Attorney at Law

3219 E. Camelback Rd. #181

Phoenix, AZ 85018
Phone: (602) 279-6933
Davis P. Bauer, Esq.
Licensed in Arizona, Colorado, Missouri, Texas, and Utah
davispbauer@gmail.com

IMMEDIATE ACTION DEMANDED

December 12, 2022
VIA CERTIFIED MAIL
Taco Bell
1 Glen Bell Way
Irvine, California 92618

RE: Cease and desist/pre-suit notice

To Whom It May Concern:
This is a cease-and-desist letter and pre-suit notice, and the only warning that you may
receive before a lawsuit is filed against you. If you have an attorney, please provide this letter
immediately to them.
My clients are the creators of the Burrito Blanket, and owners of the trademark Burrito
Blanket. My clients have used it in commerce as early as 2016. Their trademark is also registered
in the Principal Register with the United States Patent and Trademark Office, registration number
6882338, issued on October 25, 2022.
They currently use their trademark for offering Burrito Blanket items on their website at
www.burritoblanket.com.
You are not authorized to be utilizing my client’s trademark, Burrito Blanket, on
your products, packaging, photos, advertising, social media accounts or website.1

1
As seen on your website, with the link to the trademarked material here:
https://www.tacobelltacoshop.com/products/taco-bell-ultra-plush-burrito-blanket
1
Trademark Infringement by Taco Bell
December 12, 2022
Page 2 of 2

In doing so, this causes confusion for consumers and dilutes the goodwill and
distinctiveness of my client’s trademark. Therefore, the unauthorized use of my client’s trademark
constitutes trademark infringement.
We hereby demand that you immediately cease and desist from using my client’s trademark
and remove Burrito Blanket from your products, packaging, photos, advertising, social media
accounts and website. Failure to do so will result in further legal action against you and we will
seek all available damages and remedies.
Demand
Due to the aforementioned harm you have already caused, this letter shall serve as a pre-
suit notice demanding that you provide me written assurance within 7 days that you will refrain
from further actions that could be deemed as trademark infringement against my client. Please
forward this communication to my email address and/or mailing address.
Please have your attorney reach out to discuss this matter with me to avoid costly litigation
– litigation that would be extremely costly for you as well in merely retaining all relevant
electronically-stored information in your possession from the website you currently maintain that
infringing upon my client’s trademarked burrito blanket.
Please be advised that you may have an obligation under the laws of your state to preserve
any evidence that could be relevant to the case or documents reasonably calculated to lead to the
discovery of admissible evidence, including those stored in electronic form. As a result of that
obligation, you need to halt the destruction of all relevant documents, or documents reasonably
calculated to lead to the discovery of admissible evidence, whether electronic or not. Please do not
contact my client or his employer unless you plan to immediately cease and desist from utilizing
their trademark and intellectual property.
We expect a prompt response to this communication within seven (7) days. If no
response or communication is received, then my client may pursue legal remedies for the damage
you have caused to him. Please contact me at the email address or phone number listed above with
any questions.

Very truly yours,

Davis P. Bauer, Esq.