[Name]

[Address]

And by FedEx Priority Overnight

And by email to [Email address]

And by U.S. Registered Mail Return Receipt Requested

Re: Client

Dear [_________]:

This office represents [Client_________]. It has come to our attention that you are engaged in the construction and operation of stores that bear a trade dress that is confusingly similar to our client's stores. Specifically, you have replicated certain elements of our client's trade dress, including but not limited to [_________].

This letter serves as formal notice that your use of the aforementioned trade dress constitutes an infringement of our client's rights under Section 43(a) of the Lanham Act, 15 U.S.C. §125(a). This is in accordance with the ruling in Two Pesos, Inc. v. Taco Cabana, Inc., 60 U.S.L.W. 4762 (1992 WL 141119 (U.S.)). Additionally, our client asserts copyright protection over its store design, which you have also infringed upon. We have reason to believe that your infringement is intentional and deliberate, with the intent to replicate our client's business by copying its trade dress and store design.

Therefore, our client demands that you immediately take the following actions:

1. Cease and desist from constructing and operating stores that bear a trade dress similar to [Client_________] stores;
2. Cease and desist from any and all other violations of the Lanham Act and the copyright laws; and
3. Remove and destroy all elements of our client's trade dress and store design from your stores.

Failure to comply with this demand may result in our client seeking relief in court, including but not limited to an injunction and damages. Judicial relief may include, but is not limited to, the destruction of the infringing articles under 15 U.S.C. §118, treble damages, your profits, any damages sustained by our client, court costs, and attorney's fees under 15 U.S.C. §117, and an injunction under 15 U.S.C. §116. In addition, our client reserves all rights it may have and does not waive or abandon any rights by sending this demand letter prior to filing a lawsuit.