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How Not to Write a Cease-and-Desist Letter

Posted by ScuttleMonkey on Mon Oct 08, 2007 12:39 PM
from the love-seeing-bullies-get-bullied dept.
In our overly litigious society it seems that many companies are all too happy to fire off a cease-and-desist letter if they see something they don't like. Many times these letters end up online just causing further embarrassment for the company. One such company has decided to try scaring their targets out of this response by including a copyright notice for their cease-and-desist letter. Public Citizen has fielded one of these dumb letters and has invited them to try to assert their cease-and-desist copyright (which isn't even registered).
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TechDirt has a follow up to a case they covered back in October where a law firm was trying to claim a copyright on the cease-and-desist letters they sent out. Public Citizen poked a number of holes in this claim and invited the lawyers to "try it." Well, unfortunately the lawyers decided to bite and what's more, they actually got a judge to buy it. The news was announced by the victorious lawyer who now claims he can sue anytime someone posts one of his cease-and-desist letters. "The copyrighting of cease-and-desist letters is an easy way for law firms to bully small companies who have committed no wrong, but who have no real recourse to fight back against an attempt to shut them up via legal threat. Until today, many companies who were being unfairly attacked by companies and law firms misusing cease-and-desist letters to prevent opinions from being stated, had a reasonable recourse to such attacks, and could draw attention to law firms that used such bullying tactics to mute any criticism."
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  • by Anonymous Coward on Monday October 08 2007, @12:42PM (#20900325)

         
  • Ssh! (Score:5, Funny)

    by Anonymous Coward on Monday October 08 2007, @12:43PM (#20900339)
    Don't tell Darl about this.
    • by drachenfyre (550754) on Monday October 08 2007, @01:46PM (#20901167) Homepage
      1. You do not need to register a copyright in the US to enforce it.
      2. You DO need to register it before pursuing legal action in the US AND damages are limited to actual damages, not statutory damages. Legal fees expended in defending the copyright are also ineligible to be claimed in this case.

      There are about 50 posts in this thread already going back and forth on this point and it's really clouding up what is a good discussion.
      • by evanbd (210358) on Monday October 08 2007, @03:24PM (#20902657)

        From its content alone, your post is completely indistinguishable from any other post by someone who claims to know how copyright works in the US. It should be obvious that just because you know you're right, that doesn't mean the rest of us can tell that just because you sound certain about it. So, please post a link to a reputable reference, rather than just adding another post going back and forth on the issue and clouding up the discussion.

        (FWIW, I think you're right about this. But it would add a lot more to the discussion if you could actually include a reference.)

  • Good idea / bad idea (Score:5, Informative)

    by networkBoy (774728) on Monday October 08 2007, @12:44PM (#20900359) Homepage Journal
    How to get bad press: http://farmersreallysucks.com/editorialtakedown1.shtml [farmersreallysucks.com]
    How to get *good* press: http://farmersreallysucks.com/editorialgetafirstlife.shtml [farmersreallysucks.com]
    -nB
    • In the UK... (Score:5, Informative)

      by meringuoid (568297) on Monday October 08 2007, @02:59PM (#20902323)
      ... Over here, there's a standard form for contemptuous replies to legal bluster. It goes: "I refer you to the reply in the case of Arkell v. Pressdram [wikipedia.org]".
      • by networkBoy (774728) on Monday October 08 2007, @01:03PM (#20900645) Homepage Journal

        The Linden Labs non-C&D is hysterical.
        I don't think it can get much better than this:

        In conclusion, your invitation to submit a cease-and-desist letter is hereby rejected.
        Point is, LL got just as much (or more) publicity from this letter as they would have gotten from a normal C&D, but instead it's all positive. By responding they secured their position of ownership, while not looking like asshats. IMHO most C&Ds are written from the perspective that if the company does not respond they risk trademark dilution issues. The problem is they respond wrongly, not that they respond. In the case of my C&D from Farmers, they quote all the commercial portions of US code and none of the sections that deal with comment or criticism. Once you read through Title 15 and 17 you will find that it explicitly negates its self when dealing with the personal side of publication. Specifically:

        (4) The following shall not be actionable under this section:
                        (A) Fair use of a famous mark by another person in comparative
                commercial advertising or promotion to identify the competing goods
                or services of the owner of the famous mark.
                        (B) Noncommercial use of a mark.
                        (C) All forms of news reporting and news commentary.
        So all a lawyer has to do is send a letter stating that they are asserting trademark ownership and such, while recognizing this particular application of their trademark is protected. They could then go on to request alterations as they see fit, and likely get a much more positive response.
        -nB
  • by bnisonger (857781) on Monday October 08 2007, @12:44PM (#20900369)
    There is no registration or notice requirement anymore to assert copyright.
    • by cfulmer (3166) on Monday October 08 2007, @01:10PM (#20900727) Journal
      Well... You are quite right that you do not need to register a work in order to have a copyright on it (at least in the U.S.). But, you can't sue somebody for infringement unless you've registered the original work. You can register after the infringement and then sue, but you still have to register.
      • by roystgnr (4015) * <{roystgnr} {at} {ticam.utexas.edu}> on Monday October 08 2007, @02:03PM (#20901489) Homepage
        But, you can't sue somebody for infringement unless you've registered the original work. You can register after the infringement and then sue, but you still have to register.

        I was about to correct you, but I went to the US Code to find a relevant quote, and holy crap, it looks like you're right! Title 17, Chapter 4, 411:

        "Except for an action brought for a violation of the rights of the author under section 106A (a), and subject to the provisions of subsection (b), no action for infringement of the copyright in any United States work shall be instituted until preregistration or registration of the copyright claim has been made in accordance with this title."

        The exceptions in 106A appear to be about plagiarism/misrepresentation cases, not about simple "making unlicensed copies".

        I thought you registered your copyrights so you'd be eligible for statutory damages and attorneys' fees in a lawsuit. That's in the law, but it's just a reason to register copyright before any infringement begins rather than right before you sue. You learn something new every day. This must be why lawyers charge the big bucks.
      • by Artifakt (700173) on Monday October 08 2007, @01:16PM (#20900813)
        A legal notice, prepared so as to be admissible in a court proceeding, becomes a document of the court. As such, its broader publication is from then on to be determined by a judge, who could, for example seal the record, theoretically including the document. Unless a judge actually did this, the document is part of the public record, subject to various 'sunshine laws' and basic rules for federal proceedings, that override any assertion of copyright.
                The proper method to deal with publication is to go ahead and press the case, and ask the judge to issue an order prohibiting both sides from discussing the case in public forums as a pre-trial motion. There is no real venue to stop publication of the legal notice short of actually taking the case to court, and there are some powerful SCOTUS decisions on the first amendment issues involved that say any such method would be prior restraint.

        (please note my Sig. Any actual lawyers please feel free to correct me if I have got anything wrong here.)
        • by hal9000(jr) (316943) on Monday October 08 2007, @01:52PM (#20901285)
          From the US Copyright office FAQ on registration http://www.copyright.gov/help/faq/faq-general.html#register [copyright.gov]:

          When is my work protected?
          Your work is under copyright protection the moment it is created and fixed in a tangible form that it is perceptible either directly or with the aid of a machine or device.

          Do I have to register with your office to be protected?
          No. In general, registration is voluntary. Copyright exists from the moment the work is created. You will have to register, however, if you wish to bring a lawsuit for infringement of a U.S. work. See Circular 1, Copyright Basics, section "Copyright Registration."

          Why should I register my work if copyright protection is automatic?
          Registration is recommended for a number of reasons. Many choose to register their works because they wish to have the facts of their copyright on the public record and have a certificate of registration. Registered works may be eligible for statutory damages and attorney's fees in successful litigation. Finally, if registration occurs within 5 years of publication, it is considered prima facie evidence in a court of law. See Circular 1, Copyright Basics, section "Copyright Registration" and Circular 38b, Highlights of Copyright Amendments Contained in the Uruguay Round Agreements Act (URAA), on non-U.S. works.

          I've heard about a "poor man's copyright." What is it?
          The practice of sending a copy of your own work to yourself is sometimes called a "poor man's copyright." There is no provision in the copyright law regarding any such type of protection, and it is not a substitute for registration [ephasis added by me].

          so the mailing it to yourself adds no special protection.
          • by Creepy Crawler (680178) on Monday October 08 2007, @02:19PM (#20901741)
            ---The practice of sending a copy of your own work to yourself is sometimes called a "poor man's copyright." There is no provision in the copyright law regarding any such type of protection, and it is not a substitute for registration

            Thats just false. If you do NOT register a valid work, you must prove it is yours. By providing a federal datestamp, it does provide some basic claim that it was created by X date.

            You still cannot sue for violating copyright if you didnt register it. The mail trick only works in preventing others from suing YOU.
        • by belmolis (702863) <billposer@NOsPaM.alum.mit.edu> on Monday October 08 2007, @01:54PM (#20901317) Homepage

          Copyright is copyright. One copyright is not stronger than another copyright.

          The only difference between a registered and unregistered copyright is the burden of proof.

          Sorry, this is wrong. Registration of the copyright provides a number of advantages, which are summarized here [copyright.gov] by the Copyright Office. Among them is that, if the copyright is registered within three months of publication or prior to infringement, statutory damages and attorney's fees may be obtained. If not, only actual damages may be recovered by the copyright owner. In the case of a letter such as this, which has no commercial value, actual damages would be zero, so the failure to register the letter effectively eliminates any financial recovery. (Of course, the author of the letter is unlikely to succeed in the threatened suit since this is an absolutely classic case of Fair use.)

  • Copyright (Score:5, Informative)

    by aitikin (909209) on Monday October 08 2007, @12:49PM (#20900421)
    Correct me if I'm wrong (cause I know you will), but I was always taught that copyright exists the moment you put pen to paper. You will have a harder time proving it if you haven't registered it, but legally speaking you own the right to allow copies to made and or distributed it the moment it's written.
    • Re:Copyright (Score:5, Informative)

      by Baricom (763970) on Monday October 08 2007, @12:57PM (#20900513)
      That's true, but in the U.S., if you don't register, you cannot bring suit, and if you register late, you can only claim actual damages (as in, how much money you lost because somebody copied your work), not statutory damages (where the $100,000+ liability figures come from), and you cannot claim attorney's fees.

      Note: I am not an attorney. I used http://www.publaw.com/advantage.html [publaw.com] as my source.
  • Funny Stuff (Score:5, Interesting)

    by eldavojohn (898314) * <my/.username@@@gmail.com> on Monday October 08 2007, @12:50PM (#20900425) Homepage Journal
    You can find the first letter to start all this here [citizen.org]. I recommend you read that letter and then the one linked in the text.

    They attempt to use Fair Housing Council of San Fernando Valley v. Roommates.com, LLC decision as a reason that Leonard is legally liable for hosting defamatory statements about an infomercial company! This is Charles Montgomery Burns quality humor.

    Also, for further comedic value, I heavily recommend The DirectBuy website [directbuy.com] done entirely in flash. Which doesn't offer much except a registration form (click the upper right hand ticket). I can't find a damned thing on how their business model works unless I sign up for it. Seems to be a way to get home furnishings as discount prices. But for some reason you have to go to a show room for that. Sounds like something where the value isn't really there but they're certain they can sell you on the idea if they get a half hour of your time. Probably not a scam but pretty damned close--time share style!

    Also what's interesting is how they respond to negative feedback questions [directbuycares.com]:

    We're happy to hear that you are considering a DirectBuy membership. We understand that negative information can make it hard for you to make an informed decision about how membership can meet your current and future buying needs, and we'd like to respond.

    DirectBuy's unique business model is very different than mainstream retail operation. Our concept, combined with our continued growth over 36 years, has made DirectBuy, just like any other sizeable corporation, a target for controversy.

    That being said, most of the information online is posted by individuals who have not attended an Open House, or have chosen not to become members.

    We realize that DirectBuy is not for everyone, and that's why we encourage individuals who are interested in taking a calculated approach to undeniable savings to attend an Open House to learn about our unmatched selection, savings, and service. The complaints you see online from those who have actually visited DirectBuy represent a very small fraction of the hundreds of thousands of individuals each year who attend an Open House. (And to set the record straight, DirectBuy has never been involved in a class-action lawsuit.)

    We're very proud of our long track record of satisfied members who have enjoyed the undeniable savings and wide array of merchandise that we offer. Our members invest upfront to avoid paying traditional retail markup and save significantly on virtually everything for in and around their homes. Members' satisfaction is our number-one priority.

    But the only way to make an informed decision about whether DirectBuy membership is right for you is to attend an Open House event at a showroom near you. There, you'll learn more about the benefits of DirectBuy membership by gaining exclusive access to our showroom and getting a firsthand look at the savings, selection and services available to members from our team of knowledgeable professionals.

    DirectBuy members, tell McBain about your membership experience here, too. We'd love to hear from you!
    I've bolded the sentence that worries me. It both sounds too good to be true and sounds like they take my money and promise me something later that's ill defined. What do you think?

    I'll bet any amount of money that wasn't written by a person with a soul. Shady legal threats from an even shadier company. What do you expect?
    • Re:Funny Stuff (Score:5, Interesting)

      by Billosaur (927319) * <wgrother&optonline,net> on Monday October 08 2007, @01:00PM (#20900577) Journal

      The really funny part is that their service is pretty much a scam... I've read up on them and apparently some of their policies are a little suspects, such as clause that do not allow you to return merchandise, cancel an order, or even (get this), terminate your membership! And where did this information come from? Try Consumer Reports [consumerreports.org]. DirectBuy is just another company with its head in the sand. Personally, I can't wait to see if this will end up in court.

    • Re:Funny Stuff (Score:4, Insightful)

      by Luke Dawson (956412) on Monday October 08 2007, @01:28PM (#20900933)

      What do you think?

      I find this bit the most amusing:

      We understand that negative information can make it hard for you to make an informed decision about how membership can meet your current and future buying needs, and we'd like to respond.

      As if, somehow, only looking for positive information about something is the best way to come to an "informed" decision. If anything, I'm looking specifically for negative information when I am trying to make an informed decision before buying something.

  • by Zymergy (803632) * on Monday October 08 2007, @12:53PM (#20900469)
    A Good comment posted from the original article:
    7. No License... No Reading by Todd on Oct 8th, 2007 @ 8:41am

    Dear Lawfirm,

    Regarding your recent letter containing copyrighted content, I seem to not have an appropriate license to read your letter. I sure wish I could respond to whatever allegations you claim, but that would require that I read your letter, of which I do not have a proper license to do.

    Sincerely,
    Your Victim
  • by Nymz (905908) on Monday October 08 2007, @12:57PM (#20900507) Journal
    All submissions sent to my email become my property, and reciept of your email shall consitute your acceptance of this agreement. Expect a couter-suit detailing your violation of my copyright, as I do not permit my letters to be sent via email. Thank you.
  • form letter (Score:5, Interesting)

    by Johnny Mnemonic (176043) <mdinsmore @ g mail.com> on Monday October 08 2007, @02:33PM (#20901981) Homepage Journal
    My wife worked in the Claims department of a large rental car company. If you were hit by a rental car of this company, and the driver accepted the insurance at the time of rental, you would contact her to get your claims fulfilled. Yes it sucked. Notice the tense.

    Anyway, she received a letter from an attorney that demanded a response, but stipulated that form letters would not be accepted as legit response.

    She sent a letter, but it was returned with "FORM LETTER REJECTED" stamped all over it, and the lawyer subsequently demanded more communication.

    Which she ignored, because:
    a) it wasn't a form letter;
    b) even it was, the attorney couldn't possibly prove it;
    c) even if he could prove it, you can't dictate the terms of the response as long as it's legally sufficient;
    d) his stamping of the letter provided nice verification that he had received it and read it. He may as well have signed for receipt.

    He kept demanding further response, and she followed up with letters that basically said "see previous".