From: Hannah Amentler (hannah[at]
To: security curmudgeon (jericho[at]
Date: Thu, 21 Jun 2001 10:01:49 -0700

Here is the first correspondence

Hannah Amentler
General Manager
Inficad Communications
602.265.4423 x125

-----Original Message-----
From: Hannah Amentler [mailto:hannah[at]]
Sent: Monday, June 18, 2001 12:30 PM
To:; pats[at]
Importance: High

Ms. Hamburg.
I am in receipt of your emailed letter dated June 12.
However, your letter is not specific in what content on the
site is actually violating your client's copyrights and/or trademarks.

I have examined many areas of their site and have found no mention of the
Mastercard logo or similar items. I am unable with the current information
to identify what items your letter is referring to.  According to the
Digital Millennium Copyright Act which includes the Online Copyright
Infringement Liability Limitation Act which limits the liability of
Online Service Providers (OSPs) for allegations of contributory
copyright infringement as a result of the OSPs storage of subscriber
materials, you have failed to provide us with enough information to act upon
your request.

My understanding is we are entitled to the following:

(ii) Identification of the copyrighted work claimed to have been
infringed, or, if multiple copyrighted works at a single online site
are covered by a single notification, a representative list of such
works at that site.

(iii) Identification of the material that is claimed to be infringing
or to be the subject of infringing activity and that is to be removed
or access to which is to be disabled, and information reasonably
sufficient to permit the service provider to locate the material.

If you will provide a list or indication of what items on the website are actually in violation of any copyright or
trademark laws I will be happy to look into it and contact the owners of
this site in order for them to comply with your requests.

However, I would point out to you that this website is not hosted by
Inficad, we do not receive and have never received any monetary compensation
from them whatsoever. The website is hosted on a server that
is not owned by Inficad, but by the owners of The only
resource they utilize is Inficad's outbound bandwidth and IP address.  I am
not in control of what content is on their server. The only way I could even
act on this request is to deny their IP address which would shut down their
entire server, not just the material you have requested to have removed.
Inficad has no access to their files or any items on their servers.

I will be happy to help in any other way I can, and will contact the owners
of to see if they have complied.

I look forward to your response.
Thank you,

Hannah Amentler
General Manager
Inficad Communications
602.265.4423 x125

-----Original Message-----
Sent: Monday, June 18, 2001 11:57 AM
To: hannah[at]; pats[at]

Dear Ms. Amentler and Mr. St. John:

Please be advised that unless we receive your immediate confirmation that
the infringing content is removed from pursuant to our June 4
letter and June 12 email, our client will have no recourse but to consider
legal action against Inficad as a contributory infringer under the U.S.
Copyright and Trademark laws.

Jeanne Hamburg
Baker Botts L.L.P.
30 Rockefeller Plaza
New York, NY 10112
(212) 408-2698
fax (212) 705-5020

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