From: Jill Kahn Meltzer To: zpub@sirius.com Subject: trademark Date: Friday, April 24, 1998 9:37 AM Dear Mr. Peterson: The phrase "Anti-Defamation" was coined by the Anti-Defamation League in 1913, and has become inseparably associated with that organization, according to several court decisions. As my letter indicated, one such decision was from the U.S. Court of Appeals for the D.C. Circuit in Anti-Defamation League of B'nai B'rith v. National Mexican American Anti-Defamation League. We don't claim "ownership" of the word "defamation" but rather the rights to the phrase "Anti-Defamation"as part of an organizational name. Under federal law, proof of actual confusion is not necessary in order to successfully bring a claim of trademark infringement. It is sufficient to show there is a liklihood of confusion. Because of the national reputation of our agency, its international work and programs, there is considerable name recognition associated with Anti-Defamation League. That is in fact why some groups improperly use the phrase -- in an attempt to gain from the good will and name recognition associated with the Anti-Defamation League. The Anti-Defamation League of B'nai B'rith is the formal name of the organization established in 1913 and incorporated in 1946. The Anti-Defamation League is the same organization and is often used as a shortened version of the name. The web site address is www.adl.org. You are of course free to select an alternative name for your organization. Since we have dealt with this issue on numerous occasions, we would be happy to furnish you with a list of other possible names which you might want to consider. We don't mean to imply any opposition to the work of your organization, neither do we necessarily endorse your group. Our sole concern is protecting our trademark. Sincerely, Jill Kahn Meltzer Corporate Counsel