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Suite 410 Portland, OR 97214 T 503-345-6912 F 503-345-6912 email@example.com Oregon Bar Member Washington Bar Member
May 15, 2012
F.R.E. 408 SETTLEMENT COMMUNICATION Re: Copyright Infringement of Corbis images 42-23005175, 42-19154199, 42-22582989, and 42-22277428. Dear Mr. Thank you for your email dated March 6. While my client appreciates that has removed the images from your website, that removal does not absolve from responsibility for past infringement. Copyright infringement is a strict-liability offense, and the law is clear that website owners bear responsibility for the content on their sites. In an infringement law suit, my client would be entitled to seek both statutory damages and attorney’s fees. Corbis, however, prefers to settle this dispute out-of-court, if possible. Accordingly, it hereby oﬀers to release from liability for all claims raised in my February 29, 2012 letter in exchange for payment of $18,000. This offer will remain open until the close of business on May 30, 2012. You should consult your attorney for help reviewing this offer. Alternately, as I said in my initial letter, you should consult your insurance carrier to determine whether your general liability insurance policy covers this event as an “advertising injury.” I remain hopeful that we may resolve this matter outside of court. Corbis continues to reserve all rights, claims, legal arguments, and remedies with respect to this matter, none of which have been or will be waived.
John E. Grant, III