JUDGE TORRES

JS 44C/SDNY REV. 7/2012

CIVIL COVE

U

CV

^504

TheJS-44civil cover sheetandtheinformation contained herein neither replace nor supplement thefiling andservice of

Judicial Conference ofthe United Statesin September 1974, Isrequired for use ofthe Clerk ofCourt for the purpose of
Initiating the civil docket sheet.
PLAINTIFFS

pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the

DEFENDANTS

KANYE WEST and MASCOTTE HOLDINGS, INC.

0DAYCOINS.COM, COINYE-EXCHANGE.COM, NEWCHG.COM,

AMAZON.COM, INC., JAblE-DOES 1 through 50,JOHN DOES 1 through 50,

FNU LNU a/k/a .ION|IY BRAVO and DOGECOIN

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
Brad D. Rose, Dyan Finguerra-DuCharme, Madelon Gauthier, Ryan Klarberg, PryorCashman LLP, 7 Times Square, NewYork, NewYork

ATTORNEYS (IF KNQ.yW

10036 - Telephone: (212) 421-4100 CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OF CAUSE)
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)

Lanham Act Unfair Comp., 15 U.S.C. § 1125(a); Cybersquatting, 15 U.S.C. § 1125(d)
Has this or a similar case

been previously filed in SDNY at any time? No
Invol. n Dismissed
NO

[X

Yes

7J Judge Previously Assigned
& Case No.

If yes, was this case Vol. n

NoD Yes • M Yes •

If yes, qive

date

IS THIS AN INTERNATIONAL ARBITRATIONCASE?

(PLACE AN[x] IN ONEBOXONLY)
TORTS

NATURE OF SUIT
ACTIONS UNDER STATUTES

CONTRACT

PERSONAL INJURY INSURANCE
MARINE MILLER ACT

PERSONAL INJURY

FORFEITURE/PENALTY

BANKRUPTCY

OTHER STATUTES

[1110 []120 11130 [1140 11150

[ ] 310 AIRPLANE [ J315 AIRPLANE PRODUCT
LIABILITY

[ ] 362 PERSONAL INJURY MED MALPRACTICE

[1610 [ ]620 11625

[ ] 365 PERSONAL INJURY
PRODUCT LIABILITY

AGRICULTURE OTHER FOODS DRUG
DRUG RELATED

[ J422 APPEAL ' 28 USC 158 [ ]423 WITHDRAWAL
28 USC 157

[ I 400

STATE REAPPORTIONMENT

[]151 11152

NEGOTIABLE INSTRUMENT RECOVERY OF OVERPAYMENT & ENFORCEMENT OF JUDGMENT MEDICARE ACT RECOVERY OF DEFAULTED

[ ]320 ASSAULT, LIBEL & [ J 330
SLANDER FEDERAL

[]368

ASBESTOS PERSONAL
INJURY PRODUCT
LIABILITY

SEIZURE OF PROPERTY
21 USC 881

EMPLOYERS'

PROPERTY RIGHTS

1)410 ANTITRUST 1)430 BANKS & BANKING 1 1450 [ M60 DEPORTATION [1470 RACKETEER INFLU
ENCED & CORRUPT ORGANIZATION ACT

I I 340 [ J 345

LIABILITY MARINE

PERSONAL PROPERTY

MARINE PRODUCT
LIABILITY

STUDENT LOANS

[ J 350 [ ]355 MOTOR VEHICLE

MOTOR VEHICLE

[ ] 370 OTHER FRAUD [ ] 371 TRUTH IN LENDING [ ] 380 OTHER PERSONAL
PROPERTY DAMAGE

[ [ [ [

]630 ]640 1650 ]660

LIQUOR LAWS RR & TRUCK
AIRLINE REGS

[ ]690

OCCUPATIONAL SAFETY/HEALTH OTHER

[ ] 820 COPYRIGHTS [ ] 830 PATENT XI 840 TRADEMARK
SOCIAL SECURITY

(RICO)
1 1480 [ J 490 11810 [ J 850
CONSUMER CREDIT

CABLE/SATELLITE TV SELECTIVE SERVICE
SECURITIES/

(EXCL VETERANS)
[ I 153
RECOVERY OF OVERPAYMENT BENEFITS

PRODUCT LIABILITY

[ J 360 OTHER PERSONAL
INJURY

[ ] 385 PROPERTY DAMAGE
PRODUCT LIABILITY
LABOR

[ ] 861 HIA (1395ft)

[ ) 862 BLACKLUNG (923)
1 1710 [ J720
PRISONER PETITIONS
FAIR LABOR

[I 875

CUSTOMER

[]160 [J190 1)195

STOCKHOLDERS SUITS

STANDARDS ACT LABOR/MGMT RELATIONS
LABOR/MGMT

[ ]864 SSID TITLE XVI
[ J865 RSI (405(g))
FEDERAL TAX SUITS

[ ] 863 DIWC/DIWW (405(g))

CHALLENGE
12 USC 3410

(, xy

M-J<]890

OTHER STATUTORY
ACTIONS

[ 1730
CONTRACT
PRODUCT

[ ]510
ACTIONS UNDER STATUTES
CIVIL RIGHTS

MOTIONS TO
VACATE SENTENCE
20 USC 2255

REPORTING & DISCLOSURE ACT

11891 AGRICULTURAL ACTS [ ] 892 ECONOMIC
STABILIZATION ACT

LIABILITY

[ 1 196

FRANCHISE

i

REAL PROPERTY

[1441 VOTING []442 EMPLOYMENT [ I 443 HOUSING/
ACCOMMODATIONS

[ ] 530 HABEAS CORPUS [ ] 535 DEATH PENALTY [ J 540 MANDAMUS&OTHER [1791

[1740 [1790

RAILWAY LABORACT [ ]870 TAXES (U.S. Plaintiffor
OTHER LABOR
LITIGATION

[ J 893 ENVIRONMENTAL
MATTERS

Defendant)

[ ] 871 IRS-THIRD PARTY
26 USC 7609

[I 894

ENERGY

EMPL RET INC SECURITY ACT

ALLOCATION ACT

[ ] 895

FREEDOM OF INFORMATION ACT DETERMINATION UNDER EQUAL

IMMIGRATION

[ ]900 APPEAL OF FEE

j
J J
;

11210
[]220 [ I 230
[ I 240 [ ) 245

LAND

CONDEMNATION FORECLOSURE RENT LEASE & EJECTMENT
TORTS TO LAND

[ J 444 WELFARE [ ) 445 AMERICANS WITH
DISABILITIES EMPLOYMENT

PRISONER CIVIL RIGHTS

[I 462

NATURALIZATION
APPLICATION

[ ] 550 CIVIL RIGHTS [ ] 555 PRISON CONDITION

[1463
11485

[ ]446 [ J 440

AMERICANS WITH

TORT PRODUCT LIABILITY
ALL OTHER REAL PROPERTY

DISABILITIES -OTHER OTHER CIVIL RIGHTS

HABEAS CORPUSALIEN DETAINEE OTHER IMMIGRATION
ACTIONS

[ I 950 CONSTITUTIONALITY
OF STATE STATUTES

(Non-Prisoner)

[ J 290

Check if demanded in complaint:

CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23

DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING INS.D.N.Y.?
IF SO, STATE:

DEMAND $_

OTHER

JUDGE

DOCKET NUMBER_

Check YES only if demanded in complaint

JURY DEMAND: S YES • NO

NOTE: Please submit at the time of filing an explanation of whycases are deemed related.

(PLACE AN x IN ONE BOX ONLY)

ORIGIN

a n, , , 1 Original
Proceeding

r—i „ • 2 Removed from
state court

n-3„ JJl_l4 Reinstated or U 3 Remanded ^ H*™f° or Reopened
from

L~] 5 Transferred from • 6 Multidistrict ^ tMhiMMl Litiaation Litigation (SpecifyDistrict)

[] 7 Appeal toDistrict
Judge from Magistrate Judge Judgment

I | 3. all parties represented

Appellate
Court

| | b. At leastone
party Is pro se.

(PLACE AN x IN ONE BOX ONLY) BASIS OF JURISDICTION ["I 1 US PLAINTIFF • 2 U.S. DEFENDANT M 3 FEDERAL QUESTION D4 DIVERSITY
(U.S. NOTA PARTY)

IF DIVERSITY, INDICATE
CITIZENSHIP BELOW.

(28 USC 1332,1441)

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
(Place an[X] in one box for Plaintiff and one box for Defendant)
PTF DEF

CITIZENOF THIS STATE CITIZEN OF ANOTHER STATE

[ ]1 [ ]2

[ ]1 [ ]2

CITIZEN OR SUBJECT OF A FOREIGN COUNTRY

[13 [13

PTF DEF

INCORPORATED andPRINCIPAL PLACE
OF BUSINESS IN ANOTHER STATE
FOREIGN NATION

[ ]5 [ ] 5
[]6 []6

PTF DEF

INCORPORATED or PRINCIPAL PLACE
OF BUSINESS IN THIS STATE

[ ]4 [ ]4

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)

Mascotte Holdings, Inc., 1755 Broadway, 3rd Floor, New York, New York 10019

KanyeWest

,„««.,«

DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES) Amazon.com, Inc.

Corporation Service Company - Attn: Legal Department

300 Deschutes Way SW, Suite 304
Tumwater, WA 98501

DEreTOKENTATON S^^^THAT. AT THIS TIME, IHAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE
RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:

0DAYCOINS.COM, COINYE-EXCHANGE.COM, NEWCHG.COM, JANE DOES 1through 50, JOHN
DOES 1 through 50, FNU LNU a/k/a JONNY BRAVO, and DOGECOIN

Check one- THIS ACTION SHOULD BE ASSIGNED TO:
DATE 1/13/2014 SIGNATURE OF ATTORNEY OF RECORD

(DO NOT check either box if this aPRISONER PETITION/PRISONER CIVIL RIGHTS COMPLAINT.)

• WHITE PLAINS

g] MANHATTAN
Yr. 1986 )

ADMITTED TO PRACTICE IN THIS DISTRICT [ 1 NO

[X] YES (DATE ADMITTED Mo. 2

RECEIPT #

Attorney Bar Code # 2037596
•n

Magistrate Judge isto be designated by the Clerk ofthe
Magistrate Judge .

is so Designated.

Ruby J. Krajick, Clerk of Court by.

Deputy Clerk, DATED.

UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)

rurr JUDG

Tj

Brad D. Rose (BR-2740)
Dyan Finguerra-DuCharme (DF-9228) Madelon A. Gauthier (MG-4687) Ryan S. Klarberg (RK-4719) Pryor Cashman LLP 7 Times Square
New York, New York 10036

*

•*• JC

9 * a

Attorneysfor Plaintiffs Kanye West and Mascotte HoldingSj.,Inc.
IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

KANYE WEST and MASCOTTE HOLDINGS, INC.,

Plaintiffs,
Civil Action No.

- against COMPLAINT

0DAYCOINS.COM, COINYE-EXCHANGE.COM, NEWCHG.COM, AMAZON.COM, INC., JANE DOES

1 through 50, JOHN DOES 1 through 50, FNU LNU
a/k/a JONNY BRAVO, and DOGECOIN,

DEMAND FOR JJUR^ TRIAL p a? Zn-r.
z
r<

CO

Defendants.

3

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Plaintiffs Kanye West and Mascotte Holdings, Inc. (collectively, "Mr. West" or "Plaintiffs"), by their attorneys Pryor Cashman LLP, allege as follows against Defendants

0daycoins.com, Newchg.com, Coinye-exchange.com, Amazon.com, Inc., Jane Does 1 through 50 (the "Contributory Defendants"), John Does 1 through 50 (the "Defendants"), FNU LNU
a/k/a Jonny Bravo and Dogecoin:
NATURE OF ACTION

1.

This is an action for willful trademark infringement, unfair competition, dilution

and right of publicity violations, among a score of other blatant statutory and common law
violations. Defendants have willfully and admittedly traded upon the goodwill and notoriety of
Kanye West, one of the most famous entertainers and brand names in the world. Without

1291304 vl5 10859.00017

hesitation, Defendants have usurped Mr. West's name and likeness for the sole purpose of
propping up the perceived "value" of the Defendants' "digital coin mine" and its

"cryptocurrency."' In interviews with the press, Defendants brazenly admit that they adopted
the marks COINYE WEST, COINYE and COYE to directly associate their newly minted cryptocurrency with Mr. West. For example, Defendants have publicly stated that: (i) they

"chose to represent Kanye because he is and always has been a trendsetter, and he's always

keeping things unique;" and (ii) they were "really not sure how Kanye [was] gonna react." Moreover, Defendants cowardly remained anonymous because "[Kanye West] really
isn't someone we want to piss off and that they would "love if Kanye named dropped 'Coinye' . . . We don't want to pay him off to name check us, but it'd be sick if he does so."

Defendants also boldly asserted that "Anarcho-capitalism is coming, it can't be stopped. Whether
it has a symbol that looks like a dollar, a dog, or a cartoon picture of a rapper, it's all the same thing." True and correct copies of online articles quoting Defendants are attached hereto as
Exhibit A.

On January 7, 2014, Defendants had an initial public offering of a "block" of

cryptocurrency called, interchangeably, COINYE WEST, COINYE and COYE on their website located at <coinyeco.in>. Although Defendants could have chosen any name for their

cryptocurrency, they deliberately chose to trade upon the goodwill associated with Mr. West by

adopting names that are admitted plays on his name. Mr. West has been inextricably tied to Defendants' cryptocurrency, as practically every online article and blog post about the COINYE
WEST currency mentions Mr. West and/or displays a photograph of Mr. West.

1"Cryptocurrency" or"bitcoins" is a digitized monetary exchange not tied to a specific country or centralized bank.
The value is determined by supply and demand - it only has value if consumers "mine" the currency and exchanges
trade it.

1291304 vl5

10859.00017

2

With each day that passes, Mr. West's reputation is irreparably harmed by the continued
use of the COINYE WEST, COINYE and/or COYE marks in connection with Defendants'

goods and services. Defendants have admittedly and willfully infringed upon the KANYE WEST mark and consumers are likely to mistakenly believe that Mr. West is the source of these

digital coins. In fact, consumers are actually confused and mistakenly believe that Mr. West has
launched the COINYE WEST cryptocurrency as reflected in dozens of tweets posted on Twitter:
Samantha Grossman @sam_grossman 2 Jan: Forget Bitcoin, because Kanye West now has a cryptocurrency and obviously it's called Coinye West

Romesh Dodangoda @longwaveromesh 2 Jan:
Kanye West now has a currency!

Christopher Hudson @chrishudsonjr 2 Jan:
Move over UBitcoin, (fbhanyewest now has his own cryptocurrency
called (S),CoinveWest

Andrew Harris @amharris26 2 Jan:
Interest rates are at an all-time low. RT (cbpbwax Kanye West has his

own cryptocurrency and it's called Coinye West

Chase Graves @everettchase 2 Jan: Move over bitcoin, (cbkanyewest is about to create the greatest digital currency ofall time. Introducing: (jcbCoinyeWest. Mathew Ingram @mathewi 2 Jan:
shark = jumpedMT(cbjcschweitz: (a>KanyeWest now has his own

cryptocurrency, and it's called Coinye West

Candace Jackson @candaceJackson 2 Jan: Kanye West is getting his money right, launching his own bitcoininspired cryptocurrency. It's called Coinye West Eric Andersen @eric_andersen 2 Jan: Srsly? (cDJtanvewest creates his own cryptocurrency, names it Coinye
West, on Twitter at (a),CoinyeWest

Ashley Codianni @AshleyCodianni 2 Jan: Forget #Bitcoin, lemme get some Coinye West —> Kanye West now has his own cryptocurrency

1291304 vl5 10859.00017

Joshua Topolsky @joshuatopolsky 2 Jan: Kanye West Bitcoin clone to launch soon. Coinye West!

Pat McKlindon @PatMcPSU 2 Jan:
Speaking of "coining" and wordplay. Kanye Westjust made his own version ofBitCoin and named it "Coinye West"

Noah Hirsch @noahsh2 2 Jan: Is Kanye serious? He's staring his own online currency like bit-coin.
It's called Coinye-West

Marxs @marxsismo 2 Jan: Kanye Westgets his own digital currency, and it's called Coinye West// Bigger than Yeezus Francisco Dao @TheMan 2 Jan: Bitcoin is FINISHED!!! - Kanye West now has his own cryptocurrency and it's called Coinye West West Coast Sound @LAWeeklyMusic 2 Jan: All about the new Kanye Westcurrency, which is like Bitcoin but called
CoinYe

Gavin Millard @gmillard 2 Jan: Kanye WestNow Has His Own Cryptocurrency and It's Called Coinye
West. WTF.

BBC Radio lXtra @lXtra 5 Jan: Oh Yeezus. Not even kidding you (a)J(anvewest is going to have his own CURRENCY, the "Coinye West" Simon Kratschmer @Bimon 6 Jan: The cryptocoin to end them all: "Coiny West" - the Kayne West Coin These are just a sampling of the tweets and evidence of actual confusion to date. See infra at If 55 (additional tweets evidencing actual confusion). Accordingly, for the reasons set forth

herein, the Defendants must be held accountable for these egregious, willful and wanton
activities.
PARTIES

2.

Plaintiff Kanye West is a citizen and resident of the State of New York.

1291304 vl5
10859.00017

3.

Plaintiff Mascotte Holdings, Inc. is a California corporation with its principal

place of business in New York, New York.

4.

Defendant 0daycoins.com operates a digital currency exchange located at

<0daycoins.com> and is engaged in commerce in the United States including within this judicial district. There is no contact information provided on the <Odaycoins.com> website. Defendant Odaycoins.com shields its contact information by using a privacy service provided by the
registrar. Plaintiffs believe that information obtained in discovery will lead to the identification of contact information for Defendant Odaycoins.com.

5.

Upon information and belief, Defendant Coinye-exchange.com operates a digital

currency exchange located at <coinye-exchange.com> and is engaged in commerce in the United
States including within this judicial district. There is no contact information provided on the

<coinye-exchange.com> website.

Defendant Coinye-exchange.com shields its contact

information by using a privacy service provided by the registrar.

Plaintiffs believe that

information obtained in discovery will lead to the identification of contact information for
Defendant Coinye-exchange.com. 6. Defendant Newchg.com operates a digital currency exchange located at

<newchg.com> and is engaged in commerce in the United States including within this judicial

district.

The only contact information provided on the <newchg.com> website is an email

address of rozenbal@emeto.eu. Defendant Newchg.com shields its contact information by using
a privacy service provided by the registrar. Plaintiffs believe that information obtained in

discovery will lead to the identification of contact information for Defendant Newchg.com.

1291304 vl5 10859.00017

7.

Defendant Amazon.com, Inc. is a Delaware corporation with its principal place of

business in Seattle, Washington. Amazon.com, Inc. does business in this district through its dayto-day operations and through its highly-interactive website. 8. The true names and identifies of Defendants Jane Does 1-50 ("Jane Does

Defendants") are unknown to Plaintiffs. The Jane Does Defendants include, but are not limited

to: servers, web host companies, cryptocurrency exchanges, cryptocurrency "mining" service

providers, cryptocurrency payment processors, vendors of cryptocurrency, operators of cryptocurrency "wallets", retailers accepting and/or facilitating the exchange of cryptocurrency,
marketers promoting cryptocurrency, operators of cryptocurrency ledgers, "miners" of

cryptocurrency, their respective web hosts, registrars and servers and each of their heirs, executors, administrators, successors, licensees, assigns, subsidiaries, parents, affiliates, divisions, co-venturers, partners, officers, directors, employees, agents, shareholders, managers, business managers, accountants, attorneys, representatives, consultants and any and all other persons,
corporations or other entities acting under the supervision, direction, control or on behalf of any

of the foregoing who make use of the COINYE WEST, COINYE and/or COYE marks.

9.

Upon information and belief, Defendant FNU LNU a/k/a Jonny Bravo ("Bravo")

is a programmer for the <coinyecasino.com> and <coinyecasino.l8.1v> websites. Bravo is engaged in commerce in the United States including within this judicial district. The only

contact information provided on the <coinyecasino.com> website is an email address of support@coinyecasino.com. Bravo shields his contact information by using a privacy service
provided by the registrar. Plaintiffs believe that information obtained in discovery will lead to
the identification of contact information for Bravo.

1291304 vl5 10859.00017

10.

Upon information and belief, Defendant Dogecoin ("Dogecoin") is the operator,

registrant and/or host of the following websites: <minecoinye.com>, <coinyemining.com>,
<coinyegames.com>, <buycoinye.net>, <coinyeroulette.com>, <coinyedice.com>, <coinyewallet.com>, <buy-coinye.com>, <coinyegambling.com>, <getcoinye.com>, <coinyestore.com>, <betcoinye.com>, <coinyepoker.com>, <buycoinyes.com>, <coinyespin.com>, <coinye-dice.com>, and

<coinyeshop.com>,

<freecoinye.com>,

<fuckcoinye.com>. Dogecoin is engaged in commerce in the United States including within this
judicial district. There is no contact information provided on the above-referenced websites. Dogecoin shields its contact information by using a privacy service provided by the registrar.

The only contact information provided from the Whois report is: dogecoincom@obscure.me.
Plaintiffs believe that information obtained in discovery will lead to the identification of contact
information for Dogecoin.

11.

The true names and identities of Defendants named herein as John Does 1 through

50 are unknown to Plaintiffs. Upon information and belief, Defendants operate Internet websites

located

at

<coinyewest.com>,

<coinyeco.in>,

<coinyefaucet.com>,

<coinyechain.info>,

<coinyecoin.org>, <coinyecoin.com> and <buycoinye.com>.

Defendants are engaged in
The only contact

commerce in the United States including within this judicial district.

information provided on the websites are the following email addresses: coinyewest@gmail.com;
contact@buycoinye.com; and coinyecoin@outlook.com. Defendants also shield their contact
information by using a privacy service through the registrars. Plaintiffs believe that information
obtained in discovery will lead to the identification of each Defendant's true names and will

permit Plaintiffs to amend this Complaint to state the same.

1291304 vl5 10859.00017

JURISDICTION AND VENUE

12.

Jurisdiction is proper in this Court pursuant to 15 U.S.C. § 1121 and 28 U.S.C. §§

1125, 1332, 1338(a) and 1367, because the action involves claims arising under the Lanham Act
and related state law claims.

13.

This

Court has personal jurisdiction over Defendants and Contributory

Defendants because they are doing business in New York, the claims at issue arise out of their transaction of business and/or supplying goods and services directed to consumers residing in
New York. These activities fall within the long-arm statute of the State of New York, CPLR
§ 302(a)(1).

14.

Venue is proper in this District pursuant to

28 U.S.C. § 1391 because all

Defendants and Contributory Defendants are subject to personal jurisdiction in this District
because they are transacting business and committing tortious acts within the State of New York
and this District. FACTS GIVING RISE TO THIS ACTION

A.

Plaintiff Kanye West's Fame and Success

15.

Mr. West is an internationally renowned musical artist, performer, media

company owner, inventor, songwriter, producer, film director and fashion designer. Mr. West

first rose to fame as a producer for Roc-A-Fella Records, where he achieved recognition in 2001

for his work on Jay-Z's album The Blueprint, as well as on hit singles for musical artists
including Alicia Keys, Ludacris and Janet Jackson. To date, Mr. West has released seven full-

length studio albums, and has sold over 30 million digital songs in the United States, making him
one of the best-selling digital artists of all-time.

1291304 vl5 10859.00017

16.

Mr. West's first five albums, all of which have gone platinum, have received

numerous awards, including twenty-one Grammy® Awards. Mr. West was ranked by Billboard magazine as one of the top 10 music producers of the decade, and was ranked third in BET's

"Top Ten Rappers of the 21st Century" list. These are just a few of the industry awards and
accolades that Mr. West has earned.

17.

Mr. West's talent and notoriety is recognized around the world.

He has been

named one of the 100 most influential people by Time magazine, and Forbes routinely lists Mr. West as one of the most successful people in the world. Mr. West is credited with refocusing rap from hardcore-gangster themes to more personal messages. Mr. West's themes and styles have had a major impact on new artists such as Drake, Kid Cudi and Lupe Fiasco, and he is recognized as transforming the hip hop industry making it more accessible to the public at large.
18. In 2013, Mr. West released Yeezus, his sixth studio album, which debuted at

number one on the Billboard 200. Yeezus sold 327,000 copies in its first week of release and topped the charts of 30 other countries, including the United Kingdom and Australia. Within

months of its release, the Yeezus album was certified platinum by the RIAA. 19. Mr. West's Yeezus album was praised as the "Best Album of 2013" by multiple

news sources, including, but not limited to, Time Magazine, NPR, Complex, MTV, Entertainment Weekly and The New York Post. The album was described as "transformative" by

MTV stating that Yeezus "has dominated the discussion for the majority of the year" and is "the
most confrontational, controversial and confounding release of 2013." Google even named

Yeezus the album of the year and offered a limited number of free downloads to subscribers. True and correct copies of these rankings are attached hereto as Exhibit B.

1291304 vl5 10859.00017

20.

His notoriety expands well beyond the world of music, and Mr. West sets trends

for everything he touches. He has launched his own clothing lines, designed sneakers with major footwear companies, and even designed high-end shoe lines for Louis Vuitton and Giuseppe
Zanotti. Mr. West has also appeared in several films and television programs.
21. Mr. West is the source of widespread unsolicited media attention wherever he

goes. He has adorned the cover of dozens of magazines and has been the subject of hundreds of

articles including in The New York Times, Rolling Stone, Spin, Details, GQ, Time, Vibe, Complex,
among many others. Indeed, Mr. West has also been interviewed hundreds of times on television

and on the radio over the past decade.

22.

Few artists have acquired the fame achieved by Mr. West. The widespread

unsolicited media attention that Mr. West receives on a daily basis has made Mr. West a
household name.

B.

Plaintiffs' Use of KANYE WEST® and Other Trademarks

23.

Plaintiffs have used the KANYE WEST mark in connection with a wide variety

of goods and services since at least as early as February 2004. Plaintiffs own numerous federal trademark registrations for the KANYE WEST mark throughout the world including six in the
United States.

24.

Specifically, Mr. West owns U.S. trademark registrations for the KANYE

WEST® mark for the following goods and services: Class 9 musical sound recordings; audio visual recordings, namely, compact discs, tape cassettes, audio cassettes, audio tapes, audio discs,
records, CD-Roms, video tapes, video cassettes, video discs, DVDs, DATs, MP3s, and laser

discs, all featuring music; downloadable musical sound recordings; downloadable video recordings featuring music; and sunglasses (Reg. No. 3,648,799); Class 16 posters, photographic

1291304 vl5

10859.00017

10

prints and photographs (Reg. No. 3,648,800); Class 25 clothing, namely, t-shirts, tank tops, and
sweat shorts (Reg. No. 3,648,801); Class 26 ornamental novelty buttons (Reg. No. 3,648,802); Class 35 on-line ordering services and on-line retail store services, electronic retailing services

via computers, and retail store services available through computer communications, all of the
aforesaid featuring recorded product, music related items, clothing and accessories therefor, printed promotional matter such as posters, books and publications, novelty items and ornaments

(Reg. No. 3,648,803); and Class 41 music composition and transcription for others;
entertainment in the nature of a live musical performer, musical band or musical group;

entertainment in the nature of live performances by a musical artist, musical group or musical band; entertainment in the nature of visual and audio performances by a musical artist, musical

group and musical band; entertainment, namely, live music concerts; entertainment, namely,
personal appearances by a musician, musical group or musical band; entertainment services, namely, providing a web site featuring musical performances, musical videos, photographs, and
other multimedia materials; entertainment services, namely, providing prerecorded music, all

online via a global computer network; and entertainment in the nature of traveling tours featuring music (Reg. No. 3,648,804). True and accurate copies of the U.S. registrations for the KANYE
WEST mark are attached hereto as Exhibit C.

25.

Mr. West also owns several pending U.S. trademark applications, including, but

not limited to, Serial Nos. 86/052,406, 86/052,382, 86/052,394, 86/052,418, 86/052,376, and
86/052,433 for the CLOTHING BY KANYE WEST mark.

26.

The KANYE WEST brand is a strong commercial success. In particular, goods

and services offered for sale in connection with the KANYE WEST mark have generated sales in

the hundreds of millions of dollars. Mr. West is immensely popular with the general public as

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evidenced by, inter alia, his over 10.1 million Twitter followers, over 13 million "likes" for his

Facebook page, and a regularly updated extensive Wikipedia page dedicated to him.
27. Mr. West has invested significantly in creating, maintaining and promoting the

goodwill associated with the KANYE WEST mark. Mr. West and his media, Internet and

fashion partners have spent millions of dollars advertising and promoting goods and services offered in connection with the KANYE WEST mark throughout the world. In addition to

traditional advertising, Mr. West markets and promotes his products and services through social
media platforms such as Facebook, Twitter and YouTube.

28.

As a result of Mr. West's extensive sales, advertising and promotional efforts, and

his consistent production of high quality goods and services, the KANYE WEST mark is famous and has garnered goodwill of incalculable value. The KANYE WEST mark is recognized and relied upon by the consuming public as indicating one source: Mr. West.
C. The Advent of Digital Cryptocurrency

29.

"Bitcoin," as used herein, is a descriptive term for digital currency that uses

cryptography to control the production and exchange of money. It is a decentralized currency

that does not have a bank, government or a central issuer. Instead, Bitcoin operates as a peer-topeer network to control the creation and issuance of new "bitcoins," regulate transactions of the

virtual currency and monitor the security of the Bitcoin network.2 Bitcoin is denominated a
"virtual currency" not backed by metal or paper, but is the result of a cryptographic process that applies computational power to decipher chains of unique computer code. These chains of codes

are then issued as a block of twenty-five bitcoins and can be exchanged, purchased and sold for
non-virtual currency such as U.S. dollars or Euro. Bitcoins have market value because of their

Typically bitcoin currency is spelled with lowercase while Bitcoin capitalized refers to the protocol and transaction
network.

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scarcity: the amount of bitcoins that will be produced is limited according to a pre-determined
mathematical algorithm. The trading price of bitcoins has fluctuated from $80 in July 2013 to a high of $1100 in December 2013. Currently, the value of a new bitcoin is approximately $1000.
As of November 2013, there were approximately 12 million bitcoins in existence, resulting in a
total market capitalization of the currency in excess of $10 billion.

30.

The Bitcoin peer-to-peer network allows users to access an open-source computer

program to which they may apply computational programs and hefty computing power to
compete to solve difficult mathematical problems. The solution to one of these complex problems, or the cracking of the code, results in the reward of a newly "minted" bitcoin issued to

the individual who processed that search. Bitcoin currency is produced by these "miners" who use powerful computers to sort through this mathematical space searching for numbers that fit
the algorithm. This process is called "mining," likening the computational quest to a gold miner
searching for a vein within a physical mine. The work the computers do can be viewed in

parallel to guessing at a lottery number: the faster the searching computers run, the better chance of guessing the right number and winning the coins. Bitcoin mining can be done on home

computers, but as the value and interest in the currency has increased, a virtual mining industry

using powerful multi-million dollar computers has emerged. 31. Since using an individual computer may take months to solve the block to

generate bitcoins, individuals may join groups known as "mining pools" to collectively work to
solve the blocks and distribute rewards (bitcoins) based on the work contributed. Once mined,

miners and users may store their bitcoins in a bitcoin wallet. Bitcoin wallets currently consist of four types: (1) software wallet, which is located on a computer; (2) mobile wallet, which is
located on a mobile device; (3) a digital wallet, that is hosted by an online service provider that

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hosts bitcoins; or (4) a paper wallet, that consists of the public and private keys on printed paper
that is stored offline.

32.

Bitcoin uses a public-key cryptography, in that it uses a "public key" which is a

unique address and a "private key" which is the unique identifier of that address, or a signature
for the bitcoin holder. If this private key is lost, a bitcoin is lost forever. To perform a bitcoin

transaction, the public key assigned to the bitcoin address is signed by the private key. The

public key is published to the blockchain, which records all transactions on the bitcoin network,
and miners verify that the public key and private key are associated with the bitcoin address. 33. Bitcoins can be purchased and traded through various web exchanges, such as

Cryptsy and Mt. Gox, whereby a user exchanges a bitcoin with a fiat currency (also known as a

government backed currency like U.S. dollars or Euro) or vice-versa, or exchanges between
bitcoins and other digital currencies known as "alt-currencies." Alt currencies use similar opensource software but distinct mining protocols and algorithms to generate new and different

cryptocurrencies. The exchanges allow for investors to hedge on the bitcoin and alt currency
value and miners enter the race to earn more of the ever-dwindling amount of bitcoin in the
universe - banking on an increase in their value.

34.

Bitcoin was the first of the decentralized peer-to-peer network protocols called a

cryptocurrency and is known as the gold standard. Other competing cryptocurrencies using

similar open-source software but distinct mining protocols and algorithms have followed Bitcoin
in the past few years. These competitors view the success and rapid increase in value of bitcoin
and are speculating on the currency's potential for a larger retail component. 35. Because the code that underpins bitcoin is under an open-source license, any

individual with programming knowledge may become a miner, accessing the code to alter its

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aspects to create an entirely new currency, for free. There are over 150 new digital currencies
attempting to compete with Bitcoin, some in earnest and some as marketing ploys. As the creator of the mining algorithm, a new alt-currency founder can retain a certain amount of the

newly minted currency in a process known as "pre-mining," essentially hoarding it until the value increases. It has been suggested that such networks create a "pump and dump" scheme
luring investors to mine the new coins and profiting once the currency gains acceptance and is
widely traded.
D. Defendants' Illegal Activities

36.

While bitcoins are not yet widely accepted as a form of retail payment, their

appeal is gaining traction. For example, Overstock.com announced that it will start accepting the
virtual currency this year. The entertainment industry, and the music industry in particular, is also beginning to recognize cryptocurrency as a form of payment. For example, Mel B, former
Spice Girl and X-Factor judge, has announced that consumers may use bitcoins to purchase her
new single, and Snoop Dogg recently tweeted that he wants his "next record available in bitcoin."

37.

In a deliberate attempt to profit from the goodwill associated with Mr. West and

the KANYE WEST brand and to "pump" up the value of its newly released cryptocurrency,
Defendants are marketing, promoting, exploiting and/or mining cryptocurrency from websites

located

at

<coinyewest.com>,

<coinyeco.in>,

<coinyefaucet.com>,

<buycoinye.com>,

<coinyecoin.org>, <coinyecoin.com>, and <coinyechain.info> (the "Infringing Websites"). In particular, on December 29, 2013, Defendants launched a website located at <coinyewest.com> and indicated their intention to offer a block of COINYE WEST coins for mining. The <coinyewest.com> domain was later redirected to <coinyeco.in> from which Defendants are
currently marketing and promoting their alleged digital coins. Defendants have specifically

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stated that their "goal with COINYE WEST is to make it easier for people to use cryptocurrency."
See Ex. A.

38.

The COINYE WEST, COINYE and COYE marks are substantially similar in

sight, sound, meaning and commercial impression to the KANYE WEST mark. Defendants use

the COINYE WEST, COINYE and COYE marks to solicit investors and to falsely imply that Mr.
West is affiliated with, associated with and/or has endorsed the COINYE WEST

cryptocurrency. In fact, the developers have admitted that they intended to trade upon the

goodwill associated with the KANYE WEST mark and with Mr. West personally when they
adopted the COINYE WEST, COINYE and COYE marks. See f 1 & Ex. A.

39.

The Infringing Websites feature coins that resemble Mr. West wearing his

signature shutter shades sunglasses below the COINYE mark:

40.

The <coinyewest.com> website also unlawfully exploited videos embodying the

masters and the underlying compositions of Mr. West's videos. The use of the image above and Mr. West's videos heighten the likelihood that consumers would mistakenly believe that Mr. West is associated with, has sponsored or is affiliated with Defendants' goods and
services. These actions also dilute the famous KANYE WEST trademark and violate Mr. West's

right of publicity.

41.

In a further attempt to trade upon the goodwill of the KANYE WEST brand, and

as additional evidence of Defendants' willfulness, Defendants emailed Plaintiffs' agents

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requesting "[A] few second video of [Mr. West] telling us he wants coinyes." In the same
January 4, 2014 email chain, Defendants wrote:

I'm not talking on any telephone and neither is anyone else involved. If you want to talk,
contact me in email. We're anonymous and we're keeping it that way. Also, I'm not

giving up a single millionth of a percent until i get some kind of verification that kanye actually knows a deal is being made. I still don't trust you, and I sure as hell don't trust
lawyers.

A true and correct copy of this email exchange is attached hereto as Exhibit D.

42.

In response to this inquiry, Mr. West's counsel sent a letter to Defendants

demanding that they deactivate the Infringing Websites and refrain from any further infringing
conduct. A true and accurate copy of the letter sent to Defendants, dated January 6, 2014, is
attached hereto as Exhibit E. Instead of complying, Defendants published the demand letter on

blogs and, upon information and belief, provided the letter to various media outlets, thereby
making Defendants' conduct the subject of widespread media attention, including articles on the
Wall Street Journal blog and the Time Magazine blog as well as online versions of national

papers such as The New York Post. A true and correct copy of the media attention associated
with Defendants' receipt of the demand letter is attached hereto as ExhibitF.

43.

In willful disregard of Mr. West's intellectual property rights, of which

Defendants were on actual notice, Defendants modified the <coinyewest.com> and <coinyeco.in>
websites and rescheduled the launch date for the cryptocurrency from January 11, 2014 to

January 7, 2014. A true and correct copy of the <coinyewest.com> website as of January 5,
2014 is attached hereto as Exhibit G, and a true and correct copy of the <coinyewest.com>

website as of January 7, 2014 is attached hereto as Exhibit H. Upon information and belief,
Defendants launched websites located at <coinyefaucet.com>, <coinyecoin.org> and

<coinyecoin.com> to further market and promote their infringing activities.

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44.

Upon information and belief, Defendant Bravo launched the <coinyecasino.com>

and <coinyecasino.l8.1v> websites to exploit the KANYE WEST trademark and the media attention the Defendants' infringing activities had received. Upon information and belief, the

<coinyecasino.com> and <coinyecasino.l8.1v> websites allow users to participate in the online gambling using COINYE coins. On January 8, 2014, Plaintiffs' counsel sent Bravo a demand

letter and, in response, Bravo tried to extort Mr. West stating in an email to counsel: "no further
actions will be taken until a personal video on behalf of Kanye West is published in which he

kindly asks us to remove roulette wheel based on his geopolitical, religious or any other possible
insults, personality damages of any sort or inconveniences this roulette wheel has provided." A
true and correct copy of this email is attached hereto as Exhibit I. Defendant Bravo has further

stated to the news media that "the CoinyeCasino.com team is prepping even more games for Coinye users" and has sarcastically stated that it "would love to give [Plaintiffs' counsel] some house credit for a few free roulette spins." A true and correct copy of the article quoting Bravo is
attached hereto as Exhibit J.

45.

During the launch of the COINYE block, upon information and belief, consumers

chose a pool where they accessed a miner program aptly called "COINYEMINER." Upon

information and belief, coins mined by the individual users were automatically sent to their
software wallet. Upon information and belief, 666,666 COINYE WEST coins were released for mining, a number that is closely associated with Mr. West and his Yeezus album. 46. While some nominal changes have been made to the Infringing Websites in

response to the demand letter, given Mr. West's wide-ranging entrepreneurial accomplishments, consumers are still likely to believe, and upon information and belief, have mistakenly believed,
that Mr. West is the source of COINYE WEST, COINYE and/or COYE coins or is affiliated

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with, or has sponsored or endorsed the cryptocurrency. At the very least, Defendants' conduct
dilutes the KANYE WEST mark by blurring and tarnishment.

47.

Upon information and belief, Defendants' mine is unprofessional and has been

criticized by the cryptocurrency community. Critics have noted that Defendants engaged in

deceptive practices by engaging in unpublicized, pre-mining activity, such as hoarding a portion
of the coins to themselves. Defendants' mine has also been called a "pump and dump" scam,

with one commentator noting: "Coinye West coin is 100% fraud from the get go." An example
of criticism that Defendants' mine has received is attached hereto as Exhibit K.
E. Contributory Defendants' Illegal Activities

48.

Upon information and belief, Defendant Odaycoins.com is a digital currency

exchanger that has recognized Defendants' cryptocurrency and is allowing the cryptocurrency to
be traded on its exchange. Upon information and belief, Defendant Odaycoins.com earns

commissions when trades are made and is otherwise profiting from listing the currency on the

<Odaycoins.com> exchange. By recognizing the COINYE WEST, COINYE and/or COYE

cryptocurrency, Defendant Odaycoins.com is engaging in willful trademark infringement and unfair competition by using the infringing marks on the website and is engaging in willful
contributory trademark infringement and willful contributory unfair competition because without
its actions, the cryptocurrency would have no value.

49.

Upon information and belief, Defendant Coinye-exchange.com is a digital

currency exchanger that has recognized and/or will recognize Defendants' cryptocurrency and is allowing and/or will allow the cryptocurrency to be traded on its exchange. Upon information
and belief, Defendant Coinye-exchange.com.com earns and/or will earn commissions when
trades are made and are otherwise profiting from listing the currency on the <coinye-

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exchange.com> exchange. By recognizing the COINYE WEST, COINYE and/or COYE

cryptocurrency, Defendant Coinye-exchange.com.com is engaging in willful trademark
infringement and unfair competition by using the infringing marks on the website and is engaging in willful contributory trademark infringement and willful contributory unfair
competition because without its actions, the cryptocurrency would have no value.
50. Defendant Newchg.com is a digital currency exchanger that has recognized

Defendants' cryptocurrency and is allowing the cryptocurrency to be traded on its exchange.

Upon information and belief, Defendant Newchg.com earns commissions when trades are made
and are otherwise profiting from listing the currency on the <newchg.com> exchange. By

recognizing the COINYE WEST, COINYE and/or COYE cryptocurrency, Defendant Newchg.com is engaging in willful trademark infringement and unfair competition by using the

infringing marks on the website and engaging in willful contributory trademark infringement and
willful contributory unfair competition because without its actions, the cryptocurrency would
have no value.

51.

Before filing this action, Plaintiffs notified Defendant Newchg.com ofDefendants'

infringing activities and demanded that Defendant Newchg.com cease the operation, exchange,
sale, transfer and/or purchase of COINYE cryptocurrency. A true and correct copy of the letter,

dated January 8, 2014, is attached hereto as Exhibit L. While Defendant Newchg.com delisted
the COINYE coins in an apparent response to the January 8, 2014 demand letter, Defendant
Newchg.com has not formally responded to the letter.

52.

Defendant Amazon.com, Inc. provides web hosting services for the <coinyeco.in>

and <coinyewest.com> websites. Before filing this action, Plaintiffs notified Amazon.com of

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Defendants' infringing activities and other violations.
Amazon.com has not deactivated the websites.

As of this filing date, Defendant

53.

Jane Does Defendants exploit and recognize the COINYE WEST, COINYE

and/or COYE cryptocurrency in their functions as servers, web host companies, cryptocurrency
exchanges, cryptocurrency "mining" service providers, cryptocurrency payment processors,

vendors of cryptocurrency, operators of cryptocurrency "wallets", retailers accepting and/or facilitating the exchange of cryptocurrency, marketers promoting cryptocurrency, operators of

cryptocurrency ledgers and "miners" of cryptocurrency. Defendants have published Plaintiffs'
letter demanding that Defendants cease all use of the marks COINYE WEST, COINYE and/or
CONYE on the grounds that such use infringes and dilutes Mr. West's famous and distinctive

trademark among other violations. The demand letter has been posted to dozens of websites and
discussions thereof are widespread in national publications, among the online community and on social media. Upon information and belief, Jane Does Defendants 1 through 50, in wanton

disregard of Plaintiffs' rights, have aided, abetted and assisted Defendants in their infringing
activities by continuing to provide the services identified.

54.

Upon information and belief, Dogecoin is the operator, registrant and/or host of

the following websites that are utilizing and/or exploiting the COINYE WEST, COINYE, COYE marks: <minecoinye.com>, <coinyemining.com>, <coinyegames.com>, <coinyewallet.com>,

<coinyestore.com>, <buycoinyes.com>, <buycoinye.net>, <buy-coinye.com>, <betcoinye.com>,
<coinyespin.com>, <coinye-dice.com>, <coinyeroulette.com>, <coinyedice.com>, <coinyegambling.com>, <getcoinye.com>, <coinyepoker.com>, <coinyeshop.com>,

<freecoinye.com>, and <fuckcoinye.com>.

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F.

Plaintiffs Are Suffering Irreparable Harm

55.

Consumers are likely to mistakenly believe that Mr. West is the source of the

COINYE WEST, COINYE and/or COYE coins or is affiliated with, or has sponsored or

endorsed the cryptocurrency. In fact, consumers are actually confused as reflected in tweets
posted on Twitter:

Samantha Grossman @sam_grossman 2 Jan:

Forget Bitcoin, because Kanye West now has a cryptocurrency and
obviously it's called Coinye West

Romesh Dodangoda @longwaveromesh 2 Jan: Kanye West now has a currency! Christopher Hudson @chrishudsonjr 2 Jan: Move over #Bitcoin, (a)kanyewest now has his own cryptocurrency called
(a),CoinveWest

Andrew Harris @amharris26 2 Jan:
Interest rates are at an all-time low. RT (a)jobwax Kanye West has his own

cryptocurrency and it's called Coinye West
G-J van Rooyen @gvrooyen 2 Jan:

Looks as if @simondlr's prediction is still on track: Kanye West is
launching a cryptocurrency

Chase Graves @everettchase 2 Jan: Move over bitcoin, (obkanyewest is about to create the greatest digital currency of all time. Introducing: (cbCoinyeWest.
Mathew Ingram @mathewi 2 Jan:

shark = jumped MT(a)cschweitz: (a)KanyeWest now has his own cryptocurrency, and it's called Coinye West
Maya Baratz @mbaratz 2 Jan: Well, Bitcoin and Dogecoin has been Kanye'd. Literally. Enter Coinye Evelyn Rush @EvelynRusli 2 Jan: No. Folks, meet Coinye, Bitcoin has been Kanyed Candace Jackson @candaceJackson 2 Jan:

Kanye West is getting his money right, launching his own bitcoin-inspired
cryptocurrency. It's called Coinye West

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Eric Andersen @eric_andersen 2 Jan:

Srsly? (cbkanvewest creates his own cryptocurrency, names it Coinye West,
on Twitter at (cbCoinveWest

Ashley Codianni @AshleyCodianni 2 Jan:

Forget UBitcoin, lemme get some Coinye West --> Kanye West now has his
own cryptocurrency

Joshua Topolsky @joshuatopolsky 2 Jan:

Kanye West Bitcoin clone to launch soon. Coinye West!
Larry Dignan @ldignan 2 Jan:

Latest sign ofBitcoin stupidity. Kanye West his own cryptocurrency Coinye
West

Shaun Olarte @seanzyville 2 Jan:

Kanye Shows Up Obama By Getting His Face On Currency First: Coinye
West Is The Newest Pseudo Bitcoin

Pat McKlindon @PatMcPSU 2 Jan:

Speaking of "coining" and wordplay. Kanye Westjust made his own
version ofBitCoin andnamed it "Coinye West"
Noah Hirsch @noahsh2 2 Jan:

IsKanye serious? He's staring his own online currency like bit-coin. It's
called Coinye-West

Marxs @marxsismo 2 Jan:

Kanye West gets his own digital currency, and it's called Coinye West//
Bigger than Yeezus

Francisco Dao @TheMan 2 Jan: Bitcoin is FINISHED!!! - Kanye West now has his own cryptocurrency
and it's called Coinye West

West Coast Sound @LAWeeklyMusic 2 Jan:

All about the new Kanye West currency, which is like Bitcoin but called
CoinYe

Gavin Millard @gmillard 2 Jan:

Kanye West Now Has His Own Cryptocurrency and It's Called Coinye
West. WTF.

ST Communities @STCommunities 3 Jan: .(cdkanyewest has newcryptocurrency named after him - Coinye West

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CoinDesk @coindesk 3 Jan:

Flamboyant artist Kanye West now has hada digital currency named after
him

BBC Radio lXtra @lXtra 5 Jan:

Oh Yeezus. Not even kidding you (a)kanyewest is going to have his own
CURRENCY, the "Coinye West"

Simon Kratschmer @Bimon 6 Jan:

The cryptocoin to end them all: "Coiny West" - the Kayne West Coin
A true and correct copy of the Twitter feed is attached hereto as ExhibitM.

56.

Mr. West will suffer irreparable harm to his business reputation and goodwill

associated with the brand because he has no control over the cryptocurrency. This is even more
so here because the identities of Defendants are unknown, and they are luring consumers to

purchase a digital currency through the use ofmarks that are substantially similar to the KANYE
WEST mark and use of Mr. West's name and likeness.

57.

Mr. West will also suffer irreparable harm because use of the COINYE WEST,

COINYE and/or COYE marks dilutes the distinctiveness of the famous KANYE WEST mark.

58.

Mr. West will also suffer irreparable harm because as the infringing coins are

mined, they will enter the digital marketplace and may be nearly impossible to retrieve as they
will reside on computers of anonymous users.
FIRST CLAIM

(Violation of Right of Privacy and Publicity, New York Civil Rights Law § 51)
(Against Defendants and Bravo)

59.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 58 of the Complaint as

if fully set forth herein.

60.

Defendants and Bravo have used Mr. West's name, image and likeness within the

State of New York for advertising and/or for the purpose of trade.

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61.

Defendants and Bravo's use of Mr. West's name, image and likeness has been

without the written or oral authorization of Mr. West or anyone authorized by him to give such
authorization.

62.

Defendants and Bravo's use of Mr. West's name, image and likeness has caused

injury to him in an amount to be proven at trial.
63. Defendants and Bravo's use of Mr. West's name, image and likeness in the

manner described herein is forbidden and/or unlawful pursuant to Section 50 of New York Civil
Rights Law.

64.

Mr. West therefore demands exemplary damages under Section 51 of New York

Civil Rights Law.

65.

Furthermore, Section 51 of the New York Civil Rights Law provides a right to

injunctive relief to restrain the unauthorized use ofa person's name for purposes ofadvertising
or trade purposes within New York State.

66.

The acts of Defendants and Bravo have caused and are causing great and

irreparable harm and damage to Mr. West, and unless permanently restrained and enjoined by
this Court, such irreparable harm will continue.

67.

Mr. West therefore demands that Defendants and Bravo be enjoined and

restrained pursuant to Section 51 ofthe Civil Rights law ofthe State ofNew York from using Mr.
West's name for advertising purposes or purposes of trade.
SECOND CLAIM

(Federal Trademark Infringement, 15 U.S.C. § 1114)

(Against Defendants, Odaycoins.com, Coinye-exchange.com, Newchg.com,
Jane Does 1 through 50, and Bravo)

68.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 67 of the Complaint as

if fully set forth herein.

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69.

These defendants have used in commerce, without Plaintiffs' permission, the

COINYE WEST, COINYE and COYE marks in a manner that is likely to cause confusion,

mistake or deception with respect to Plaintiffs' KANYE WEST mark, and is likely to cause
confusion or mistake and to deceive purchasers as to the affiliation, connection, approval,

sponsorship or association of Plaintiffs and/or their goods, services and commercial activities, on
the one hand, with these defendants and/or their respective goods, services or commercial
activities, on the other hand.

70.

These defendants' acts constitute infringement of the KANYE WEST mark

under 15 U.S.C. § 1114.

71.

As a direct and proximate result of these defendants' wrongful acts, Plaintiffs

have suffered and continue to suffer and/or are likely to suffer damage to their trademarks,

business reputation and goodwill. These defendants will continue to use, unless restrained, the
COINYE WEST, COINYE and COYE marks or marks confusingly similar to the KANYE

WEST mark and will cause irreparable damage to Plaintiffs. Plaintiffs have no adequate remedy
at law and are entitled to an injunction restraining these defendants, their respective officers,

agents, and employees, and all persons acting in concert with these defendants, from engaging in
further acts of infringement.
72. Plaintiffs are further entitled to recover from these defendants the actual damages

that they sustained and/or are likely to sustain as a result of these defendants' wrongful acts.
73. Plaintiffs are further entitled to recover from these defendants the gains, profits

and advantages that these defendants have obtained as a result of their wrongful acts.

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74.

Because of the willful nature of these defendants' wrongful acts, Plaintiffs' are

entitled to an award of punitive damages under the common law, and treble damages and
increased profits under 15 U.S.C. § 1117.
THIRD CLAIM

(Contributory Trademark Infringement) (Against Amazon.com, Inc. and Jane Does Defendants)

75.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 74 of the Complaint as

if fully set forth herein. 76. Defendants are engaging in infringing conduct including but not limited to the use

of the COINYE WEST, COINYE and COYE marks in violation of the Lanham Act.

77.

Amazon.com and Jane Does Defendants have deliberately disregarded Plaintiffs'

counsel's notification of the Infringing Websites and have otherwise consciously avoided learning about the full extent of the infringing activity that is continuing on the Infringing
Websites.

78.

Amazon.com and Jane Does Defendants have materially encouraged, enabled,

and contributed to the Infringing Websites by providing hosting services. 79. The acts ofAmazon.com and Jane Does Defendants have caused and are causing

great and irreparable harm and damage to Plaintiffs, and unless permanently restrained and
enjoined by this Court such irreparable harm will continue. 80. As a direct and proximate result of Amazon.com and Jane Does Defendants'

actions as stated herein, Plaintiffs have suffered damage to their reputation and damage to the
goodwill associated with the KANYE WEST mark.

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FOURTH CLAIM

(Contributory Trademark Infringement)

(Against Odaycoins.com, Coinye-exchange.com, Newchg.com and Jane Does Defendants)
81. Plaintiffs hereby repeat and reallege Paragraphs 1through 80 ofthe Complaint as

if fully set forth herein.

82.

Defendants are engaging in infringing conduct including but not limited to the use

of the COINYE WEST, COINYE and COYE marks in violation of the Lanham Act.

83.

Odaycoins.com, Coinye-exchange.com, Newchg.com and Jane Does Defendants

have deliberately disregarded Plaintiffs' counsel's notification ofthe Infringing Websites and has
otherwise consciously avoided learning about the full extent of the infringing activity that is
continuing on the Infringing Websites.

84.

Upon

information

and

belief,

Odaycoins.com,

Coinye-exchange.com,

Newchg.com and Jane Does Defendants have materially encouraged, enabled, and contributed to

the Infringing Websites by engaging in the operation, exchange, sale, transfer and/or purchase of
COINYE cryptocurrency.

85.

The acts of Odaycoins.com, Coinye-exchange.com, Newchg.com and Jane Does

Defendants have caused and are causing great and irreparable harm and damage to Plaintiffs, and

unless permanently restrained and enjoined by this Court, such irreparable harm will continue.
86. As a direct and proximate result of Odaycoins.com, Coinye-exchange.com,

Newchg.com and Jane Does Defendants' actions as stated herein, Plaintiffs have suffered
damage to their reputation and damage to the goodwill associated with the KANYE WEST mark.

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FIFTH CLAIM

(Federal Unfair Competition, 15 U.S.C. § 1125(a))

(Against Defendants, Odaycoins.com, Coinye-exchange.com, Newchg.com,
Jane Does 1 through 50, and Bravo)

87.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 86 of the Complaint as

if fully set forth herein.

88.

The COINYE WEST, COINYE and COYE marks are substantially similar to

Plaintiff West's given name, Kanye West, and his KANYE WEST trademark. 89.
West.

Consumers identify the mark KANYE WEST exclusively with Plaintiff Kanye

90.

These defendants' conduct as alleged herein is likely to cause confusion and/or to

deceive users and consumers as to the origin, sponsorship, affiliation, connection and/or
association of Mr. West with these defendants' respective goods and/or services.

91.

Mr. West does not now and has never sponsored or approved or authorized these

defendants' use of the COINYE WEST, COINYE or COYE marks.
92. These defendants' conduct is willful and deliberate and done with the intent to

unfairly commercially benefit from the goodwill association with Mr. West personally and the
KANYE WEST brand name.

93.

These defendants' unfair competition has caused and is causing great and

irreparable harm and damage to Plaintiffs, and unless permanently restrained and enjoined by
this Court such irreparable harm will continue.

94.

As a direct and proximate result of these defendants' wrongful acts, Plaintiffs

have suffered and continue to suffer and/or are likely to suffer damage to their trademarks,

business reputation and goodwill. These defendants' will continue to use, unless restrained, the
COINYE WEST, COINYE and COYE marks or marks confusingly similar to the KANYE

1291304 vl5

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29

WEST mark and will cause irreparable damage to Plaintiffs. Plaintiffs have no adequate remedy
at law and are entitled to an injunction restraining these defendants, their respective officers, agents, and employees, and all persons acting in concert with these defendants, from engaging in
further acts of infringement.

95.

Plaintiffs are further entitled to recover from these defendants the actual damages

that they sustained and/or are likely to sustain as a result of these defendants' wrongful acts.
96. Plaintiffs are further entitled to recover from these defendants the gains, profits

and advantages that these defendants have obtained as a result of their wrongful acts.
97. Because of the willful nature of these defendants' wrongful acts, Plaintiffs' are

entitled to an award of punitive damages under the common law, and treble damages and
increased profits under 15 U.S.C. § 1117.
SIXTH CLAIM

(Contributory Unfair Competition) (Against Amazon.com, Inc. and Jane Does Defendants)

98.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 97 of the Complaint as

if fully set forth herein.

99.

The COINYE WEST, COINYE and COYE marks are substantially similar to

Plaintiff West's given name, Kanye West, and his KANYE WEST trademark.

100.
West.

Consumers identify the mark KANYE WEST exclusively with Plaintiff Kanye

101.

Defendants' conduct as alleged herein is likely to cause confusion and/or to

deceive users and consumers as to the origin, sponsorship, affiliation, connection and/or
association of Mr. West with Defendants' goods and services.

1291304 vl5

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30

102.

Mr. West does not now and has never sponsored or approved or authorized

Defendants' use of the COINYE WEST, COINYE or COYE marks.

103.

Defendants' conduct is willful and deliberate and done with the intent to unfairly

commercially benefit from the goodwill association with Mr. West personally and the KANYE
WEST brand name.

104.

Amazon.com and Jane Does Defendants have deliberately disregarded Plaintiffs'

counsel's notification of the Infringing Websites and have otherwise consciously avoided

learning about the full extent of the infringing activity that is continuing on the Infringing
Websites.

105.

Amazon.com and Jane Does Defendants have materially encouraged, enabled,

and contributed to the Infringing Websites by providing hosting services.
106. The acts of Amazon.com and Jane Does Defendants have caused and are causing

great and irreparable harm and damage to Plaintiffs, and unless permanently restrained and
enjoined by this Court such irreparable harm will continue. 107. As a direct and proximate result of Amazon.com and Jane Does Defendants'

actions as stated herein, Plaintiffs have suffered damage to their reputation and damage to the goodwill associated with the KANYE WEST mark.
SEVENTH CLAIM

(Contributory Unfair Competition)

(Against 0daycoins.com, Coinye-exchange.com, Newchg.com and Jane Does Defendants)
108. Plaintiffs hereby repeat and reallege Paragraphs 1 through 107 of the Complaint

as if fully set forth herein.

109.

The COINYE WEST, COINYE and COYE marks are substantially similar to

Plaintiff West's given name, Kanye West, and his KANYE WEST trademark.

1291304 vl5

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110.
West.

Consumers identify the mark KANYE WEST exclusively with Plaintiff Kanye

111.

These defendants' conduct as alleged herein is likely to cause confusion and/or to

deceive users and consumers as to the origin, sponsorship, affiliation, connection and/or
association of Mr. West with these defendants' goods and/or services.

112.

Mr. West does not now and has never sponsored or approved or authorized these

defendants' use of the COINYE WEST, COINYE or COYE marks.
113. These defendants' conduct is willful and deliberate and done with the intent to

unfairly commercially benefit from the goodwill association with Mr. West personally and the
KANYE WEST brand name.

114.

These defendants have deliberately disregarded Plaintiffs' counsel's notification

of the Infringing Websites and have otherwise consciously avoided learning about the full extent
of the infringing activity that is continuing on the Infringing Websites.

115.

Upon information and belief, these defendants have materially encouraged,

enabled, and contributed to the Infringing Websites by engaging in the operation, exchange, sale,
transfer and/or purchase of COINYE cryptocurrency. 116. The acts of these defendants have caused and are causing great and irreparable

harm and damage to Plaintiffs, and unless permanently restrained and enjoined by this Court
such irreparable harm will continue. 117. As a direct and proximate result of these defendants' actions as stated herein,

Plaintiffs have suffered damage to their reputation and damage to the goodwill associated with
the KANYE WEST mark.

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EIGHTH CLAIM

(Violation of Anti-Cybersquatting Consumer Protection Act, 15 U.S.C. § 1125(d))
(Against Defendants, Bravo and Dogecoin)

118.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 117 of the Complaint

as if fully set forth herein.

119.

Plaintiffs own all rights, title and interest in and to the KANYE WEST mark.

120.

Upon information and belief, Defendants, Bravo and Dogecoin are the registrants

of domains that are confusingly similar to Plaintiffs' distinctive and famous mark.

121.

Upon information and belief, Defendants registered the Infringing Websites with

the bad faith intent to profit as evidenced by, inter alia: (i) their use of COINYE in the domains in willful disregard of Plaintiffs' rights; (ii) the domains consist of a name that is associated with
Plaintiffs; (iii) Defendants are using the domains to perpetuate willful trademark infringement;
and (iv) Defendants' infringing activities are commercial.

122.

Upon information and belief, Bravo registered <coinyecasino.com> and

<coinyecasino.l8.1v> with the bad faith intent to profit as evidenced by, inter alia: (i) their use of
COINYE in the domains in willful disregard of Plaintiffs' rights; (ii) the domains consist of a
name that is associated with Plaintiffs; (iii) Bravo is using the domains to perpetuate willful

trademark infringement; and (iv) Bravo's infringing activities are commercial.

123.

Upon information and belief, <coinyegames.com>,

Dogecoin

registered

<minecoinye.com>, <coinyestore.com>,

<coinyemining.com>,

<coinyewallet.com>,

<buycoinyes.com>, <buycoinye.net>, <buy-coinye.com>, <betcoinye.com>, <coinyespin.com>,

<coinyeroulette.com>,

<coinyegambling.com>,

<coinyepoker.com>,

<coinye-dice.com>,

<coinyedice.com>,

<getcoinye.com>,

<coinyeshop.com>,

<freecoinye.com>,

and

<fuckcoinye.com> with the bad faith intent to profit as evidenced by, inter alia: (i) its use of

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COINYE in the domains in willful disregard of Plaintiffs' rights; (ii) the domains consist of a
name that is associated with Plaintiffs; (iii) Dogecoin is using the domains to perpetuate willful

trademark infringement; and (iv) Dogecoin's infringing activities are commercial.

124.

Upon information and belief, Defendants and Dogecoin committed these acts

alleged herein willfully and with the intent to confuse the public and to injure Plaintiffs.
125. The acts of Defendants, Bravo and Dogecoin have caused and are causing great

and irreparable harm and damage to Plaintiffs, and unless permanently restrained and enjoined
by this Court such irreparable harm will continue.

126.

As a direct and proximate result of Defendants', Bravo's and Dogecoin's

wrongful acts, Plaintiffs have suffered and continue to suffer and/or are likely to suffer damage
to their trademarks, business reputation and goodwill. Defendants and Dogecoin will continue to

use, unless restrained, the COINYE WEST, COINYE and COYE marks or marks confusingly
similar to the KANYE WEST mark and will cause irreparable damage to Plaintiffs. Plaintiffs

have no adequate remedy at law and are entitled to an injunction restraining Defendants, Bravo,

Dogecoin, their respective officers, agents, and employees, and all persons acting in concert with
Defendants, Bravo or Dogecoin, from engaging in further acts of infringement.
127. Plaintiffs are further entitled to recover from Defendants, Bravo and Dogecoin the

actual damages that they sustained and/or are likely to sustain as a result of Defendants', Bravo's
and Dogecoin's wrongful acts.
128. Plaintiffs are further entitled to recover from Defendants, Bravo and Dogecoin the

gains, profits and advantages that Defendants, Bravo and Dogecoin have obtained as a result of
their wrongful acts.

1291304 vlS

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34

129.

Because of the willful nature of Defendants', Bravo's and Dogecoin's wrongful

acts, Plaintiffs' are entitled to an award of punitive damages under the common law, and treble
damages and increased profits under 15 U.S.C. § 1117.
NINTH CLAIM

(Federal Trademark Dilution, 15 U.S.C. § 1125(c)) (Against Defendants, Odaycoins.com, Coinye-exchange.com, Newchg.com,
Jane Does 1 through 50, and Bravo)

130.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 129 of the Complaint

as if fully set forth herein.

131.

Plaintiffs used the KANYE WEST mark to identify their goods and services

before these defendants began promoting and offering goods and/or services under, or otherwise

using, the COINYE WEST, COINYE and COYE marks.

The KANYE WEST mark is

inherently distinctive and has acquired distinction through Plaintiffs' extensive, continuous and
exclusive use of the mark.

132.

The KANYE WEST mark is famous and distinctive within the meaning of 15

U.S.C. §§ 1125(c)(1), and was famous before these defendants adopted the COINYE WEST,
COINYE and COYE marks.

133.

These defendants' use of the COINYE WEST, COINYE and COYE marks is

likely to dilute the distinctive quality Plaintiffs' KANYE WEST mark in violation of 15 U.S.C. §
1125(c).

134.
irreparably.

These defendants' acts complained of herein are likely to damage Plaintiffs

135.

Plaintiffs have no adequate remedy at law for such wrongs and injuries. The

damage to Plaintiffs includes harm to their trademarks, goodwill and reputation that money

cannot compensate. Plaintiffs are, therefore, entitled to a preliminary and permanent injunction

1291304 vl5

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35

enjoining these defendants' use of the COINYE WEST, COINYE and COYE marks, or any
marks dilutive of Plaintiffs' KANYE WEST mark in connection with the promotion,

advertisement and sale of any goods, services or commercial activities by these defendants.
136. Plaintiffs are further entitled to recover from these defendants for the actual

damages sustained by Plaintiffs as a result of these defendants' wrongful acts. Plaintiffs are presently unable to ascertain the full extent of the monetary damages they have suffered by
reason of these defendants' acts of dilution.

137.

Plaintiffs are further entitled to recover from these defendants the gains, profits

and advantages these defendants have obtained as a result of their wrongful acts. Plaintiffs are
presently unable to ascertain the extent of the gains, profits and advantages these defendants
have realized by reason of these defendants' willful acts of dilution.
138. Because of the willful nature of these defendants' actions, Plaintiffs are entitled to

all remedies available under 15 U.S.C. §§ 1117 and 1118, including, but not limited to, treble
damages.
TENTH CLAIM

(Deceptive Acts and Practices, New York General Business Law § 349)
(Against Defendants)

139.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 138 of the Complaint

as if fully set forth herein.

140.

Upon information and belief, Defendants, without Mr. West's authorization or

consent, and having knowledge of Plaintiffs' rights to the KANYE WEST mark, offer and/or

will be offering goods for sale and/or rendering services on the Infringing Websites to the public
in direct competition with Plaintiffs.

1291304 vl5

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36

141.

Upon information and belief, Defendants' use ofthe KANYE WEST mark and

Mr. West's image and likeness is likely to cause and is causing confusion, mistake and deception

among the general purchasing public as to the origin ofthe Infringing Websites, and is likely to
deceive the public into believing that goods and/or services being offered for sale by Defendants
originates from, is associated with, or is otherwise authorized byMr. West.

142.

Upon information and belief, Defendants' deceptive acts and practices involve

public sales activities of a recurring nature.
143. The acts of Defendants have caused and are causing great and irreparable harm

and damage to Plaintiffs, and unless permanently restrained and enjoined by this Court, such
irreparable harm will continue.
ELEVENTH CLAIM

(Dilution, New York Gen. Bus. L. § 360-1)

(Against Defendants, Odaycoins.com, Coinye-exchange.com, Newchg.com,
Jane Does 1 through 50, and Bravo)

144.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 143 of the Complaint

as if fully set forth herein.

145.

Plaintiffs used the KANYE WEST mark to identify their goods and services

before these defendants began promoting and offering goods and/or services under, or otherwise

using, the COINYE WEST, COINYE and COYE marks. The KANYE WEST mark is
inherently distinctive and has acquired distinction through Plaintiffs' extensive, continuous and
exclusive use of the mark.

146.

The KANYE WEST mark is famous and distinctive within the meaning of New

York Gen. Bus. L. § 360-1, and was famous before these defendants adopted the COINYE
WEST, COINYE and COYE marks.

1291304 vl5

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37

147.

These defendants' use of the COINYE WEST, COINYE and COYE marks is

likely to dilute the distinctive quality Plaintiffs' KANYE WEST mark in violation of New York
Gen. Bus. L. § 360-1.

148.
irreparably.

These defendants' acts complained of herein are likely to damage Plaintiffs

149.

Plaintiffs have no adequate remedy at law for such wrongs and injuries. The

damage to Plaintiffs includes harm to their trademarks, goodwill and reputation that money
cannot compensate. Plaintiffs are, therefore, entitled to a preliminary and permanent injunction enjoining these defendants' use of the COINYE WEST, COINYE and COYE marks, or any
marks dilutive of Plaintiffs' KANYE WEST mark in connection with the promotion,

advertisement and sale of any goods, services or commercial activities by these defendants.
150. Plaintiffs are further entitled to recover from these defendants for the actual

damages sustained by Plaintiffs as a result of these defendants' wrongful acts. Plaintiffs are

presently unable to ascertain the full extent of the monetary damages they have suffered by
reason of these defendants' acts of dilution.

151.

Plaintiffs are further entitled to recover from these defendants the gains, profits

and advantages these defendants have obtained as a result of its wrongful acts. Plaintiffs are

presently unable to ascertain the extent of the gains, profits and advantages these defendants
have realized by reason of these defendants' willful acts of dilution.
152. Because of the willful nature of these defendants' actions, Plaintiffs are entitled to

all remedies under New York General Business Law.

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38

TWELTH CLAIM

(Unjust Enrichment) (Against All Defendants)

153.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 152 of the Complaint

as if fully set forth herein.

154.

These defendants have benefited from the unlawful and infringing use of the

KANYE WEST trademark and Mr. West's image and likeness because, upon information and

belief, they have derived and/or will derive substantial revenue from the sale of goods and/or the
rendering of services offered and/or promoted on the Infringing Websites through the use of Mr.
West's name, image and likeness.

155.

It would be against equity and good conscience to allow these defendants to retain

the substantial revenue and profits they have realized and/or will realize through their blatantly
unlawful use of Mr. West's name, image and likeness.

156.
157.

These defendants have been unjustly enriched by its unlawful use of said name.
The acts of these defendants have caused and are causing great and irreparable

harm and damage to Plaintiffs, and unless permanently restrained and enjoined by this Court,
such irreparable harm will continue.

158.

As a direct and proximate result of these defendants' actions as stated herein, Mr.

West has suffered damage to his reputation and damage to the goodwill of the KANYE WEST
trademark. Further, Plaintiffs are entitled to exemplary damages as a result of these defendants'
malicious actions as described above.

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39

THIRTEENTH CLAIM

(Common Law Trademark Infringement)

(Against Defendants, Odaycoins.com, Coinye-exchange.com, Newchg.com,
Jane Does 1 through 50, and Bravo)

159.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 158 of the Complaint

as if fully set forth herein.

160.

These defendants have used in commerce, without Plaintiffs' permission, the

COINYE WEST, COINYE and COYE marks in a manner that is likely to cause confusion,

mistake or deception with respect to Plaintiffs' KANYE WEST mark, and is likely to cause
confusion or mistake and to deceive purchasers as to the affiliation, connection, approval,

sponsorship or association of Plaintiffs and/or their goods, services and commercial activities, on
the one hand, with these defendants and/or their goods, services or commercial activities, on the
other hand.

161.

These defendants' acts constitute infringement of the KANYE WEST mark in

violation of the common law.

162.

As a direct and proximate result of these defendants' wrongful acts, Plaintiffs

have suffered and continue to suffer and/or are likely to suffer damage to their trademarks,

business reputation and goodwill. These defendants will continue to use, unless restrained, the
COINYE WEST, COINYE and COYE marks or marks confusingly similar to the KANYE

WEST mark and will cause irreparable damage to Plaintiffs. Plaintiffs have no adequate remedy at law and are entitled to an injunction restraining these defendants, their respective officers,

agents, and employees, and all persons acting in concert with these defendants, from engaging in
further acts of infringement. 163. Plaintiffs are further entitled to recover from these defendants the actual damages

that they sustained and/or are likelyto sustain as a result of these defendants' wrongful acts.
1291304 vl5

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40

164.

Plaintiffs are further entitled to recover from these defendants the gains, profits

and advantages that these defendants have obtained as a result oftheir wrongful acts.
165. Because of the willful nature of these defendants' wrongful acts, Plaintiffs' are

entitled to an award of punitive damages under the common law.
FOURTEENTH CLAIM

(Common Law Unfair Competition)

(Against Defendants, 0daycoins.com, Coinye-exchange.com, Newchg.com,
Jane Does 1 through 50, and Bravo)

166.

Plaintiffs hereby repeat and reallege Paragraphs 1 through 165 of the Complaint

as if fully set forth herein.

167.

Plaintiffs have expended substantial time, resources and effort to develop and

obtain a strong reputation in the marketplace and enormous goodwill in the KANYE WEST
mark.

168.

These defendants have infringed the KANYE WEST mark by using the

confusingly similar COINYE WEST, COINYE and COYE marks. These defendants' unlawful
acts are intended to capitalize on Plaintiffs' goodwill for these defendants' own pecuniary gain.
169. These defendants' use of the COINYE WEST, COINYE and COYE marks is

calculated to and is likely to create confusion and to deceive and mislead consumers into

believing that the Infringing Websites originated with or are authorized by Plaintiffs, and is

likely to cause confusion as to the source of the content of the Infringing Websites, all to the
detriment of Plaintiffs.

170.

These defendants' acts as alleged herein constitute unfair competition and will,

unless enjoined by the Court, continue to result in harm to the goodwill associated with the
KANYE WEST mark.

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41

171. Upon information and belief, these defendants committed the acts alleged herein
willfully and with the intent to confuse the public and to injure Plaintiffs.
172. The acts of these defendants have caused and are causing great and irreparable

harm and damage to Plaintiffs, and unless permanently restrained and enjoined by this Court,
such irreparable harm will continue.

173.

As a direct and proximate result of these defendants' actions as stated herein, Mr.

West has suffered damage to his reputation and damage to the goodwill of the KANYE WEST
mark. Further, Plaintiffs are entitled to exemplary damages as a result of these defendants'
malicious actions as described above.
PRAYER FOR RELIEF

WHEREFORE,

Plaintiffs

respectfully

request judgment

against

Defendants,

Contributory Defendants, Bravo and Dogecoin and their respective partners, agents, employees

and attorneys, and any and all persons in active concert or participation with Defendants, Contributory Defendants, Bravo or Dogecoin and each of their heirs, executors, administrators,
successors, licensees, assigns, subsidiaries, parents, affiliates, divisions, co-venturers, partners, officers, directors, employees, agents, shareholders, managers, business managers, accountants,

attorneys, representatives, consultants and any and all other persons, corporations or other
entities acting under the supervision, direction, control or on behalf of any of the foregoing as
follows:

1.

Preliminarily and permanently enjoining Defendants, Contributory Defendants,

Bravo and Dogecoin and their respective partners, agents, employees and attorneys, and any and

all other persons in active concert or participation with Defendants, Contributory Defendants,
Bravo and/or Dogecoin and each of their heirs, executors, administrators, successors, licensees,

1291304 vl5

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42

assigns, subsidiaries, parents, affiliates, divisions, co-venturers, partners, officers, directors,
employees, agents, shareholders, managers, business managers, accountants, attorneys,

representatives, consultants and any and all other persons, corporations or other entities acting
under the supervision, direction, control or on behalf ofany ofthe foregoing from (a) registering, operating, maintaining or using any website, blog, or Internet domain name or domain that uses
the KANYE WEST mark, COINYE WEST mark, COINYE mark, COYE mark, or any colorable
imitation of the marks KANYE WEST or KANYE, including but not limited to

<coinyewest.com>, <coinyeco.in>, <coinyefaucet.com>, <buycoinye.com>, <coinyecoin.org>, <coinyecoin.com>, <coinyechain.info>, <coinyecasino.com>, <coinyecasino.l8.1v>, <coinyeexchange.com>, <minecoinye.com>, <coinyemining.com>, <coinyegames.com>,

<coinyewallet.com>,
coinye.com>,

<coinyestore.com>,
<betcoinye.com>,

<buycoinyes.com>,
<coinyespin.com>,

<buycoinye.net>,

<buy-

<coinyeroulette.com>,

<coinyegambling.com>,

<coinyepoker.com>,

<coinye-dice.com>,

<coinyedice.com>,

<getcoinye.com>, <coinyeshop.com>, <freecoinye.com>, and <fuckcoinye.com>;

(b)

registering, operating and maintaining an "alt coin" digital currency or cryptocurrency site or
network that uses the KANYE WEST mark, COINYE WEST mark, COINYE mark, COYE

mark, or any colorable imitation of the marks KANYE WEST or KANYE, including, but not
limited to, those contained in <coinyewest.com>, <coinyeco.in>, <coinyefaucet.com>,

<buycoinye.com>,
<coinyecasino.l8.1v>,

<coinyecoin.org>,
<coinye-exchange.com>,

<coinyecoin.com>,
<coinyecasino.com>,

<coinyechain.info>,
<minecoinye.com>,

<coinyemining.com>,

<coinyegames.com>,

<coinyewallet.com>,

<coinyestore.com>,

<buycoinyes.com>, <buycoinye.net>, <buy-coinye.com>, <betcoinye.com>, <coinyespin.com>,
<coinyeroulette.com>, <coinyegambling.com>, <coinyepoker.com>, <coinye-dice.com>,

1291304 vl5

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43

<coinyedice.com>,

<getcoinye.com>,

<coinyeshop.com>,

<freecoinye.com>,

and

<fuckcoinye.com>; (c) engaging in the operation, exchange, sale, mining, transfer, purchase,
storage or other use in commerce of an alt coin digital or cryptocurrency bearing any

photographs or the name or likeness of Mr. West in any manner that is likely to cause confusion,
mistake or to deceive the public into believing that the operation, exchange, sale, mining, transfer,

purchase, storage or other use in commerce of the alt coin digital or cryptocurrency by
Defendants originated with Mr. West or that there is any affiliation or connection between Plaintiffs and the operation, exchange, sale, mining, transfer, purchase, storage or other use in
commerce of an alt coin digital orcrypto currency by Defendants, and from otherwise competing

unfairly with Plaintiffs; (d) assisting, aiding or abetting any other person or entity in the

operation, exchange, sale, mining, transfer, purchase, storage or other use in commerce of an alt
coin digital or cryptocurrency bearing COINYEWEST, COINYE or COYE as a trade name,
trademark, brand name, as an Internet domain name, as a digital currency name, as a

cryptocurrency, as an alt coin name, or in any other source-identifying manner; (e) using the
KANYE WEST mark, or any other mark, term or title confusingly similar to the KANYE WEST

mark, including, but not limited to, the COINYE WEST , COINYE and COYE marks; (f) using

any photographs, videos or the name or likeness of Mr. West in any manner that is likely to
cause confusion, mistake or to deceive the public into believing that any website or domain

registered by Defendants, Contributory Defendants, Bravo or Dogecoin originate with Plaintiffs
or that there is any affiliation or connection between Plaintiffs and the websites, and from
otherwise competing unfairly with Plaintiffs; and (g) representing by any means whatsoever,

directly or indirectly, or doing any other acts or things calculated or likely to cause confusion,
mistake or to deceive the public into believing that any goods or services, or website or domain

1291304 vl5

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44

registered by Defendants, Contributory Defendants, Bravo or Dogecoin originate with Plaintiffs
or that there is any affiliation or connection between Plaintiffs and the websites, and from
otherwise competing unfairly with Plaintiffs;

2.

Awarding Plaintiffs damages in amount to be determined at trial, including

compensatory, statutory damages and punitive damages;

3.

Awarding an accounting to Plaintiffs for the gains and profits of all defendants

and for the damages sustained by Plaintiffs as a result of the willful, intentional and wrongful
conduct of all defendants;

4.

Awarding Plaintiffs treble damages on account of the willful nature of all

defendants' infringing acts for an amount to be determined at trial;

5.

Requiring all defendants to pay Plaintiffs their costs in this action, including

reasonable attorneys' fees and costs; and

6.
proper.

Granting Plaintiffs such other and further relief as the Court deems just and

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Dated: New York, New York

January 13,2014

Respectfully submitted,
PRYOR CASHMAN LLP

jJrad D. Rose (BR-2740)

)yan Finguerra-DuCharme (DF-9228)
Madelon A. Gauthier (MG-4687)

Ryan S. Klarberg (RK-4719) Pryor Cashman LLP
7 Times Square New York, New York 10036

Telephone: (212)421-4100
Fax. (212) 326-0806 brose@pryorcashman.com

dfinguerra-ducharme@pryorcashman.com mgauthier @pryorcashman.com
rklarberg@pryorcashman.com

Attorneys for Plaintiffs Kanye West and
Mascotte Holdings, Inc.

1291304 v 13

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EXHIBIT A

Everything You Wanted To Know About the Kanye-Inspired 'Coinye' B...

http://www.usnews.conVnews/articles/2014/01/02/everything-you-wa...

QM2H!Snews
Everything You Wanted To Know About the Kanye-Inspired 'Coinye' But
Were Afraid To Ask
Some entrepreneurs are using Kanye West to launch a cryptocurrency - so what does that mean, again?
By TIERNEY SNEED
January 2, 2014

You would think a Twitter account that popped up Tuesday called "Coinye West" was a parody
account created by some econ nerd-cum-Yeezy

fan. It in fact is the handle of a new digital
currency inspired by Kanye West that, as the creators confirmed to VICE Thursday, will launch Jan. 11. Confused yet? So were we. Here's a
primer.

So Kanye has his own currency now? Not exactly. It looks like West - surprisingly, considering the lengths he'll go to for self promotion - has nothing to do with it. Some techie

monetary entrepreneurs - who for the time being
"want to stay sorta anonymous in case Kanye gets pissed off' -- are launching a cryptocurrency using West's likeness and some clever punning called "Coinye West." [READ: U.S. Unveils New $100 Billto Fight Counterfeiting] Cryptocurrency ... excuse me, what? Cryptocurrencies are digital monetary systems. Users can use these networks to buy and sell things online, usually anonymously and almost like PayPal, but in a decentralized fashion. You may have heard of Bitcoin, the 4-year-old form of digital currency that attracted congressional attention in November. It went on a boom-and-bust ride last year, with the price of a bitcoin skyrocketing above $1,000 in November only to crash 50 percent.
A new digital currency named Coinye looks to capitalize on the fame of rapper Kanye West

Because it is online, anonymous and decentralized, Bitcoin and other cryptocurrencies get a reputation as being especially useful for illicit purchases (it
was the accepted currency of the recently shut down illegal drug trafficking website, Silk Road). However, the rise of BitPay, BitGive and other platforms that use Bitcoin have given it some legitimacy, and attention now has turned to how it could be regulated.
So how does this all work?

Similar to how a treasury prints cash, bitcoins are released in a process known as "mining," in which users' computers compete to solve algorithms to
win bitcoins (the algorithm gets increasingly harder so that the race will occur every 10 minutes or so and the bitcoin rewarded is halved every four

years, meaning the bitcoin supply is finite). Coinye's creators say they willrelease their own front-end mining program called CoinyeMiner, which
according to them will be more user-friendly than the mining programs used by other cryptocurrencies. Walt - they named the mining program 'CoinyeMiner,' and not 'Gold Digger'? I know, missed opportunity, right?
[ALSO: Silk Road Shuttered: Online Drug Market's 100,000 Patrons May Be in Hot Water]

What's the point of naming your weird online currency after a megalomaniac, Kardashian-loving rapper? Well, this is the point: attention. For these currencies to work they must have users, and the more users they have the more stable they'll be. Just last month, some Internet geeks created a cryptocurrency called Dogecoin - inspired by 2013's Meme of the Year, a Shiba Inu dog named Kabosu - and its value surged 900 percent in a week while its competitor currencies stumbled.

"There was this trend effect of people thinking it was associated with something cool and trendy," says Reuben Grinberg, a lawyer in the financial

lof2

1/8/2014 8:06 PM

Everything You Wanted To Know About the Kanye-Inspired 'Coinye' B...

http://www.usnews.com/news/articles/2014/01/02/everything-you-wa...

institutions group of the lawfirm Davis Polk &Wardwell LLP. The Coinye creators likely are hoping for a similar effect."My guess would be is that they're
trying to profit on something associated with [Kanye's] name."

As Coinyecreators toldVICE, "We chose to represent Kanye because he is and always has been a trendsetter, and he's always keeping things
unique."

Should I buy Coinye?

Though the Coinye creators say their program will be moreaccessible than other cryptocurrencies, they haven't really specified how.
"As more people get involved in mining this currency, it's goingto be difficult for everyday people to get access to these coins and it's going to be people with professional setups who profit the most," Grinberg explains. So you might be better offsticking to the moreestablished Bitcoin. Also worrisome, Grinberg says, is the kind of users Coinye seeks to attract: Kanyefans, rather than economists, mathwhizzesand techies who are

known to get involved in cryptocurrenices. Cryptocurrencies are very risky, and non-economists buying inout of a lovefor Kanye could lose a lotof
money if they don't know what they're doing.

"These are not the people I would say who should be getting involved in digital currencies," Grinberg says. [MORE:Group Seeks to Solicit Charitable Donations in Bitcoins]

How many Coinye will it take to buy a 'mayonnaise colored Benz'?
We won't know until the currency launches, but as of press time, a $300,000 Mercedes-Benz costs about $384.73 in bitcoin.
I bet Twitter is loving this.
Too much. More News:

• House Weighs Bill to CrackDown on Coin Counterfeits
• Dollar Coin Advocates Renew Push to Banish $1 Bill

• How Did Bitcoin Become a Real Currency? Tags: money, internet, art

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2 of 2

1/8/2014 8:06 PM

http://www.hollywoodreporter.com/print/668324

10:55 PM PST 1/2/2014 by Kevin Rutherford, Billboard
10
22

0

Kanye West

Coinye West launches Jan. 11, with its creators saying they wish to remain anonymous "in case Kanye gets pissed off."
Thisstoryfirst appeared at Billboard.com.
our editor recommends

Best of 2013: From One Direction to Kanye West. Why Grandiose Tours Rule

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First it was Bitcoin. Then came Dogecoin. Now, a group of Internet denizens are creating a new form of e-currency —and it's got that New God Flow.

As Noisey reports, a new cryptocurrency named after Kanye West is about to hit the marketplace. Deemed Coinye West,the currency is supposedto
become available Jan. 11. STORY: From One Direction to Kanye West. Why Grandiose Tours Ruled in 2013

In an interviewwith Noisey,the creators of Coinye Westsaid they're remaininganonymous"in case kanye gets pissed off," but the currency is totally legitimate. With a tagline of "we ain't minin', we pickin'," Coinye West is created in the spirit of, according to its creators, makingit "easierfor people
to use cryptocurrency."

"We chose to represent Kanye because he is and always has been a trendsetter, and he's always keeping things unique," the Coinye creators added. "I can picture a future where Coinye is used to buy concert tickets, with cryptographically verified virtual tickets, and other ideas I can't give away just
yet."

Yeezus himself isn't exactly behind the idea just yet, but that hasn't stopped the creators of Coinye West from reaching out to the rapper in the hope
that he'll invest —or, at least, not get mad about its existence.

"Have you ever invested in bitcoin or litecoin?" its creators asked West via Twitter. In the Noisey interview, they also invited West to get in contact with them, offering the rapper 100,000 "COINYE," as it's being called. No word on how the rapper feels about having a form of currency named after him just yet.

lof2

1/8/2014 8:07 PM

http://www.hollywoodreporter.com/print/668324

The website encountered an unexpected error. Please try again later.

2 of 2

1/8/2014 8:07 PM

New Bitcoin-Esque Cryptocurrency Named After Kanye West Launching... http://www.billboard.com/articles/news/5855158/new-bitcoin-esque-..

billboard

New Bitcoin-Esque Cryptocurrency Named After Kanye
West Launching
By Kevin Rutherford | January 02, 2014 9:44 PM EST

Coinye West, in the vein of Bitcoin and Dogecoin, launches Jan. 11
First itwas Bitcoin. Then came Dogecoin. Now, a group of Internet denizens are creating a new form of e-currency - and it's
got that New God Flow.

As Noisey reports, a newcryptocurrency named afterKanye West is aboutto hit the marketplace. Deemed Coinye West, the
currency is supposed to become available Jan. 11.

In an interview with Noisey, the creators of Coinye West said they're remaining anonymous "in case kanye gets pissed off," but the currency is totally legitimate. With a tagline of"we ain't minin', we pickin'," Coinye West is created in the spirit of,
according to its creators, making it "easier for people to use cryptocurrency."

"Wechose to represent Kanye because he is and always has been a trendsetter, and he's always keeping things unique," the Coinye creatorsadded. "I can picture a future where Coinye is used to buy concert tickets, with cryptographically verified
virtual tickets, and other ideas I can't give away just yet."

Yeezus himself isn't exactly behind the ideajust yet, but that hasn't stopped the creators of Coinye West from reaching out
to the rapper in the hope that he'll invest - or, at least, not get mad about its existence.
Coinye
@CoinyeCoins

Fo"°w

(fi>kanye\vest Kanye, have you ever invested in bitcoin or
litecoin? What do you think of (S'ComyeVVest ?
7:52AM-31 Dec 2013
51 RETWEETS 15FA/ORITES

I
i
i

"Have you ever invested in bitcoin or litecoin?" itscreators asked Westvia Twitter. In the Noisey interview, they also invited

j

West to get in contact with them, offering the rapper 100,000 "COINYE," as it's being called.
Noword on how the rapper feels about having a form of currency named after him just yet.

|

f

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1/8/2014 8:07 PM

Coinye West, a Bitcoin Clone Named After Kanye West, Set to Launch|...

hfep://www.digitaltrends.com/cool-tech/coinye-west-kanye-west-real/

PRODUCT REVIEWS

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KANYE WEST IS NOW A BITCOIN CLONE
By Andrew Couts — January 2, 2014

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If you thought Internet-meme-based cryptocurrency Dogecoin was ridiculous, then KanyeWest-based altcoin Coinye West will probably just make you angry.

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Named after Yeezus himself, Coinye West is set to launch on January 11, at 11pm ET, according to the cryptocoin's creators, who tell Vice's Noisey blog that they hope it willhelp bring the nebulous
world of digital currencies into the mainstream.
Inside out: Audi reveals stunning next-gen
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"Our goal with Coinye West is to make it easier for people to use cryptocurrency," Coinye West's
unnamed creators tell Noisey. "Right now, it's kind of a dark art for people to mine coins. We plan on

The 2015 Volkswagen Golf R begs the question: Why get anything else?

releasing a front end to the "mining" programs called CoinyeMiner. It willmake things a lot more
simple and people will be able to make their own coins."
MOST COMMENTED

Coinye West's creators say they chose Kanye as their cryptocurrency mascot because "he is and

always has been a trendsetter." But despite the creators' enthusiasm for the rapper, West has not
endorsed the crypotocurrency, and is apparently no way involved with it - and that could be a
problem.

MOST SHARED

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"We're really not sure how Kanye is gonna react to this," says Coinye's creators. "We hope he loves it, but if he doesn't, he really isn't someone we want to piss off."
Typo keyboard case review

Coinye West is only the latest so-called altcoin to launch over the past year. Some, like Litecoin, trade at a fairly high value - though nothing close to the $750+ exchange rate Bitcoin currently enjoys. Most wallow in the fraction-of-a-penny range - a place where Coinye should probably get
comfortable.

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1/8/2014 8:10 PM

Cryptocurrency Named After Kanye West - XXL

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While many can argue whether or not Kanye West is the God he proclaims to be, Yeezus can add another convincing argument to his case. Now the face and inspiration of the newly

emerging form of cryptocurrency, Coinye West Kanye seems to be well on track as starting 01/11/14, Ye'willhave a currency named in his honor and he did nothing to launch it
Cryptocurrency is a decentralized peer-to-peer utilized medium used for digital exchanges on global-friendly internet platforms. The most celebrated and acknowledged type of cryp tocurrency is "Bitcoin."a currency exchange infamously known for it's frequent trade on black markets to purchase firearms and drugs. In the past the currency's value was listed at
$1,000 per Bitcoin.

The College Droupout isn't in anyway affiliated with the project, but in an interview with Noisey (httpy/notsey.vice.com/en.uk/read/screw-bitcoin-and-dogecoin-theres-a-new-kanyewest-themed-cryptocurrency-on-the-way)- the Coinye creators explained their thought process behind naming their Cyprtocurrency after 'Ye."Wechose to represent Kanye be
cause he is and always has been a trendsetter, and he's always keeping things unique. Ican picture a future where Coinye is used to buy concert tickets, with cryptographically verified virtual tickets, and other ideas Ican't give away just yet" The start-up founders also reassured their company's name isn't a publicity plea even adding an open invitation to the G.O.O.D. Music head-honcho. "We'd love if Kanye named dropped Coinye," said the founder. "I think he's gonna love that there's a CURRENCY named in his honor. We don't want to pay him off to name check us. but it'd be sick if he does so.

In-fact we're making an open invitation to Kanye: Get hold of us at coinyewest.com and we'll send you 100,000 COINYE on launch. A hundred thousand. Bitcoin started small too.

1 of 3

1/8/2014 8:13 PM

Cryptocurrency Named After Kanye West - XXL

htt4D://www.xxlmag.com/news/2014/01/kanye-west-cryptocurrency-coi.

and now look where it's at"

After reading the interview In it's entirety, you'd be convinced the group's founders are die-hard Yeezy stans. Intrue Kanye fan fashion, Coinye's official's website

(http://coinyewest.com/) quotes one of the rapper's most popular punchlinesas their mantra:"Idon't know whats better,gettin laidor gettin paid..."
Now I ain't sayin she a Gold Digger...

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1/8/2014 8:13 PM

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Creators claim that "the name 'Coinye' is intended solely as parody, not an indication or implication of endorsement or involvement"
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KanyeWest has demanded that CoinyeCoin, the Bitcoin-duplicate he inspired, should immediately end "development, sale, distribution and promotion" or else face litigation.
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On January 6, the creators of the cryptocurrency, who have capitalised on the
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The rapper's attorney, Brad D Rose, accused CoinyeWest, as it was known at the time, of trademark infringement, trademark dilution,
unfair competition and cyberpiracy.
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Despite Mr West's threat that he will sue any business that accepts the novelty currency, Coinyelaunched last night, 4 days earlier than it had originally intended, and posted on its website, "We are being attacked with fishsticks and must launch sooner." The altcoin's developers have responded to the rapper's attempts to shut it down by changing the name from CoinyeWest to Coinye, altering the logo image and launching the currency early.

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open letter to his

lof5

1/8/2014 8:14 PM

Bitcoin duplicate inspired by Kanye West launches to avoid legal action... http://www.independent.co.uk/life-style/gadgets-and-tech/bitcoin-dupli.

Onthe forumbitcointalk.com, CoinyeCoin developers alsoexplained that "Thename'Coinye' isintended solely asparody, notan indication or implication ofendorsement orinvolvement."

Interviews given totheWall Street Journal andArsTechnica indicate that theanonymous creators ofCoinye hold anti-establishment and anti-capitalist beliefs, having been quoted assaying that"anarchocapitalism iscoming, it can'tbestopped. Whether ithasa symbol that
looks likea dollar, a dog,or a cartoon pictureofa rapper,it's allthe same
thing."

Thecreators, who identify themselves "justa few guys who wantto take

cryptocurrency tothemainstream," tweeted the rapicon inDecember to
askhimhisthoughts on the project, andmorerecently toldVice they
"hope he loves this."
Gisele

Withthis development, the creatorsprobablyhavetheir answer.

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10. Matangi, M.I.A.

Pop provocateurs tend toage awkwardly, and M.IA. often tries alittle too hard to foment outrage (although it's hard totrump having Julian Assange as anopening act). Still, her fourth album isplenty provocative and outrageous-sounding: dance music that's twitchy like aslug ofThird World-exploiting coffee, shot through with neonbright digital distortion and mutated South Asian instrumentation. And her most potent weapon isstill herdry, venomous, word-savoring voice.

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9. Mole City, Quasi

Twenty years into their collaboration, singer/guitarist/keyboard-abuser Sam Coomes
andferal drummer JanetWeiss arestillon such a roll thattheirninthalbum isa

double, just 'cause. They're aswittily indignant asever, and Coomes aims his bile
inward as oftenasoutward. Thesharpest ofMole City's many homebrewed
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evocations oftheearly-'70s moment when Queen andTodd Rundgren and Badfinger were getting loud and weird is, naturally, called "Nostalgia Kills."

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Partsoul revivalist, partretro-Afrofuturist, allrobot - oh,fine, shejustplays oneon
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On a February night in 1997,the powerwent out at the club wherethe late cult hero Chiltonwas playing—but somebodyhad an acousticguitar, and somebodyelsehad a cassette recorder, and so this thrilling, off-the-cuff set of covers was preserved. Chiltonwas alwaysa contrarian, and he stopped makingbig artistic statements after his early-Vos band BigStar brokeup, so this is just a documentofa greatentertainer
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l. Yeezus, Kanye West Kanyeis the best there is, and he's still not as good as he thinks he is. Has there ever been another great album this bitter, this entitled, this abrasively unsatisfied —or this self-aware about it? (See its most-quoted joke: "In a French-ass restaurant/Hurry up with my damn croissants.") Yeezus is brief, spare, nasty, and as charismatic as a cult leader. Its music grinds sourly or lurches like an old rollercoaster; West's voice drips contempt or hides behind frigid Auto-Tune effects. But Yeezus,has he ever got raw
power.

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McBizzy Hell yeah it's Yeezus

MattCasale

Seriously, you put Kanye on here but not Eminem? Shame on you.

ScottValentire

Full Circle by Half Moon Run. Hands Down.

GregMason No list is complete without The National's Trouble Will Find Me.

*

MeeBrr

I

No no no no no no no. Kanye is to music what Kim Kardashian is to television: fake, ridiculous and a piss-poor representation of intelligent life on the planet.

Litrigol

«H&3&W

No, I mean, where are Kurt Vile and Arcade Fire ones?

JoshVfckers

Everytime some one says something positive about Kanye West, a fairy dies.

AlexanderZhukov

God is dead in the world where yeezus is on top.

JeffConanVargon

It's great to see this Alex Chilton album on this listl Thanks Dougl

C£]
'The Electric Lad/' by Janelle Monae featuring Miguel, Erykah Badu, Cee Lo, and Prince was so good and revolutionary. She raps and sings like Lauryn Hill. It's a shame it didn't get any Grammy nominations.

AustinJames

this is the biggest joke of a list I have seen. How are you rating these albums. How do you leave off an Artist who had tie two number 1 albums in the same year and the biggest selling album of the year in Justin

http://entertainment.time.com/2013/12/04/arts-and-entertainment/slide/top-10-albums/

1/9/2014

Top 10 Albums | Top 10 Everything of 2013 - Arts and Entertainment | TIME.com
Timberiake. If Ididn't stumble upon this article Iwould have never seen this same as no on readsTIME magazine.... you are a joke of a magazine and aricle writer.

Page 5 of 6

ViduaDiabolusNiger

Music is not your business but stillbetter than very specialized magazines, pity is that rock is dead to you, and this is idiocyprimary! ...LikeClockworkisa masterpiece of an artistwith Rock in the veins, music is art!!! MBV??
Makes me sleep. The Real Rock is dead to you, unfortunately

lordmeta

Really? http^/www.taylorclark.co\vp-content/uploads/2013/04/picard.jpg

IndieSongADay

I'll never getmusic like Yeezus, let alone it making a Top 10of the Year list.
The best songs of 2013 are here

indie best of 2013(@ndiesongaday)

coyotebandt3

@MattCasale Probablyb/c MMLP2is a pretty bad album.

jJJsjS FuckingMagic
@MattCasalethey both suck

coyotebandtS

@MeeBrr Uhh, no.There's a reason every single one of his albums has been widelycritically acclaimed and has inspiredbasicallyeveryone inrap. There's a reason hs album MBDTF is considered one ofthe greatest albums
every created in music.

KerusNIaw

i bet you bve nirvana, the beatles, and pinkfloyd you sheep:")

StevenTanner

©Litrigol Arcade Fire mustbe the mostoverrated band intheworld. They're aright, butvery pretentious and
overwrought

coyoteband!3

©JoshVickers KanyeWest is a great producer.Kanye West is an influential icon in rap. KanyeWest created one of the greatest albums in music. KanyeWest has one of the most consistent discographiesin music right
now with all6 of his albums getting HUGEcriticalacclaim.

coyotebandt3

@AlexanderZhukov u mad cuz u bad

mossitabrenancs

@AustinJames Britney Spears had plenty of numberone albums, but her muse sucks!

scottsurette

©Austin James a number 1 abum on tie chartshas absolutely nothing to do with how good thealbum is. Ilove the 20/20experience, butthat'sjust a silly argument. One Direction's albumreachednumber1 and solda ton of
copies, does that mean in yourview it belongs on this list?

D.Ubben

©IndieSongADay I personally think some of the songs on yourplaylist are awful, but Ido agree on Yeezus. So
overrated.

EmiliaBajena

©StevenTanner @LitrigolThey have been makingmusic fora very long time, I'vebeen a fan foralmosta decade. Idon't think that just because the worldstarted recognizingtheir talent recently makes them pretentious.
If Iwas in the industry for that long Iwouldn't give a crap either.

DamienWillis

©StevenTanner ©Litrigol But I loves dem

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Page 1 of38

best music of 2013

50 favorite albums

NPR Music's 50 Favorite Albums Of 2013
December 10, 2013 8:07 AM

Source: NPR

Credit: Meredith Rizzo

Conversations About Our
Albums Of The Year

These are the albums we loved the most this

year. In what we've written about each one
below, you can see what we felt should be

rewarded, what shook us up and what sucked us
The Best Indie Pop Of
2013
5 mln 24 sec

in over the 12 months of 2013.

Not every one of the 22 different people with

bylines here agree on which albums did any of
More Than Just "Yeezus": The Year In

that to them — we don't listen the same way, or

Hip-Hop

for the same reasons — but you'll read the word "warm" more than once (as applied to an indie
songwriter, a country singer and two electronic

Classical And World

Music Highlights

producers). We were seduced by darkness at least five times (electronic, rock, classical, metal) and loved sounds that we call "delicate" (three

out of four made by men). "Wry" hit the spot twice (country singer again, and a pair of

http://www.npr.org/blogs/bestmusic2013/2013/12/10/249243 87 l/npr-musics-50-favorite-al...

1/9/2014

Page 21 of 38

KACEY MUSGRAVES

SAME TRAILER DIFFERENT PARK

The biggest quiet story in popular music this year involved women
singer-songwriters who kept their tongues in their mouths and told

the truth of ordinary lives. Texas-born, Nashville-based Kacey
Musgraves set the standard with a major label debut that sounded

like current country while avoiding all the cliches about Chevys and

flags and spring break debauchery. Instead, Musgraves sang in her
been-there-done-that drawl about restaurant workers waiting for a

break, small-town kids slowly morphing into the parents they resent
and strong women who know that a hook-up might be just a hook-up and Prince Charming is sometimes best kept as a memory. Then

there's the anthem "Follow Your Arrow," the "Same Love" of country, which turned YOLO into a means of real liberation. By year's end,
Same TrailerDifferent Park was winning awards, Musgraves was
writing songs with Katy Perry, and she had fully proven that country belongs as much to women with smarts as to men with trucks. —Ann
Powers

"Merry Go "Round"

KANYE WEST YEEZUS

http://www.npr.org/blogs/bestmusic2013/2013/12/10/249243 87 l/npr-musics-50-favorite-al...

1/9/2014

Page 22 of 38

Right before Yeezus, his sixth studio album, crashed into the public sphere in June, Kanye West told the New York Times, "I understand culture. I am the nucleus." The album almost justifies such supreme egotism. Soundwise, it builds something new, juxtaposing avantgarde industrial and electronic innovations with the High Romantic
hip-hop West had already perfected. And then there's what West

says in its forty rampaging minutes. Sex fantasies and a dirty lover's despairing mea culpas emerge from West's confused id, while his exacting superego places his urges within the context of American racism, international celebrity and the infinite void of consumerist decadence. (There are jokes, too, Richard Pryor style.) The most

Blood On The Leaves

Kanye West
6:00

"i 'i'iiLiif

LA SANTA CECILIA
TREINTA DIAS

2013 was a big year for the LA-based La Santa Cecilia after years of
touring, recording and hustling a place for themselves in Latin music. The group was signed by a major label. Its stellar vocalist La Marisol was invited to sing on the Elvis Costello/Roots collaboration released

this year. The band was featured in the pages of major U.S.

newspapers and of course we at Alt.Latino continued to appreciate its unique musical vision, and especially Treinte Dias, a forwardlooking mix of folklore, jazz, cumbia and rock 'n' roll spirit. —Felix
Contreras

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mr<

Sure you want to be different, you don't want to be a sheep, blindlyfollowingthe herd wherever it goes. You don't wanna be a "stan," unable to see any fault with the new work of an artist whose work you've loved before. But what are you gonna do? Lie? Just so you can be different, just to
buck a trend? Just to prove a point? That'd be stupid. Much like three years ago, when Kanye West topped every year-end list in the universe with My
Beautiful Dark Twisted Fantasy album, and its centerpiece song "Runaway," we seem to finding a similar state of unanimity in feeling about this year's Yeezus and "New Slaves." You gotta give in. If

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you're gonna be honest at least. Kanye's operating at a higher level of artistry than any other artist
on the planet right now.
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It's apparent from jump. Right from the opening synth squalls of "On Sight." From the electro tick-

DO ANDROIDS DANCE

tick-tick. From the bass turned way past distortion. This is something new. Sounds you haven't hear

Todd Terry Made a Trap Album
PEPSI PULSE

before. Like a spaceship crashing in your backyard. You cant help but look, you can't help but
approach. Out of curiosity if nothing else at first. You're being pulled forward by your ears. Kanye's
making a statement. "I'm from the future. I'm here to show you how it's going to be." It's not all going to be pretty. It's not all going to fun. The sounds are discordant, abrasive. The lyrics harsh, abusive. It's nasty. But it's thrilling. Through the whole album. There's no let up. Song after song. Start to finish. (Only ten songs. That's all it takes.) Especially now, six months after its release, Yeezus has revealed itself to be one coherent set piece. With its sound, and its themes. On message, on point. "My momma was raised in an era when/Clean water was only served to the fairer skin." That's the world I'm coming from, he's saying. That's the world you made. I didn't make it, and I

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don't like it. So I'm tearing the whole thing down and starting a new one.
That's what art is, right? Making something new. Even if it's just a little different (and Yeezus is a lot different), making something new that can show people a different perspective, a different viewpoint. Musically, Kanye is glowing right now. Like a piece of Kryptonite. Yeezus is something we've never seen before. It's a huge accomplishment. A triumph. What are you gonna do? It's the best. —Dave Bry

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The fact that French Montana's album is even on this list makes me question it's credibility.
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L Yeezus, Kanye West
He can't be serious. Thats what all the late-nighthosts and lists of"craziest Kanyequotes" toldus about Kanye Wast in 2013. And sure, he's the one who said that thingabout beinga god, and that other thingabout hurrying up with his damn massage. Butlike any human (even one who raps, "Nosports bra/Lets keep itbouncing"). Kanye's got every right to be serious. Asserting that freedom on Yeezus, he exposes the rage of a wildly ambitiousartist confoundedby the wily shape of racismtoday. He smashes the atoms of his fears, ego, and sex drivetogether fortracks like"BlackSkinhead,' featuringrhymes about "coon s—"and a beat deddedly free of Under Armour.(Itended up soundtracking a popular IV spot for smartphones.) Mostly, his sound obsession runs riot,fromthe blown-speaker Wax of"On Sight' to the abundance of dancehailsingers and samples to "Bloodon the Leaves,"withits unflinching appropriationofNinaSimone's "Strange Fruit"The overriding message: Listenclosely.Kanyewillnever validateanyone's celebrityworship.On Yeezus, though, he throws
down serious thunderbolts.

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Best Track: "Blood on tie Leaves" fhttp://www.mtv.comAr'ideosAriisc/948751/bloodon-the-leaves-live.ihtmn

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1/9/2014

Top 10 I 10 Best Albums of 13: Nick Catucci's Picks | Photo 10 of 10 | EW.com

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the discussion.

rmsmty

Share &

i-o0n

•Pa|§|amhirwlnd.
Pi!

9 Humorous Family
<itr. ago

icfSR

Loved thaty you had Kacey and Miley where you did, but, what, no Daft Punkl
pArfiothi one that EW didn't even review bu most incredible was Patty Griffin's
American Kid. Maybe one day before I'm in the ground I'll 'get' Kanye, but so far it's just Toise.
Roply • Share .•

Society

£|

Color Me Impressed* in*ind'®rr;cr;[na3C-

,ajlBk Wow this list is a joke. Earl Sweatshirt? Ok. Drake?. Fine. Local Natives is a poor attempt to insert "indie cred." Miley Cyrus at number 3? Wtf?l That album was awful I The only ones on this list I agree with are Vampire Weekend and Kanye. Where's Tegan & Sara? Daft Punk? Deerhunter? Sad, sad list...
d" v . Reply • Share •

jfe

BrendaBarrett.* CoteWe im&sssan-s iiiorah ajju

tfliftt, ITA. Not sure what Kool-Aid EW and other music critics have been drinking, but this latest steaming Kanye effort is nothing but noise. It's baffling the credence and attention that is given to this
talentless, toneless hack.
parentsociety.com/perenfng/1un
2'*

Ropiy • Share

The Beta Max- s mottn 33c
Liked Yeezus but no EMINEM? wow.
S'1'

• Reply • Share;

Kyle Sharp, s mumn aco

Marshall Mathers LP2 and Ariana Grande's Yours Truly top my list.
4^ 1v . Reply • Share .

la8perCornKings~» Kvi« Shan.,.3 month ^

fours Truly > » » » » » » » » » Bangerz
^ • Repiy * Share >

Kyle Sharp ~
Julia Roberta Walka

PREACHI

the Red Carpet Wth
Her Best Friend

Rftwly

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joogle Play is giving away 'Yeezus' and top singles from 2013 | The Verge
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Spotify, now may be your best chance to catch up on the year's biggest hits. Update: Google tells us that different promotions are being offered in differentregions.
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1/9/201 <•

EXHIBIT C

Lit Q.: 9

Prior U.S. Cls.: 21, 23, 26, 36, and 38

Reg. No. 3,648,799

United States Patent and Trademark Office
TRADEMARK
PRINCIPAL REGISTER

Registered June 30,2009

KANYE WEST

MASCOTTE HOLDINGS, INC. (CALIFORNIA

FIRST USE 2-0-2004; IN COMMERCE 2-0-2004.
THE MARK CONSISTS OF STANDARD CHAR ACTERS WITHOUT CLAIM TO ANY PARTICULAR

CORPORATION)
410 PARK AVE., 10TH FLOOR C/O PRYOR CASHMAN LLP NEW YORK, NY 10022 FOR: MUSICAL SOUND RECORDINGS; AUDIO VISUAL RECORDINGS, NAMELY, COMPACT DISCS, TAPE CASSETTES, AUDIO CASSETTES, AUDIO TAPES, AUDIO DISCS, RECORDS, CDROMS, VIDEO TAPES, VIDEO CASSETTES, VIDEO DISCS, DVDS, DATS, MP3S, AND LASER DISCS, ALL FEATURING MUSIC; DOWNLOADABLE MU SICAL SOUND RECORDINGS; DOWNLOADABLE VIDEO RECORDINGS FEATURING MUSIC; SUN GLASSES, IN CLASS 9 (U.S. CLS. 21, 23, 26, 36 AND 38).

FONT, STYLE, SIZE, OR COLOR.
THE NAME "KANYE WEST' IDENTIFIES A LIV
ING INDIVIDUAL WHOSE CONSENT IS OF RE CORD.

SN 78-499,390, FILED 10-13-2004.
JOHN WILKE, EXAMINING ATTORNEY

Int. Q.: 16

Prior U.S. Os, 2, 5,22,23, 29, 37, 38, and 50
United States Patent and Trademark Office
TRADEMARK
PRINCIPAL REGISTER

Rgg ^ ^ ^
Registered June 30,2009

;KAIOTfyTEi!r

MASCOTTE HOLDINGS, INC. (CALIFORNIA CORPORATION)
VARD2ND FLOOR2ND FLOOR SHERMAN OAKS, CA 91403

THE MARK CONSISTS OF STANDARD CHAR

C/O KELLOGG AND ANDELSON ACCOUNTANCY

ACTERS WITHOUT CLAIM TO ANY PARTICULAR FONT, STYLE, SIZE, OR COLOR.
THE NAME "KANYE WEST' IDENTIFIES A LIV ING INDIVIDUAL WHOSE CONSENT IS OF RE
CORD.

CORPORATION, 14724 VENTURA BOULE-

FOR: POSTERS; PHOTOGRAPHIC PRINTS; PHO TOGRAPHS , IN CLASS 16(U.S. CLS. 2,5,22,23,29,37,
38 AND 50).

SN 78499,402, FILED 10-13-2004. JOHN WILKE, EXAMINING ATTORNEY

FIRST USE 2-0-2004;IN COMMERCE 2-0-2004.

Int. a.: 25

Prior U.S. Os.: 22 and 39

TT . J „

United States Patent and Trademark Office
TRADEMARK
PRINCIPAL REGISTER

^

Reg. No. 3,648,801

Registered June 30,2009

:MAimwEsr

CORPORATION) C/O KELLOGG AND ANDELSON ACCOUNTANCY CORPORATION, 14724 VENTURA BOULEVARD2ND FLOOR2ND FLOOR

MASCOTTE HOLDINGS, INC. (CALIFORNIA

THE MARK CONSISTS OF STANDARD CHAR ACTERS WITHOUT CLAIM TO ANY PARTICULAR FONT, STYLE, SIZE, OR COLOR.
THE NAME "KANYE WEST' IDENTIFIES A LIV ING INDIVIDUAL WHOSE CONSENT IS OF RE
CORD.

SHERMAN OAKS, CA 91403

FOR: CLOTHING, NAMELY, T-SHIRTS, TANK TOPS, SWEAT SHORTS, IN CLASS 25 (U.S. CLS. 22
AND 39).

SN 78-499,409,FILED 10-13-2004. JOHN WILKE, EXAMINING ATTORNEY

FIRST USE 2-0-2004;IN COMMERCE 2-0-2004.

Lit. Q.: 26

Prior U.S.Os.: 37, 39, 40,42, and 50
United States Patent and Trademark Office
TRADEMARK
PRINCIPAL REGISTER

Reg. No. 3,648,802 Registered June 30,2009

,*««»

KANYE WEST

MASCOTTE HOLDINGS, INC. (CALIFORNIA CORPORATION) C/O KELLOGG AND ANDELSON ACCT. CORP.
14724 VENTURA BOULEVARD, 2ND FLOOR SHERMAN OAKS, CA 91403 FOR: ORNAMENTAL NOVELTY BUTTONS, IN

THE MARK CONSISTS OF STANDARD CHAR ACTERS WITHOUT CLAIM TO ANY PARTICULAR

FONT, STYLE, SIZE, OR COLOR.
THE NAME "KANYE WEST' IDENTIFIES A LIV ING INDIVIDUAL WHOSE CONSENT IS OF RE
CORD.

CLASS 26 (U.S. CLS. 37, 39,40, 42 AND 50).
FIRST USE 4-16-2008; IN COMMERCE 4-16-2008.

SN 78-499,411, FILED 10-13-2004. JOHN WILKE, EXAMINING ATTORNEY

Int a.: 35

Prior U.S. Os.: 100,101, and 102
United States Patent and Trademark Office
SERVICE MARK
PRINCIPAL REGISTER

Reg. No, 3,648,803 Registered June 30,2009

,*««»*

KANYE WEST

MASCOTTE HOLDINGS, INC. (CALIFORNIA CORPORATION) C/O KELLOGG AND ANDELSON ACCT. CORP. 14724VENTURA BOULEVARD, 2ND FLOOR
SHERMAN OAKS, CA 91403
FOR: ON-LINE ORDERING SERVICES AND ON

FIRST USE 24-2004; IN COMMERCE 2-0-2004.

THE MARK CONSISTS OF STANDARD CHAR ACTERS WITHOUT CLAIM TO ANY PARTICULAR

FONT, STYLE, SIZE, OR COLOR. LINE RETAIL STORE SERVICES, ELECTRONIC RETAILING SERVICES VIA COMPUTERS, AND
RETAIL STORE SERVICES AVAILABLE THROUGH THE NAME "KANYE WEST' IDENTIFIES A LIV ING INDIVIDUAL WHOSE CONSENT IS OF RE
CORD.

COMPUTER COMMUNICATIONS, ALL OF THE AFORESAID FEATURING RECORDED PRODUCT, MUSIC RELATED ITEMS, CLOTHING AND AC CESSORIES THEREFOR, PRINTED PROMOTION AL MATTER SUCH AS POSTERS, BOOKS AND

SN 78-499,413, FILED 10-13-2004. JOHN WILKE, EXAMINING ATTORNEY

PUBLICATIONS, NOVELTY ITEMS AND ORNA MENTS, IN CLASS 35 (U.S. CLS. 100,101 AND 102).

Int. a.: 41

Prior U.S. Os.: 100,101, and 107

Reg. No. 3,648,804

United States Patent and Trademark Office
SERVICE MARK
PRINCIPAL REGISTER

Registered June 30,2009

KANYE WEST

MASCOTTE HOLDINGS, INC. (CALIFORNIA CORPORATION)
C/O KELLOGG & ANDELSON ACCOUNTANCY
CORP.

CAL VIDEOS, PHOTOGRAPHS, AND OTHER MULTIMEDIA MATERIALS; ENTERTAINMENT
SERVICES, NAMELY, PROVIDING PRERECOR DED MUSIC, ALL ONLINE VIA A GLOBAL COM PUTER NETWORK; ENTERTAINMENT IN THE NATURE OF TRAVELING TOURS FEATURING

14724VENTURA BOULEVARD, 2ND FLOOR SHERMAN OAKS, CA 91403
FOR: MUSIC COMPOSITION AND TRANSCRIP

MUSIC, IN CLASS 41 (U.S. CLS. 100,101 AND 107).
FIRST USE 8-0-2004; IN COMMERCE 8-0-2004.
THE MARK CONSISTS OF STANDARD CHAR ACTERS WITHOUT CLAIM TO ANY PARTICULAR

TION FOR OTHERS; ENTERTAINMENT IN THE NATURE OF A LIVE MUSICAL PERFORMER, MUSICAL BAND OR MUSICAL GROUP; ENTER
TAINMENT IN THE NATURE OF LIVE PERFOR

MANCES BY A MUSICAL ARTIST, MUSICAL GROUP OR MUSICAL BAND; ENTERTAINMENT
IN THE NATURE OF VISUAL AND AUDIO PER

FONT, STYLE, SIZE, OR COLOR.
THE NAME "KANYE WEST' IDENTIFIES A LIV ING INDIVIDUAL WHOSE CONSENT IS OF RE
CORD.

FORMANCES BY A MUSICAL ARTIST, MUSICAL GROUP AND MUSICAL BAND; ENTERTAIN MENT, NAMELY, LIVE MUSIC CONCERTS; EN TERTAINMENT, NAMELY, PERSONAL APPEARANCES BY A MUSICIAN, MUSICAL GROUP OR MUSICAL BAND; ENTERTAINMENT SERVICES, NAMELY, PROVIDING A WEB SITE FEATURING MUSICAL PERFORMANCES, MUSI

SN 78-499,414, FILED 10-13-2004.

JOHN WILKE, EXAMINING ATTORNEY

EXHIBIT D

Klarberg, Ryan S.

REDACTED

From: Matthew Mellon <777mellon@gmail.com<mailto:777mellon(a).gmail.com»
Date: January 5, 2014 at 9:09:13 PM EST

To: Michael Guido <mguido@.ccgglaw.com<mailto:mguido@.ccgglaw.corn>> Subject: Fwd: Kanye WestLegal council Michael Guido

Forwarded message From: Coinye West<comvewest@.gmail.com<mailto:coinvewest(a).gmail com»
Date: Sat, Jan 4,2014 at 6:54 PM

Subject: Re: Kanye West Legal council Michael Guido

To: Matthew Mellon <777mellon(atgmail.com<mailto:777mel1on(S)pmai1 r.mT,»

I dont know. I don't want to inconvenience him. A simple few second video of him telling us he wants coinyes would suffice, but i understand you might be concerned about that hitting the media. As I'm well aware you guys are going to try and get my identity I'm not comfortable with a phone call, and skype would be too slow through the proxies i use.
I'm totally willing to discuss things with you guys. In email, or on IRC which is internet relay chat. I can give you the step by step to get connected if you dont have access to a geek when its time to talk. It's just that before we actually risk ruining the currency by "printing" a crapload of it to give to kanye, I'm going to need some kind of proof its actually going to him, by getting
some sort of verification from the man himself.

Thank you

On 1/4/2014 4:39 PM, Matthew Mellon wrote: How would like to Kanye to confirm that?

On Sat, Jan 4,2014 at 6:35 PM, Coinye West
<coinvewest@gmail.com<mailto:coinyewest(a),gmail.com» wrote:

I didn't say yes. Someone else with access to this email said yes. I'm not talking on any telephone and neither is anyone else involved.
If you want to talk, contact me in email. We're anonymous and we're keeping it that way.
Also, I'm not giving up a single millionth of a percent until i get some kind of verification that kanye actually knows a deal is being made. I still don't trust you, and I sure as hell don't trust lawyers.

On 1/4/2014 4:16 PM, Matthew Mellon wrote:

I am happy to talk prior to 10:00am.. Let me know I can give you the lay of the land.
+19174599067<tel:%2B19174599067>

On Sat, Jan 4,2014 at 6:03 PM, Coinye West

<coinvewest@gmail.com<mailto:coinvewest(g)/gmail.com» wrote:
Yes.

On Sat, Jan 4, 2014 at 3:00 PM, Matthew Mellon
<777mellon@gmail.com<mailto:777mellon@gmail.com>> wrote:

I am happy to speak then.. Coinye shall I patch you in?

On Sat, Jan 4,2014 at 3:38 AM, Michael Guido

<mguido(a)>ccgglaw.com<mailto:mguido(g)/ccgglaw.com» wrote: Ok. As you know I am 10 hours ahead ofNY. And boarding a plane now. I will be free at

about 10 am mytime tomorrow which will be about 11:30pm my time Saturday evening. Is that
something that can work?

On Jan 4, 2014, at 1:15 PM, "Matthew Mellon"

<Matmew@coinapex.com<mailto:Matthew@/coinapex.com>> wrote:
Hi Michael:

Coinye has requested to speak to you directly being Kanye West's legal council.
Best,
Matthew

"CONFIDENTIAL"

Information Classification: Confidential

The information contained in this e-mail, and any attachment, is confidential and is intended

solely for the use of the intended recipient. Access, copying orre-use ofthe e-mail orany attachment, or any information contained therein, by any other person is not authorized. Ifyou are not the intended recipient please return the e-mail to the sender and delete it from your
computer. Although we attempt to sweep e-mail and attachments for viruses, we do not guarantee that eitherare virus-free and accept no liability for any damage sustained as a result of
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"CONFIDENTIAL"

Information Classification: Confidential

Theinformation contained in this e-mail, andany attachment, is confidential andis intended

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"CONFIDENTIAL"

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The information contained in this e-mail, and any attachment, is confidential and is intended

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computer. Although we attempt to sweep e-mail and attachments for viruses, we do not

guarantee that either are virus-free and accept no liability for any damage sustained as a result of
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EXHIBIT E

Pryor Cashman llp
7 Times Square, New York, NY 10036-6569 Tel: 212-421-4100 Fax:212-326-0806

New York | Los Angeles
www.pryorcashmaacom

Brad D. Rose
Partner

Direct Tel: 212-326-0875
Direct Fax: 212-798-6369

brose@pryorcashman.com

January6, 2014
VIA E-MAIL fcoinyewestia)gmail.coml
Re:
Dear Sir or Madam:

Infringement of KAYNE WEST Mark and Other Violations

This law firm acts as litigation counsel for Kanye West and his affiliated companies. As
you are aware, Mr. West is an internationally renown musical artist, songwriter, producer, film director and fashion designer, to name just a few of Mr. West's endeavors. Mr. West has won twenty-one Grammy Awards, making him one of the most awarded artists of all-time. He has

been named one of the 100 most influential people by Time magazine and is routinely listed by
Forbes as one of the most successful people in the world.

Mr. West's tremendous success and notoriety has catapulted the KANYE WEST brand

into a commercial asset of incalculable value. In addition to his common law rights, Mr. West owns numerous federal trademark registrations for the KANYE WEST mark for various goods and services as well as several pending applications. See, e.g., U.S. Reg. Nos. 3,648,799; 3,648,800; 3,648,801; 3,648,802; 3,648,803; and 3,648,804. Without doubt, the KANYE WEST markis famous and is entitled the broadest protection underthe law.
We write to you concerning your unauthorized use of the COINYE WEST mark in

connection with a purported cryptocurrency that may be available on January 11, 2014. We have recently learned that you are promoting the COINYE WEST cryptocurrency through the
<coinvewest.com> website, on Facebook at <facebook.com/coinvewest> and on Twitter at

<twitter.com/CoinveWest>. The COINYE WEST mark is substantially similar to the KANYE WEST mark in sight, sound, meaning and commercial impression. Interviews with the founders

of the COINYE WEST cryptocurrency leave no doubt that your clear intent is to trade upon the
goodwill associated with the KANYE WEST mark and Mr. West's international fame and

notoriety. In particular, several news sources have quoted the developers as stating "We chose Kanye because of his trendserting abilities and his originality," and also that you have decided to

remain anonymous "in case Kanye gets pissed off." Such statements support a finding that your
infringement is blatant and willful.

Given Mr. West's wide-ranging entrepreneurial accomplishments, consumers are likely to mistakenly believe mat Mr. West is the source of your services or is, at the very least,
affiliated with, or has sponsored or endorsed the cryptocurrency. The likelihood that consumers will be confused is heightened by the unauthorized use of an image of Mr. West on the coin:
1290471 v2 10859.00017

I Pryor Cashman llp
January 6,2014 Page 2 of 3

Your actions constitute, inter alia, willful trademark infringement, unfair competition,

j

cybeipiracy and dilution in violation of Sections 32(1),43(a), 43(c) and 43(d) of the LanhamAct, and subject you to monetary damages including treble damages based on the willful nature of the infringement.

I ( |
|

In addition to the Lanham Act claims, you are also liable under the Copyright Act for misappropriation of Mr. West's music videos embedded in the <coinyewest.com> website. Your actions also violate Mr. West's right of publicity under state law, which subjects you to
further liability.

| I |
f
I

Mr. West takes these violations of his intellectual property very seriously and seeks to

I

resolve this matter without resort to litigation including filing an application for a temporary restraining order. Accordingly, please immediately confirm that you and all of your affiliated
companies, employees, consultants, agents and representatives will immediately:
1. cease and desist from any and all use of the mark COINYE WEST and any

| f
f
j

versions ofthat mark including COINYE;
2. cease and desist from any and all development, sale, dstribution and promotion of any and all products and services in connection with the mark
KANYE WEST, or any names or marks confusingly similar to KANYE
marks;

f
f |
I
I

WEST, including, but not limited to, the COINYE WEST and COINYE

j

3. cease and desist from any and all use of Mr. West's copyrighted material including his music videos;

| f

1

4. deactivate the website located at <coinvewest.com>. unlock the domain
name to allow it to be transferred and provide us with the authorization

|

{
t

code to facilitate such transfer;
5. deactivate all social media accounts created and/or used in connection with

f

}

the COINYE WEST mark, including, but not limited to, the Facebook
account located at <facebook.com/coinvewest> and the Twitter account
located at <twitter.com/CoinveWest>; and

|
f
f

1290471 v2

10859.00017

•Pryor Cashman llp
January 6, 2014 Page 3 of3

6. cease all use of Mr. West's name, image or likeness in connection with any
product or service.

We further demand that you immediately confirm to ns. in writing, no later than 5:00

p.m. E.S.T. on January 6. 2014. your intent to comply promptly with our demands, failing which our client will proceed with the necessary measures to protect its valuable rights, including, if necessary, securing injunctive relief in court against you, and recovering all appropriate damages,
includingtreble damages, attorney's fees and costs.

If you fail to comply with these demands, we will notify the cryptocurrency community at large ofyour infringing actions and pursue all legal remedies against any business that accepts the puiported COINYE WEST currency. Specifically, Mr. West will pursue claims of contributory trademark infringement and contributory unfair competition, among others, against any entity that
accepts or exchanges the COINYE WESTcurrency.

Should you wish to discuss any aspect of this matter, we suggest that you have your legal
representative contact the undersigned before the above-referenced deadline.

The foregoing is not Intended as a comprehensive statement ofour client's rights orposition, and nothing herein shall be deemed to be awaiver ofany ofour client's rights at law or in equity.
Very truly yours,

'tyih>*9^
Brad D. Rose

cc:

Michael Guido, Esq.

1290471 v2

10859.00017

EXHIBIT F

Kanye's Lawyer Moves to Block Coinye - Digits - WSJ

htup://blogs.wsj.com/digits/2014/01/07/kanyes-lawyer-moves-to-blo..

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Kanye's Lawyer Moves to Block Coinye
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BITCOIN COINYE

VIDEO ! COMMENTS (6)
COIWE WEST KANYE WEST VIRTUAL CURRENCIES

By DANNY YADRON

Lawyers for Kanye West filed cease-and-desist papers against the seven anonymous coders behind Coinye West, a virtual currency that went from chatroom joke to Internet
sensation last week.

The legal document, dated Jan. 6, includes an image of Coinye - a cartoon representation of West on a gold medallion. West's lawyer argues trademark infringement.

Don't Miss [?]

"Given Mr.West's wide-ranging entrepreneurial accomplishments, consumers are likely to mistakenly believe
that Mr. West is the source of your services," wrote Brad Rose, a partner at Pryor Cashman LLP, which has previously
worked for West.

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Hoping to keep pace with the self-assured, brash West, the techies aren't backing down. Instead, they are

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Digits delivers breaking news and insights about the technology landscape, including Q&As with newsmakers, product news and strategic moves. Send news items, comments and questions to diglts@wsj.com. Uk» •Digitson Facebook

moving up Coinye's release date to as early as Tuesday night. Looking for surer footing, they changed the name of the currency from Coinye West to just "Coinye" and moved their website from a .com domain name to one registered In
India.

Kanye, not Coinye—Cetty

Popular Now

"We want to release this to the public before the man can try to crush it," one of the coders said in a Skype text interview Monday night. "They'll still come after us, but that's
OK."

41

No to Military, Yes to
Hair: The Most and Least Stressful...

So, how did the world-famous rapper get in a legal feud with seven nerds who refuse to
share their names or locations?

Top 10 Revelations As virtual currencies like bitcoin and litecoin have taken off, copycats have emerged. Some offer slight tweaks to the bitcoin code to account for fraudsters or improve transactions. Others, such as BBQcoin and dogecoin, appear more as jokes than
legitimate crypto-currencies.
From Robert Gates's
Memoir

Still, the proliferation of virtual coin prompted the group of seven coders to ask themselves, what else could you name a virtual coin? "We said Coinye West and we were

When It's OK To Love Someone at the

lof4

1/8/2014 8:32 PM

Kanye's Lawyer Moves to Block Coinye - Digits - WSJ

http://blogs.wsj.com/digits/2014/01/07/kanyes-lawyer-moves-to-blo.,

like, 'Holy... we gotta make that," one of themsaid.
The Internet, predictably, became obsessed. West, an internationally known "musical artist, songwriter, producer, film director and fashion designer," stayed silent, according to his lawyer. Rose didn't return a request for comment. In writing, Rose requested that the people behind Coinye stop using the name or any
variation of it, hand over their website and deactivate Facebook and Twitter accounts for Coinye.

Office

San Francisco to Tax

'Google Buses'

Ifthey don't comply, Rose threatened to "notifythe cryptocurrency community at large of your infringing actions and pursue all legal remedies against any business that accepts the purported COINYEWEST currency." As with any virtual currency, there is a chance Coinye could take off if Internet users decide it has value. And the spat with West willcertainly give Coinye extra publicity.
Or as West once sang: "That that don't kill me can only make me stronger."

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Comments (5 of 6)
1:16 pm January 8, 2014
OhlGettt wrote:

View all Comments »

That's pretty clever including a linefrom the song Stronger inthis story, whichis the song that Kanye West stole Daft Punk's music wholesale, and made it worse. Pretty clever indeed.
5:39 pm January 7, 2014
Robinz wrote:

Dodecoin is the ONLY real currency - all SMARTand SAVVY and BLEEDING EDGE INVESTORS (unlikethe neckbeard losers who love bit coin) need to see the opportunityfor
HUGE GAINZ

3:04 pm January 7, 2014

CrazyMlner wrote:

dogecoin is a legitimate crypto-currencies. And remember... what was bitcoin at the beginning
?

11:00 am January 7, 2014
Barackazillion wrote:

Allthey have to do is make it a paper currency and you are fine. Google Barackazillion for a
laugh!
10:13 am January 7, 2014

General Ulysses S Grant wrote:

If you see the President, tell him from me that whatever happens there will be no turning back.

3 of 4

1/8/2014 8:32 PM

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1/8/2014 8:32 PM

Kanye West Unleashes Lawyers on 'Coinye' Altcoin

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Bitcoin > Bitcoin News > Technology > Altcoins

Kanye West Unleashes Lawyers on 'Coinye' Altcoin
Nermin Hajdarbegovic | Published on January 8, 2014 at 11:30 GMT | Altcoins, Companies, News,
Startups
Tv»etKl76 Shire

A beginner's guide to bitcoin
Bitcoin is a digital currency that is being used increasingly all over the world. Find out more about how it works and how you can use it with our straightforward guides.

{±D

1111 j_

«

What is bitcoin?

It'sa decentralized digitalcurrency

176 F apper-tumed-entrepreneur Kanye ->•—-west has taken legal action against

Tw*e?Jie creators of Coinye West, a
rrartgue-in-cheek digital currency that

w|as supposed to launch this week.
Wests lawyers filed a cease-and-

Why use bitcoin? It's fast, cheap to use, and secure

6 desist orderagainst the team of
coders who developed Coinye West,

How can I buy bitcoins? From an exchange or an individual

3*1 claiming trademark infringement.

4 According to the Wall Street Journal, the document was filed on 6th Januaryand
it is going after the coders because the design of the coin features a cartoon of
reddiwest.
Got a news tip or guest feature?

1 The documents explains:
News in Your Inbox Bitcoin news, delivered daily "Given Mr West's wide-ranging entrepreneurial accomplishments,
consumers are likely to mistakenly believe that Mr West is the source of
your services."
Subscribe

The currency was supposed to launch on Sunday, but instead of being intimidated by the cease-and-desist order, the coders have actually chosen to
bring the launch forward.

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**ao<Lw

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of Bitcoins and Mining Gear

The CoinyeWest team wrote on the redesigned homepage:

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Another Bitcoin Warning

"Due to legal pressure, we will be launching today, January 7, at 7:00PM,
Pacific Standard Time."

US Senator Tom Carper Sees 'Good Things' in Bitcoin

As ifthat wasn't enough, they redesigned the image which was cited in the complaint. The new design stillfeatures a cartoon of Kanye West, but it is a lot
less flattering.
Mmmm

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for Litecoin ASIC Miners

http://wvvw.coindesk.com/kanye-west-lawyers-coinye/

1/8/2014

Kanye West Unleashes Lawyers on 'Coinye' Altcoin

Page 2 of3

It depicts Kanye as a fish (South Park fans should getthejoke). Ironically, Kanye was parodied in South Park for not getting a simple joke conceived by one ofthe
show's protagonists.

Who'd Have Known, Lily Allen Could
Have Been a Bitcoin...

Taking legal action against a team ofcoders who clearly have a healthy sense of
humour probably won't help Kanye's reputation in certain circles.

The original 'Fishsticks' episode ofSouth Park aired in 2009 and even West said
itwas funny, although he admitted it hurt his feelings.

Matt Stone and Tray Parker chose to mock Kanye Westagain, just a fewweeks

ago. If they happen to be bitcoin fans, who knows, maybe they'll doit again.
Kanye's lawyers havea valid point- using celebrity photos and puns to promote
a product is a questionable practice to say the least.

However, apartfrom having a good sense ofhumour, the developers obviously know a thing or two about trademark law. Certain parodies oftrademarks are permissible, including artistic and editorial parodies thatare protected bythe First
Amendment in the US.

Therefore their decision to redesign the coin and mock Kanyeeven further

makes perfect sense. However, itis not a bulletproof legal argument, and courts have rejected so-calledparody defence arguments inmany instances.

Ester Edry, owner of David's Antiques, Jewelry, Collectables Old & New

i m CoinDesk

Share {47]

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Kanye West-Inspired DigitalCurrency 'Coinye West' Launching Next Week
Flamboyant artist Kanye West is about to get a digital
currency named after him.

Follow @coindesk

13 comments

• «o

• Jem the discussion...

Best -

Community

Share fit

Loyin »

Jack B-'~; hours ;>a:?

good.
6 -*• v • Reply • Share .

StrikeltPoor • ar t-ojr a^c

What's next beibercoin, cyruscoin, kardashiancoin, etc?

They didn't expect to receive cease and desist letter?

Crypo doesn't imply the rest of the worldmight not notice. As crypto becomes
mr.ro mainotraam nrtt r,rtl\i nraiarnmant ro/11 ilatrtro ara «r»in/i in ha u/ot^hinn hi I*

http://www.coindesk.com/kanye-west-lawyers-coinye/

1/8/2014

Kanye West Unleashes Lawyers on 'Coinye' Altcoin

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Kanye West is not happy about "Coinye,"a new digital currency created by
anonymous coders that bears his name and face.

West's lawyers filed a cease-and-desist letter against Coinye's creators on Monday, arguing that the cryptocurrency represents a trademark infringement, accordmg to
the Wall Street Journal.

"Given Mr. West's wide-ranging entrepreneurial accomplishments, consumers are

likely to mistakenly believe that Mr. West isthesource ofyour services," the
document reads.

Theunknown groupbehind Coinye responded to the mounting legal pressure by announcing that thecryptocurrency will golive on Tuesday at 7 p.m. PST, instead of the originally planned launch date of January 11. Thegroupchanged their website URL from "coinyewest.com" to "eoinyeco.in", registered in India,and also changed
the image on Coinye to one less flattering:

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"Weare being attacked with fishsticks and must launch sooner. Jan 7th," the Coinye websitenow reads, referring to a "South Park" episodethat made fun of West by repeatedly suggesting he was confused by the words "fishsticks."

Sorry, But Your Cat Is Actually A Total
Jerk. It's Just Science.

Coiayeis just the latest of many cryptocurrencies createdin the wake of the successof
Bitcoin. Some are serious, but others such as Dogecoin and BBQcoin are ironic, meme-inspired jokes —although the creators of Coinye claim to be serious about the
future of their digital currency.

"We want to release this to the public before the man can try to crush it," one of die coders said in a Skypetext interview with the WSJ on Monday night. They'll still come after us, but mat's OK."
25 Reasons Norway Is The Greatest

Perhaps the codersare taking inspiration from Kanye'sGrammy-nominated song,
"Can't Tell Me Nothing:"

Place On Earth

"Wait tallI get my money right... then you can't tell me nothing, right."
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Coinye Coin: Kanye West Lawyers Attempt to Block Bitcoin-like
Currency
By ALISTAJRCHARLTOH | January 7,2014 15:56 PMGMT
14

The creators of Ccinye have been wwjuested to stop by Kanyfc West l*wy«s.

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Aluminium and Leather Design

Lawyers representing Kanye West have filed a cease-and-desist order against the creators of Coinye West, a crypto-currency similarto bitcoin.
Due to be launched on 11 January, the currency was developed as interest in

Formula E Race Car Debuts at CES Preview

decentralised crypto-currencies bitcoin and the cheaper litecoin reached new
highs.

The legal document, dated 6 January, includes an image of the Coinye currency, which features a cartoon representation of the hip-hop artists and record producer; it is argued that this image infringes on West's trademark.
Addressing the creators of Coinye. letter reads: "Given Mr. West's wide-ranging entrepreneurial accomplishments, consumers are likely to mistakenly believe
that Mr. West is the source of

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RELATED

Kanye West-Inspired Bitcoin
Alternative Coinve West to Launch
Next Week

wnai is uogecow c i ne ivieme mat Became the Hot New Virtual

your services."

Currency

In response to the legal challenge, the currency's

'•V.',.
JA,

,'v :*r
-----

creators are looking to move its launch forward, possibly to as early as 7 January. Speaking to the Wall Street Journal over Skype instant messaging, one of the currency's coders said: "We want to release this it the public before
the man car try to crush it. They'll sttfl come after us, but that's OK."

Ford Boss Mulally Bows Out of Microsoft CEC
Race

The cease-and-desist document requests that the creators of Coinye stop

using the name, or a variation of it, hand over their website and deactivate the
associated Facebook and Twitter accounts for Coinye.

In an attempt to out-maneuver West's legal team, the creators of Coinye have altered the cartoon image, dropped the West' from its name and moved their website from a com domain to one registered in India.
The newly located site states: "Due to legal pressure, we willbe launching

today January 7. at 7:00pm, Pacific Standard Time." This is Sam, 8 January in
the UK.

L.S Senator. Bitccia Should Not be Killed in The Cradle

A Twitter account for Coinye tweeted: 'Who gon stop me huh? Coinye feelin' the heat, gonna spread what we got so far before the bigwigs steal our work."
We wonder if Kolndashian will be next.

For much of 2013. bitcoin and fltecoin were the only crypto-currencies

JLMU

publicised by the media, but they were joined in December by Dogecoin, which features a dog on a gold coin as its symbol and is based on the Doge internet
rrteme.

mm
SHOP NOW

7ortnnc^ M fast &free shipping 4.
In early January, veteran bitcoin developer Matt Corallo created Coingen.io, a site letting any visitor create their own version of bitcoin and calling it whatever they want. The cost ofcreatlng a new virtual currency Is 0.01 bitcoins, or
around $10.

^PRKif * BOTH WAYS*
ADVERTISE WITH US

Once created, coins for the new currency can be mined by computers solving mathematical equations, just as bitcoin is mined - however, the value of these coins is likelyto remain incredibly low compared to five-year-old bitcoin, which currently trades for around 51,000 per coin.

To report problems or to leave feedback about this article, e-mail: a. charlton@ibtimes.eo. uk To contact the editor, e-mail: edstorQibtimes.co.uk

China's Largest Online Marketplace Bans Sale of Bitcoin and Mining Equipment

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Kanye West declares legal war on 'Coinye' digital currency | New Yo...

http://nypost.com/2014/01/08/kanye-west-declares-legal-war-on-coi.,

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Kanye West declares legal war on 'Coinye' digital currency
ByNtws.com.au
January8, 2014 | 9:0

SIX-IER THAN EVER.

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TRENDING NOW

Kanye West declares legal waron 'Coinye' digital currency

YahooftMayer, T-Mobile chiefthe
KanyeWest's lawyershave issued a cease and desist order to the digital ourrenoy"Coinye."
Photo: CoJnyeco.in/Getty Images

talk of tech

It's a tough gig being Kanye West.
MORE ON:

KANYEWEST

First people try to steal your limelight on stage, then they spoof your music videos and now the rapper is fighting a legal battle against a new digital currency
made in his image.

Hungry? GetDomino'sfrom new in-car orderingsystem

2014: Who'sin andwho'sart!?

"Coinye" is the brainchild of an anonymous group of seven web developers who claim they are just a few guys "excited about the future of cryptocurrency."
The digital currency is designed to rival bitcoin and uses

SandraBemhard's takes onthe

year in pop culture
10worstfashion fails of2013

Kanye's name and image as a parody in a bid to help it
become more mainstream.

Page Six
SIX-IER THAN EVER.

However Kanye hasn't taken kindly to his monetary likeness, with lawyers for Mr. West firing a cease and desist letter against the developers.

"Mr West is an internationally renown musical artist, songwriter, producer, film director and fashion designer, to name just a few of Mr West's endeavours," says a letter dated January 6 that reads as if it could have been written by Kanye himself.

The lawyers claim the name of the currency is "substantially similar" to Kanye's name
READ NEXT: Hungry? Get Domino's from new..

lof4

1/8/2014 8:27 PM

Kanye West declares legal war on'Coinye' digital currency | New Yo...

http://nypost.com/2014/01/08/kanye-west-declares-legal-war-on-coi.

and have demanded the group deactivate all websites and social media accounts associated with the currency. The developers have changed the name from Coinye West to Coinye and moved their website to India, according to the Wall Street (ournal.

However they've also decidedwhat doesn't kill them makes them stronger and brought forward the launch date due to "legal pressure," according to a note on their website.
This article originally appeared on Ncws.com.au.
FILED UNDER CELEBRITY LAWSUITS. COINYE. DIGITAL LIFE. KANYE WEST

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Kanye West threatens legal action against Coinye programmers over digital currency
Users who receive the new Coinye coins can take them directly to the new Coinye Casino to play some classic European roulette or save them hoping they catch on and grow in value.
Comments©
BY NANCY DILLON / NEW YORK DAILY NEWS
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Fans who receive Coinye coins can take them directly to the new Coinye Casino to play some
classic European roulette. They think Coinyes are forever.

1 2

Michelle Rodriguez makes a spectacle of herself at Knicks game Leonardo DiCaprio reveals terrifying
shark attack

The founders of a new Kanye West-themed digital currency are defying a legal threat from the famous entertainer and promising to give out thousands of newly minted digital Coinye coins to
online users Wednesday.

3 4
5

KrisJenner posts sexy poolside bikini
photo

Spitzer &Smith hot tub tipwas all wet
Mindy Kaling's Elle cover sparks
controversy

Users who receive the new Coinye coins can take them directly to the new Coinye Casino to play some classic European roulette or hoard them hoping they catch on and grow In value.

6
7

Sofiavergara on bikini body: 'Damn, Istill
look gooo*

The coders reportedly plan to release the coins in blocks of 666,666 - a nod to West's rumored
affiliation with the itluminatf - up to a pre-set maximum.

Courteney Cox reveals DavidArquetteis
having a baby boy

8

Shia LaBeoufreceives cease and desist
letter alter plagiarism accusation

"We haven't heard from any lawyers yet, but we'd love to give (Wests attorney) some house credit for a few free roulette spins," one of the programmers behind Coinye Casino told the Daily News in

9

"Bachelorette' EmilyMaynard engaged

an email Wednesday.

lO Shakira on weight pressure: 'My man prefers meat over bone'

The programmer, who used the name Jonny Bravo, said theCoinyeCasino.com team isprepping
even moregames for Coinye users after the site opened for"real play" earlyWednesday.

It wasMonday thatWest's Manhattan-based lawyer sent a cease-and-desist letter to the anonymous coders behind Coinye claiming copyright infringement.

Thelogo for the humorous new cryptocurrency features a cartoon version ofWest with his
trademark slatted shades.

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The logo for the newcryptocurrency features a cartoon version ofKanye West with his trademark
slatted shades.

rumors linking him

"Given Mr. West's wide-ranging entrepreneurial accomplishments, consumers are likely to

Gwyneth Paltrow helps out at her kids'
lemonade stand

mistakenly believe that Mr. West isthe sourceor yourservices,'' lawyer Brad Rosewith Pryor
Cashman said in the letter obtained by the Wall Street Journal.

"We are justa few guys whowantto take cryptocurrency to the mainstream," the anonymous
founders wrote online as they moved their launch date to Tuesday nightfrom later in the month.

Gwyneth Paltrow may be a health nut, but even she can appreciate lemonade
and cookies.

Chris Brown rejects

"We would like to make itclear that we are entirely independent of (West), and there should be no

plea deal in assault
case

confusion as to the intentor originof this project,"they said. "The name 'Coinye' is intended solely as parody, not an indication or implication of endorsement or involvement."

Chris Brown rejected a

plea deal Wednesday related to his alleged
sidewalk smackdown in

Cryptocurrency is invisible money releasedfrom a network that's preprogrammed with a certain
number of coins distributed over time to users who unlock them, often times by solving complex
math problems.

The coins are an invention of the network founders, and they derive any potential street value from their popularity and scarcity.

Kanye West threatens legal action over Coinye digital currency
The founders of a new

Kanye West-themed digital currency are defying a legal
Candace Cameron Bure defends her 'submissive role* in

Bitcoins have been around for years and become so popularthey've attained street value in this
manner.

Some supporterssay the point of cryptocurrency isto create an international system free from government regulation thatacts as a cheap, egalitarian version of mainstream banking services
such as Western Union.

marriage
Candace Cameron Bure

has spoken out about
where she stands in her

*$mL It

Attempts to reach West's lawyer and the Coinyecoders were not immediately successful
Wednesday.
Shia LaBeouf receives cease and desist letter after

ndillon@nydailynews.com
POST A COMMENT »

plagiarism
accusation
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sky-written apology to

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Kanye West's lawyer orders "Coinye" to cease and desistjust before launch | Ars Technica Page 1 of 4

http://arstechnica.com/business/2014/01/kanye-wests-lawyer-orders-coinye-to-cease-and-de... 1/7/2014

Kanye West's lawyer orders "Coinye" to cease and desist just before launch | Ars Technica Page 2 of4

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page cease^irid-desist letter"{PDF); by e-mail to the creatpf|or cjwtbfs of Coiiyf-7«8rylrig ft simpV.to

More researchers join KSAconference boycott to protest $10million NSA •

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The letter cites""willful trademark infringement, unfair

competition, cyberplracy, anddilution,' as wellas violations of"Mr. West'slight of publicity under statelaw." Heordered Coinye to cease anddesist,threatening the creators with
litigation. One problem? The creatorsremainanonymous, and they have hiddenthemselves behindVPNs, privacy
services, and other anonymblng tools.

TO THE LETTER

Nebraska AG seeks to shut down

vague patent demand letters
New Oculus prototype
COMYE WEST: ANEW CRYPTOCURRENCY FOR THE MASSES AND ANODE TOKANYE
Stunt cryptocurrency at its finest.

features positional tracking,
reduced motion blur

"Fight for the people"
Ars contacted the creator of Coinye via IRC

(lrc.freenode.net/ #coinyecoin), though the developer declined to providea real name or locationand goes only by
the online moniker "Coinyewest"

NSA employee will continue to co-chair influential crypto standards group

New gravity lab: Two white
- FURTHER READING -

Coinyewest explained that he did take into account some of the changes requested in the letter, such as alteringthe logo image, removing a Kanye West video fromthe site, and dropping the "West" partof the name. Other than that, the cryptocurrency appears to be plowingahead as planned.

dwarfs and a neutron star

PLAYSTATION NOW LAUNCHING-. LATER

Sony's game-streaming "PlayStation
Now" service coming this summer

http://arstechnica.coni/business/2014/01/kanye-wests-lawyer-orders-coinye-to-cease-and-de... 1/7/2014

Kanye West's lawyer orders "Coinye" to cease and desist just before launch | Ars Technica Page 3of4

CoinPlle

trlgeekr there wffl beptentyVtf^^^

how'much'the/re reallyworth V ". .-*.'•* "'•';* £$t*?li.-% ••' V "'...ti?..-!>. '.•(* L'^»' - - "•''••a' '•'••••••-"

__.

So why another Bltcoin-like clone? Coinyewest waxed philosophical.

'Anarcho-capitalism iscoming,', it can't bestopped. Whether ithas a symbol that looks like adollar, a
dog,ora cartoon picture of a rapper, it'sall the samething," he said. "Away for people to createtheir owneconomiesand stop relyingon this one we watchfailing worseand worseevery year.Peoplewant something different, that1s why all this suddenInterest In cryptocurrency I'vetalked with the creators of Dogecoin about the same things Itseems silly butwe areJust trying to market these Ideas to a broader
audience."

IfCoinye doesn'twork,there's always Norn's Coin, which is set to launch on January 14,2014. Representatives of ChuckNorris didnotimmediately respond to Ars'requestforcomment.
-EFROMOTED COMMENTS Cateye I Moderator I el Subscriptor
Jump to post

WhenIsitdownto inventory the thingsIfind troublesome aboutgovernment-controlled currencies and
economies, you know what's at the top of my list?They're alljust not ironicenough. Because when searchingfor somewhere new to base myfinancial trust, finding a cryptocurrencythat incorporates somethinglikea fleetingpop-culturereference intoits name or iconography is certainly paramount. If"anarcho-capitalism" really is coming, then apparently it's goingto be insufferablystupid before itgets
interesting.
5383 posts {registered Jul 26,2003

http://arstechnica.com/business/2014/01/kanye-wests-lawyer-orders-coinye-to-cease-and-de... 1/7/2014

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