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FIFELSKI LEGAL, PLC
ATTORNEY & COUNSELOR
James E. R. Fifelski, Esq.
james@annarborslawyer.com
______________________________________________________________________________
October 10, 2014
Sent by email
sales@a2hosting.com
!
Re:
Notice of IPR Violation: Marketing of Counterfeit Goods
www.testosterone-booster.co
!
Dear Sir/Madame:
We represent CrazyMass, LLC, the sole owner of all trademarks, copyrights, and other
intellectual property associated with the CrazyMass website, brand name, and product line,
which can be found at: www.crazymass.com.
It recently came to our attention that a website that your company hosts,
www.testosterone-booster.co, has contested a DMCA notice that our client sent concerning their
active marketing and promotion of a counterfeit company by the name of “CrazyBulk”.
CrazyBulk actively markets and sells a counterfeit version of the CrazyMass website, brand
name, and product line from their website found at: www.crazybulk.com. (See A Comparison of
CrazyMass and “CrazyBulk” counterfeit, attached as Exhibit A). Your client,
www.testosterone-booster.co, used to market the CrazyMass website and product line. Our client
submitted their DMCA notice when they discovered that the site was promoting the CrazyBulk
counterfeit instead. (See Evidence of Promotion of Counterfeit, attached as Exhibit B).
As you can see from the attached exhibits, CrazyBulk’s website, logo, product names,
and company image are substantially indistinguishable from, and constitute a direct theft and
counterfeit of, our client’s intellectual property. These similarities are designed to confuse
consumers and divert traffic from our client’s website to the counterfeit site. While our client’s
claim was initially under the DMCA, this counterfeit is also in direct violation of the Lanham
Act, 15 U.S.C. §1051 et seq, as well as the Trademark Counterfeiting Act, 18 U.S.C. § 2320.
_______________________________________________________________________________________________________
455 E. Eisenhower Pkwy, Ste 360, Ann Arbor, MI 48108 / Ph: 734-726-0225 / Fax: 734-418-1468 / james@annarborslawyer.com
!
FIFELSKI LEGAL, PLC
ATTORNEY & COUNSELOR
James E. R. Fifelski, Esq.
james@annarborslawyer.com
______________________________________________________________________________
It is true that since September – the date CrazyBulk first launched – this counterfeiter has
modified the appearance of their website and product labels in an attempt to conceal their crime
and evade justice. However, the updated labels and website continue to infringe on our client’s
intellectual property because the similarity of the brand name and the logo’s appearance causes
brand confusion among consumers. In addition, while the marketing materials have been
modified, the product that is actually shipped is clearly a counterfeit. (See Shipped Counterfeits,
attached as Exhibit C).
This letter is official notification that your servers are being used in order to violate our
client’s intellectual property rights. We trust that, as a service provider, you have a direct interest
in rectifying any ongoing infringement of intellectual property rights that involves your servers.
Therefore, we request that you immediately notify the infringer of this notice and their violation
of our client’s intellectual property rights. We further request that you investigate and remove or
disable the infringing material from your servers with all due speed should the infringer, your
client, not comply immediately. Should you wish to discuss this matter, you may contact our
office directly.
Sincerely,
Juan C. Perez, Esq.
Encl.
_______________________________________________________________________________________________________
455 E. Eisenhower Pkwy, Ste 360, Ann Arbor, MI 48108 / Ph: 734-726-0225 / Fax: 734-418-1468 / james@annarborslawyer.com
!
ATTACHMENT
A
10/10/2014
Testosterone Booster | Crazy Mass Review - Risk Free Method for body building
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Crazy Mass Review
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Home » Testosterone Booster – Crazy Mass Review – You Really Need To Read This!
Testosterone Booster – Crazy Mass Review –
You Really Need To Read This!
0
Introduction
Testosterone is a hormone that is
primarily produced by male testicles
and also found to be present in females
too. After the age of 30 years, the
human, especially male testosterone
production reduces and continues to
decline as the age progresses. A
decline in testosterone levels not only
impacts sexual and reproductive
functions, but also affect in muscle
mass and hair loss. There are many
testosterone boosters online and they come under the category of legal steroids. The
following products are part of the Crazy Mass and this is their brief review.
Click Here For The BEST DEAL On Crazy Mass
Supplements
Trenbalone or Tren-Bal Elite Series
Trenbalone or Trenbolone is a bulking agent designed to give immediate results and is
the known strongest legal steroid available. Its ultra-enhanced formula helps gain strength
and power while hardening and cutting the body into shape.
The working of Trenbalone or Tren-Bal:
Trenbalone or Tren-Bal releases large amount of free testosterones that increases
nitrogen retention in the body gaining serious muscle mass. It is observed that it has
lipolytic fat burning properties that make possible the leanest type of muscle gain. In a
matter of 30 days, Trenbalone will allow you to gain 10-15lbs of lean muscles.
Features:
· Improves retention of nitrogen in muscle tissue
· Releases free testosterone in high levels
https://web.archive.org/web/20131109134601/http://testosterone-booster.co/
1/14
10/10/2014
Testosterone Booster | Crazy Mass Review - Risk Free Method for body building
· Helps burn visceral and subcutaneous fat
· Produces dry dense quality muscle
· Gives quick anabolic results
· Quicker muscle gain
· The strongest known Anabolic that is available on the market.
Benefits:
· Oral intake avoids injections and needles.
· Prescription-less legal steroid
· Safe alternative to pure steroids
· Shows result in less than two weeks.
Testosterone MAX – Test-Tone Elite Series
Favorite amongst bodybuilder’s world-wide as the godfather of weight lifting supplements
Testosterone MAX – Test-Tone increases lean muscle mass and gives you energy and
strength that you have never experienced before.
The working of Testosterone MAX:
Formulated from the extract of Tribulus Terrestris, it is an all-natural testosterone booster,
which is designed to safely and effectively increase the production of the male
Testosterone in the body without any negative or side effects. It’s Anabolic and
Androgenic properties increases protein synthesis for gaining strength gains and reduces
body fat. It also enhances basic male characteristics especially fertility.
Features:
· Boosts protein synthesis and muscle gain.
· Helps nitrogen retention and increases blood flow
· Substantially increases Strength, Stamina and Recovery decreasing stress levels.
· Enhances lean muscles and rapidly reduces body fat.
Benefits:
https://web.archive.org/web/20131109134601/http://testosterone-booster.co/
2/14
10/10/2014
Testosterone Booster | Crazy Mass Review - Risk Free Method for body building
search
Privacy Policy
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View Results from Users
Beware of Counterfeit Steroids
Home » Testosterone Booster – Crazy Bulk Review – You Really Need To Read This!
Testosterone Booster – Crazy Bulk Review –
You Really Need To Read This!
0
Introduction
Testosterone is a hormone that is primarily
produced by male testicles and also found to be
present in females too. After the age of 30 years,
the human, especially male testosterone production
reduces and continues to decline as the age
progresses. A decline in testosterone levels not only
impacts sexual and reproductive functions, but also
affect in muscle mass and hair loss. There are
many testosterone boosters online and they come
under the category of legal steroids. The following
products are part of the Crazy Mass and this is
their brief review.
Click Here For The BEST DEAL
On Crazy Bulk Supplements
Trenbalone or T-BAL 75 ELITE
Trenbalone or Trenbolone is a bulking agent designed to give immediate results and is
the known strongest legal steroid available. Its ultra-enhanced formula helps gain strength
and power while hardening and cutting the body into shape.
The working of Trenbalone or Tren-Bal:
Trenbalone or T-Bal 75 Elite releases large amount of free testosterones that increases
nitrogen retention in the body gaining serious muscle mass. It is observed that it has
lipolytic fat burning properties that make possible the leanest type of muscle gain. In a
matter of 30 days, Trenbalone will allow you to gain 10-15lbs of lean muscles.
Features:
https://web.archive.org/web/20140915023701/http://www.testosterone-booster.co/
1/15
10/10/2014
Testosterone Booster | Crazy Mass Review - Risk Free Method for body building
· Improves retention of nitrogen in muscle tissue
· Releases free testosterone in high levels
· Helps burn visceral and subcutaneous fat
· Produces dry dense quality muscle
· Gives quick anabolic results
· Quicker muscle gain
· The strongest known Anabolic that is available on the market.
Benefits:
· Oral intake avoids injections and needles.
· Prescription-less legal steroid
· Safe alternative to pure steroids
· Shows result in less than two weeks.
Testosterone MAX – Test-Tone Elite Series
Favorite amongst bodybuilder’s world-wide as the godfather of weight lifting supplements
Testosterone MAX – Test-Tone increases lean muscle mass and gives you energy and
strength that you have never experienced before.
The working of Testosterone MAX:
Formulated from the extract of Tribulus Terrestris, it is an all-natural testosterone booster,
which is designed to safely and effectively increase the production of the male
Testosterone in the body without any negative or side effects. It’s Anabolic and
Androgenic properties increases protein synthesis for gaining strength gains and reduces
body fat. It also enhances basic male characteristics especially fertility.
Features:
· Boosts protein synthesis and muscle gain.
· Helps nitrogen retention and increases blood flow
https://web.archive.org/web/20140915023701/http://www.testosterone-booster.co/
2/15
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