1752 NW Market St, #211
Seattle, WA 98107
T 206 903 8182
F 206 903 8183
Padriac Sheridan September 13, 2010
Murphy & Gonzalez
5020 39th Place, Apt. #3
Sunnyside, NY 11104
via mail and email to firstname.lastname@example.org, email@example.com
Re: Copyright Infringement of Alaska Stock Image #351PL_AA0001D001_P
ACTION REQUIRED: Respond by September 23, 2010
Dear Padriac Sheridan:
I represent Alaska Stock LLC, the owner and operator of AlaskaStock.com, a leading
provider of rights managed stock photography images.
It has come to our attention that you are using Alaska Stock Image
#351PL_AA0001D001_P on your website, murphy-gonzalez.com, without authorization. Proof
of this unauthorized use is enclosed. This is copyright infringement in violation of 17 U.S.C. §
U.S. copyright law makes clear that any reproduction, distribution, or display of a
copyrighted work without authorization from the copyright holder constitutes infringement.
Copyright infringement is a strict liability offense: you are responsible for any infringing act on
your website regardless of your intent. Removal of the infringing work does not relieve you from
liability for damages arising from your past infringement.
Additionally, your website claims “© 2008 Murphy & Gonzalez.” As you are not, in fact,
the lawful copyright holder of #351PL_AA0001D001_P, your action constitutes the falsification
of copyright management information under 17 U.S.C. § 1202(a).
A copyright holder is entitled to seek statutory damages up to $30,000 per infringement
as well as statutory damages of not less than $2,500 or more than $25,000 per falsification of
copyright management information, in addition to attorney’s fees and costs. Swift and amicable
settlement, however, is preferable to protracted litigation. Therefore my client is asking that you
pay $11,750 to settle this matter.
Accordingly, we demand that you:
(1) Immediately cease and desist from all unlicensed use of the above image number.
(2) Remit the full $11,750 to my office by September 23, 2010.
(3) Identify and provide contact information for any person or party responsible for
the content on your website, including your web developer.
(4) Identify and provide contact information for your website hosting company.
(5) Provide the name and policy number of your insurance carrier.
(6) Preserve all evidence, physical and digital, relating to the claims of this letter.
Should you choose not to cooperate with these demands, we reserve the right to seek all
If you carry insurance, now would be a good time to contact your carrier to determine
whether copyright infringement is covered under your policy (many policies cover it as an
Imua Legal Advisors
Eric S. Meltzer, Esq.
(1) Copy of Source Image
(2) Evidence of Infringement
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351PL AA0001D001 P
Alaska Governor Sarah Palin official portrait November 2006
Model/Property Release info:
Not released. If a person is in this photo it may only be used for
EDITORIAL uses. Please contact Alaska Stock.
Image Availability: Approx. 2 hours during business hours.
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have: keywords keywords
090308 female portrait
090908 front posing
101508 governor republican
30's indoor sarah palin
adult nominee smiling
akstock official studio
alaska one united states
caucasian palin vice president
face person woman
To download image for comp use:
1. Right click on the image. (Control-Click on Macintosh)
2. Select the Save Picture As... option from the pull-down menu that appears.
3. Choose the destination file where you want to save the image.
4. Click Save and the image will begin to download to the chosen location.
Note: If prompted to save as format Source or Text, select Source