www.pillsburylaw.com Patrick J. Jennings Phone: 202.663.8918 [email protected] Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW | Washington, DC 20036-3006 | tel 202.663.8000 | fax 202.663.8007 March 16, 2015 For Settlement Purposes Only Subject to F.R.E. 408 VIA EMAIL Ms. Isis Phoenix 65 Wes 55 th Street, Apt. 7B New York, NY 10019 E-mail: [email protected] and [email protected] Re: Infringement of the Yoga Alliance Trademark Our Ref. 25741-000012 Dear Ms. Phoenix: We represent Yoga Alliance in connection with intellectual property matters. Yoga Alliance is the largest nonprofit association representing yoga teachers, schools, and studios in the United States. You can find more about Yoga Alliance at www.yogaalliance.org. Yoga Alliance owns a federal registration for the trademark YOGA ALLIANCE. This registration, a copy of which is attached to this letter, gives Yoga Alliance the exclusive, nationwide right to use the YOGA ALLIANCE mark in commerce in the United States. Under federal law, no one may use the YOGA ALLIANCE mark without Yoga Alliance’s prior written permission. Yoga Alliance has learned that you are using the Yoga Alliance name on the Web site http://asanaexposed.com/, as per the attached screen shots. This unauthorized use of Yoga Alliance’s federally registered trademark is likely to cause confusion in the marketplace and dilute the distinctiveness the mark. Your use of the Yoga Alliance name also falsely suggests that Yoga Alliance has a connection with you and endorses naked yoga. Yoga Alliance does not wish to be associated with naked yoga and the content on your Web site. For these reasons, Yoga Alliance demands that you: 1. Immediately and permanently stop using the YOGA ALLIANCE trademark and name in any manner whatsoever;

Re: Infringement of the Yoga Alliance Trademark · 2015. 3. 17. · March 16, 2015 Page 2 2. Immediately and permanently remove all references to Yoga Alliance from any and all domains

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Page 1: Re: Infringement of the Yoga Alliance Trademark · 2015. 3. 17. · March 16, 2015 Page 2 2. Immediately and permanently remove all references to Yoga Alliance from any and all domains

www.pillsburylaw.com

Patrick J. Jennings Phone: 202.663.8918

[email protected]

Pillsbury Winthrop Shaw Pittman LLP 1200 Seventeenth Street, NW | Washington, DC 20036-3006 | tel 202.663.8000 | fax 202.663.8007

March 16, 2015

For Settlement Purposes Only Subject to F.R.E. 408 VIA EMAIL

Ms. Isis Phoenix 65 Wes 55th Street, Apt. 7B New York, NY 10019 E-mail: [email protected] and [email protected] Re: Infringement of the Yoga Alliance Trademark Our Ref. 25741-000012 Dear Ms. Phoenix:

We represent Yoga Alliance in connection with intellectual property matters. Yoga Alliance is the largest nonprofit association representing yoga teachers, schools, and studios in the United States. You can find more about Yoga Alliance at www.yogaalliance.org. Yoga Alliance owns a federal registration for the trademark YOGA ALLIANCE. This registration, a copy of which is attached to this letter, gives Yoga Alliance the exclusive, nationwide right to use the YOGA ALLIANCE mark in commerce in the United States. Under federal law, no one may use the YOGA ALLIANCE mark without Yoga Alliance’s prior written permission. Yoga Alliance has learned that you are using the Yoga Alliance name on the Web site http://asanaexposed.com/, as per the attached screen shots. This unauthorized use of Yoga Alliance’s federally registered trademark is likely to cause confusion in the marketplace and dilute the distinctiveness the mark. Your use of the Yoga Alliance name also falsely suggests that Yoga Alliance has a connection with you and endorses naked yoga. Yoga Alliance does not wish to be associated with naked yoga and the content on your Web site. For these reasons, Yoga Alliance demands that you:

1. Immediately and permanently stop using the YOGA ALLIANCE trademark and name in any manner whatsoever;

March 16, 2015 Page 2

www.pillsburylaw.com

2. Immediately and permanently remove all references to Yoga Alliance

from any and all domains and Web sites you may own, operate, lease, control, and/or use;

3. Immediately and permanently refrain from engaging in any activities indicating or suggesting that you have any affiliation or connection with Yoga Alliance or any of its members;

4. Immediately and permanently remove the YOGA ALLIANCE

trademark and any confusingly similar marks from all advertising, banners, bills, billboards, brochures, buildings, business cards, clothing, decals, domain names, e-mails, e-mail addresses, equipment, flags, flyers, invoices, leaflets, letterhead, letters, marketing materials, office materials, patches, pencils, pens, pins, posters, printed materials, retail locations, shipping containers, ships, signs, social networking sites (including but not limited to Facebook, Twitter, and Instagram), stickers, stores, telephone books, trucks, uniforms, warehouses, Web sites, and anywhere else it might appear in association with your business;

5. Immediately destroy all materials bearing the wording “Yoga

Alliance”; and 6. Confirm the foregoing in writing.

We look forward to receiving a response to this letter by March 23, 2015. If we do not hear from you by that date, Yoga Alliance will take all necessary steps to protect its intellectual property rights. This letter is sent without prejudice to any rights or remedies available to Yoga Alliance, all of which are hereby expressly reserved. Regards,

Patrick J. Jennings