WILLIAMS MULLEN
Dizee Dal 4349515718
‘righ wilismenslen.com
September 30, 2008
VIA ELECTRONIC MAIL, AND
CERTIFIED MAIL, RETURN RECEIPT REQUESTED
WikiLeaks
oo Julie S. Tumer, Esq.
The Turner Law Firm
344 Tennessee Lane
Palo Alto, CA 94306
Re: Copyright Infringement
‘To Whom It May Concem:
‘We represent Sigma Phi Epsilon Fraternity, a Virginia non-stock corporation, (“Sig Ep”),
and are writing to you on its behalf regarding your unauthorized use of a copyrighted work
‘owned by Sig Ep. Please address all correspondence on this matter to us.
Posted on your website is a link to the secret ritual book of Sig Ep (the “material”), We
have enclosed a screenshot of your website showing the posting where the text of the material
can be found. This copyrighted material was created by members of Sig Ep and is its sole
Property.
Sig Ep has invested substantial time, money and effort in creating this material. Your
unauthorized posting of this material constitutes copyright infringement. We, on behalf of our
client, in good faith assert that the use of the material on your website is not authorized by Sig
Ep, the copyright owner, its agents, or the law.
‘Without waiving any rights that Sig Ep may have against you or those acting in concert
with you, we hereby demand that you immediately cease all uses of Sig Ep’s copyrighted
material, and that you specifically (1) cease and desist any further postings or uses of this
material and any other similar material on your website; (2) remove the material, any links to the
‘material, and any similar material from your website.
Please be advised that Sig Ep intends to use any and all remedies available to it in Jaw
and equity, including but not limited to litigation against you in order to preserve the integrity of
its copyright. Sig Ep’s remedies against you for your infringement may include recovery of
A Professional Corporation
NORTH CAROLINA + VIRGINIA + WASHINGTON, D.C. + LONDON
321 East Main Sc, Suite 400. Charles, VA 22902-3200. Tel: 434.951.5700 Fax: 804.783.6507 or 434.817.0977
‘wow villiamemullen.comWILLIAMS MULLEN
September 30, 2008
Page 2
damages, an injunction prohibiting your further use of the copyrighted material, and recovery of
costs and attomeys” fees incurred in bringing an action against you,
We request a response within 5 business days after your receipt of this letter. If we do
not hear from you, we may proceed as Sig Ep deems necessary, without further notice to you.
We look forward to your prompt response. The assertions and statements in this
notification are accurate, and under penalty of perjury, this firm is authorized to act on behalf of
the owner of the exclusive rights holder of the copyrighted material.
Sincerely,
WILLIAMS MULLEN
Bryan D. Wright
ce: Sigma Phi Epsilon Fraternity
Douglas Nabhan, Esquire with enclosure