KeatsGatien LLP Anthony M. Keats, Partner
Emaii: tony@keatsgatien.com
wow, kealsgatien.com
June 29, 2017
President
Kendall + Kylie
101 Japanese Village Plaza
Los Angeles, CA 90012
Re: Kendall + Kylie:
Dear Sir or Madam:
-famous rock-and-
and the estate of Ray
Wners of the copyrights,
trademarks, rights of publicity (including without limi jghts in and to the names,
signatures, photographs, likenesses and iden “ of The Doors) and all
intellectual property with the band and its 1 fer, the “Protected Property”),
ommon law. The Doors are also
ts of which they have retained and
which are protected by federal law, state
the owners of copyrights in numerous p
enforce,
@ by the Lanham Act 15 U.S.C. § 1114
In particular, th
i trademark; 15 U.S.C. § 1125(a) regarding False
et seq. regarding inf
et seq.; Californi
and Professions
of publicity ar
; State statutory right
statutory unfair competit
ition law.
f publicity; California Business
and state common law rights
s of U.S. trademark registrations for the mark THE DOORS
\dard word mark format for t-shirts among other apparel items,
aghied). Your use of the registered trademarks in commerce is likely to cause confusion,
mistake, or to deceive consumers into believing that the Kendall + Kylie apparel was
authorized by The Doors when no such authorization was sought or provided by The Doors.
‘The sale of the infringing apparel bearing the registered trademark of The Doors is
likely to cause confusion, mistake, or to deceive consumers into believing that Kendall + Kylie
is affiliated, connected, or associated with The Doors or that the apparel has been approved ofKendall + Kylie
June 29, 2017
Page 2
or sponsored or originates with The Doors. The sale of the t-shirts was simply an act of unfair
competition under both the federal Lanham Act as well as California's Busines
Professions Code § 17200.
Ata minimum, the gross unauthorized use of the famous THE DOOR:
likely to cause dilution by tarnishment of the famous mark as such use in ¢o1
Kendall Jenner selfie harms the reputation of The Doors, particularly at
fans of The Doors. This damage was already cognizable in the blog
Kendall + Kylie product now found on social media,
In addition to trademark infringement and unfail
Mortison’s post-mortem right of publicity. ‘The supg
over the iconic “Lion” portrait of the late Jim Morr d
failure to recognize the rights of the estate of Mr. Mot the use of his likeness.
of Kendall Jenner
You are hereby put on notice that the
and distribution of the Protected Property to p
to purchase your commercial products cop
ess and to induce consumers
of the above-referenced rights.
Doors and any third parties
rotected Property to advertise,
desist from manufacturing, advertising, and selling the
id that you confirm by telephone or e-mail within twenty-
‘you complied with this demand.
onfirm in writing within seven (7) days that you have immediately and
jnently removed any reference to the Protected Property from your websites,
are locations, if any, and any other marketing or promotional materials,
brochures, catalogs, headings, search functions, ad words and product
descriptions;
3. Identify all advertising materials on which the Protected Property has appeared;
4, Provide a full accounting of all proceeds received from the sale of goods in
connection with your unauthorized use of the Protected Property; and,
5. Immediately recall all of the apparel bearing the Protected Property from all
distributors, wholesalers, and retail outlets.Kendall + Kylie
June 29, 2017
Page 3
Please immediately confirm that you have ceased your unauthorized reproduction,
advertisement, use and distribution of the Protected Property. If we do not receive the
requested immediate confirmation before July 1, 2017, we will recommend that our client
consider taking further take legal action against you.
This letter is not a complete statement of The Doors’ rights in connection with
‘matter, and nothing contained herein constitutes an express or implied waiver of a
reserved.
AMK:dvom
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Akg
Goods and —_IC.009, us|
Services
& S: Musical sound recordings; Musical video recordings.
ISE IN COMMERCE: 19670100
2.28 029 037 038 050. G & S: Posters; Calendars. FIRST USE:
‘COMMERCE: 19680000
9G & S: T-shirts; Hats. FIRST USE: 19680000. FIRST USE IN COMMERCE:
'S, AND/OR NUMBERS IN STYLIZED FORM
Circle figures or designs including semi
MISC Miscellaneous shaped designs
code SHAPES. TRIANGLES Triangular shaped designs and marks including incomplete triangles
77236528
Filing Date July 23, 2007
Current Basis. 1A
inal Filing
Basis uw
roles and incomplete circles
January 8, 2008
Registration
Neos 3401460
March 25, 2008
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Date
Owner (REGISTRANT) The Doors John Densmore, a U.S. citizen; Robby Krieger, a U.S. citizen; Ray
Manzarek, a U.S. citizen; the Estate of James Morrison, a California estate; and the Estate of
Pamela Courson, a California estate PARTNERSHIP CALIFORNIA 8899 Beverly Blvd. Los
Angeles CALIFORNIA 90048
Attorney of
sore ‘Amthony M. Keats
Prior
Registrations 2412706:2576987
Description of Coioris not claimed as a feature of the mark, The mark consists of the stylized words|
Mark Doors,
Type of Mark TRADEMARK
Register PRINCIPAL
Affidavit Text SECT 15. SECT 8 (6-YR).
LiveDead tye
Indicator
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Typed Drawing
Word Mark THE DOORS
Goods and _1C.025. US 022 039. G & S: Clothing, nat
Services 19890900. FIRST USE IN COMME|
Mark Drawing (1) rypcD DRAWING 9
Serial Number 75632268
Filing Date February 1, 199:
Current Basis 1A
Original Filing
Basis
Published for
Internet Browser to
5. T-shirts and hats. FIRST USE
, The the Estate of James Morrison, a California estate; John Densmore, a
Krieger, a U.S. citizen; Ray Manzarek, a U.S. citizen; and the Estate of Pamela
ia estate. PARTNERSHIP CALIFORNIA Penny Lambert Ziffren, Brittenham,
& Fischer 1801 Century Park West Los Angeles CALIFORNIA 900676406
paorrey OF ANTHONY M. KEATS
Type of Mark TRADEMARK
Register PRINCIPAL
Affidavit Text SECT 15. SECT 8 (6-YR). SECTION 8(10-YR) 20120611
Renewal 1ST RENEWAL 20120011
LivelDead
Indicator a
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