Date: Wed, 15 Nov 1995 22:31:13 -0800 (PST)
From: Helena Kobrin <hkk@netcom.com>
Subject: Unauthorized use of copyright and trade secret materials
To: dst+@cs.cmu.edu
cc: postmaster@cs.cmu.edu
Message-ID: <Pine.3.89.9511152257.A13039-0100000@netcom6>
MIME-Version: 1.0
Content-Type: TEXT/PLAIN; charset=US-ASCII


Dear Mr. Tourestzky:

I have just been informed that you again have the so-called
"Fishman affidavit" on your web page which is accessible at
http://www.cs.cmu.edu/~dst/Fishman/Declaration/index.html.

I am putting you on notice on the following:

As you are aware, I represent Religious Technology Center
("RTC"), which is the owner of the confidential Advanced
Technology of the religion of Scientology, and the holder of
exclusive rights under the copyrights applicable to the Advanced
Technology materials.

The Fishman affidavit contains copyrighted and trade secret
materials which you posted onto your Web site without the
authorization of my clients, which, of course, would not have
given such authorization had it been requested.

This posting constitutes violation of the United States Copyright
laws, and also violates trade secret laws.  I therefore demand
that you remove these materials immediately.

You should also be informed, as you might be aware of, that there
are currently pending two separate lawsuits regarding postings of
these same materials in different jurisdictions of the United
States, and a third suit regarding posting of Advanced Technology
materials.  In addition a similar legal action has also been
filed in Holland against some access providers and individuals
that have posted the same documents on their web pages.

We are not seeking to become involved in additional litigation,
but will take all necessary measures to protect these proprietary
materials.  I am sure that your University has no interest in
being an instrumentality of copyright infringement or trade
secret misappropriation.  I will be notifying the University's
attorney.

Please advise as soon as you receive this e-mail what actions you
will take.  This is the second time that you are infringing upon
my client's rights and I therefore must urge you that speed in
dealing with this situation is critical and we will not hesitate
to take immediate actions in case you are not willing to remove
the infringing materials from your site on an immediate basis.

Sincerely,
Helena Kobrin