To: jericho[at]
Date: Thu, 21 Jun 2001 12:43:42 -0500

	RE:	MasterCard/Infringement by

Dear Sirs:

	Your email address was provided to us by Inficad, which is hosting a
web site.  As you probably are aware from the correspondence already
forwarded to you by Inficad, we are the attorneys for MasterCard
International Incorporated ("MasterCard").

	Since at least as early 1998, MasterCard has aired a series of
television and print advertisements that feature the names and/or images of
a series of goods or services purchased by one or more individuals and
which, with either voice-overs and/or other visual displays, convey to the
viewer the price of each of these items (the "MasterCard Priceless
Advertisements"). At the end of each of the MasterCard Priceless
Advertisements a phrase identifying some priceless intangible that cannot be
purchased (such as "a day where all you have to do is breathe") is followed
by the word and/or voice over: "priceless".  Immediately following
"priceless" are the words and/or voice overs: there are some things money
can't buy, for everything else there's MasterCard".  

	Additionally, MasterCard is the owner of  a U.S. service mark
registration for the mark "PRICELESS" (Reg. No. 2,370,508) (the "Priceless
Mark").  Indeed, MasterCard has applied for protection of the Priceless Mark
in numerous countries throughout the world. As a result of MasterCard's
extensive advertising, the Priceless Mark has become associated exclusively
with MasterCard's financial services products. Furthermore, MasterCard owns
multiple U.S. copyright registrations for the Priceless Advertisements. 

	It has come to our attention that you have posted and are
distributing, at the web address, material that
infringes the MasterCard Priceless Advertisements and that further infringes
MasterCard's Priceless Mark.

	This material (the "Infringing Material ") blatantly copies the
sequential display of a series of items belonging to one or more
individuals, showing, the "price" of each item, and, at the end, infringes,
with impunity, the Priceless Mark.

	 In associating this content, which is often obscene, with
MasterCard and its famous Priceless Mark, the Infringing Material infringes
MasterCard's rights under the federal and state trademark and unfair
competition laws, under the federal and state anti-dilution laws, and under
the Copyright Act.  

	We must have your prompt, written assurance no later than June 22,
2001, that you will remove the Infringing Material. Otherwise, MasterCard
will have no choice but to consider legal action.

	We look forward to your prompt reply.

				Very truly yours,
				Jeanne M. Hamburg
				Baker Botts, L.L.P.
				30 Rockefeller Plaza
				New York, New York 10112-4498
				Phone: (212)408-2698
				Fax (212)705-5020

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