter and my initial letter was not intended to reflect upon your reputation or integrity or method of doing business. However, my client has authorized me to take any and all action necessary to quickly secure the enronmetals.com and enronmetals.com.uk domain names. Consequently, please send me a return e-mail stating whether or not you intend to promptly transfer those domain names to Enron Corp. Very truly yours, /wsb/ W. Scott Brown 0803:4494 Houston:304801.1
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