VIA CERTIFIED MAIL/RETURN RECEIPT REQUESTED
E-MAIL:abusegaffinity.com & FACSIMLIE

Copyright Agent
Affinity Internet Inc.
3250 W. Commercial Blvd.
Ft. Lauderdale, FL 33309

Re:Conflict with National Alliance (American Defense League) (Our Ref. AFL USA TC-01/05611)

Dear Sir or Madam:

We are intellectual property counsel for the Anti-Defamation League of B'nai B'rith, owner of the trademark ADL. Our client has been using this trademark for nearly nine decades in connection with its educational services in the field of civil rights and combating prejudice and racism. Our client is also the owner of a federaltrademark registration for "ADL anti-Defamation League" which is valid, subsisting and in full force and effect. Moreover, our client's Registration No. 1,776,315 for the mark is incontestable and serves as prima facie evidence of our client's exclusive right to use ADL in connection with the services set forth in that registration.

Through decades of our client's extensive nationwide use and promotion of its mark - including an Internet site at www.adl.org - the public has come to identify ADL exclusively with our client and exclusively with its education services in the field of combating bigotry.

It had come to our client's attention that our client's ADL mark is being used on and in connection with the website located at www.americandefenseleague.com. We have communicated with several web hosts as well as the proprietor of the web page www.americandefenseleague.com. As we understand it, this web site is dedicated to "documenting how the Jewish community is destroying our investment in America." While we are offering no comment on the substantive content of the site, our client is concerned about the infiinging use of its ADL mark. We were successful in having the site removed by XO Communications, Inc., but unfortunately, now we see that Mr. Pribich has found another outlet to infringe our client's mark. If you visit the web site you will notice that the web site refers to the American Defense League organization as "ADL". This unauthorized use of the Anti-Defamation League's mark constitutes trademark infringement, unfair competition as well as dilution under the Lanham Act and applicable state law.

Furthermore, both the federal and state anti-dilution laws prohibit the commercial use of a mark if such use will tend to diminish the distinctive value of another's trademark. It is self-evident that the unauthorized use of the ADL mark in connection with a web site disparaging our client impairs the ability of our client's well-known registered mark and logo to exclusively denote our client and its services.

All of the above referenced actions violate numerous provisions ofthe U.S. Trademark (Lanham) Act of 1946, including Sections 32(l), 43(a) and 43(c), 15 U.S.C.  11 14(l), 1125(a), I 125(c), as well as applicable state law, thereby entitling our client to seek all applicable remedies, including, but not limited to a lawsuit seeking injunctive relief, monetary damages, costs and attomey's fees. In addition, we note that this page is posted in violation of your own subscriber policies. Our client is prepared to take whatever action is necessary to protect its valuable trademark rights.

In view of the above, we therefore demand on behalf of our client your written confirmation within ten (10) days that you will immediately cease providing services to the owner of the web page until all reference to our cliert's ADL mark is removed. lf we have not heard from you by such date, we will be forced to consider taking further action against you and/or the infringing site to ensure that our client's most valuable trademark rights remain protected. This letter is sent without prejudice to all rights and remedies of our client, which are expressly reserved. It is, of course, our sincere hope that we can resolve this matter quickly and amicably.

Thank you in advance for your cooperation in this matter.

Sincerely,

[signature]
Michelle P. Foxman

MPF/GD

cc:Susan Upton Douglass, Esq.