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Matthew Chan

P.O. Box 6391

Columbus, GA 31917
January 10, 2017
Ms. Vanessa Bouchara
Cabinet Bouchara Avocats
17 rue du Colise - 75008 PARIS
Email Address:,
I am in receipt of your two letters where you attempt to convince me that I should remove
specific blog posts from my websites where I have reported demonstrably accurate facts and
expressed informed opinions about your purported client, Getty Images.
It is unclear to me whether you represent Getty Images in the U.S. or Getty Images in France.
Which specific entity do you represent here? I request to see proof of who you claim to represent
as this is unprecedented for me to receive any letters from France regarding any matter.
Regardless of which corporate entity you represent in France, I inform you of the following:
1. I am a U.S. Citizen who lives and work in the U.S.
2. I do not have any business interests in or solicit any business from France.
3. My websites are hosted in the U.S., written in English, and primarily targets American
As such, any content you or your client may object to on my website all firmly within the realm
of U.S. laws and the First Amendment. I do not see how you can threaten me with a lawsuit
being brought in a country in which I have no contact, connections, or involvement.
Am I to blindly accept and believe that French law somehow has jurisdiction over me, my posts,
or my websites based on your form letter? What about the U.S. First Amendment? Are you
asserting that French law somehow has superior jurisdiction here?
French law might have jurisdiction over you, your law firm, and your client operating in France.
But I cannot see any way whatsoever how French law applies to me or my websites.
Until you provide me some important answers to my questions regarding your purported client's
status and standing as well as a convincing explanation why French law has any bearing or
relevance to me or websites, I have no intention whatsoever in removing any posts that I or
anyone else have written and posted on my websites.

Matthew Chan (on behalf of &

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