From: AMPaquette@aol.com
Message-ID: <d0.207e8bb6.296f877d@aol.com>
Date: Thu, 10 Jan 2002 19:10:37 EST
Subject: Notice of Copyright Infringement 
To: brianr@osiris.978.org
CC: AMPaquette@aol.com
MIME-Version: 1.0
Content-Type: text/plain; charset="US-ASCII"
Content-Transfer-Encoding: 7bit

Dear Mr. Ristuccia:

     Our office represents Church of Scientology International ("CSI") a 
non-profit
religious corporation located in Los Angeles, California regarding 
intellectual property
matters.  

     Our client has authorized us to send you this notification of copyright
infringement that is occurring on your web site and request that the 
offending
infringements be removed immediately.  
                                
              Identification of Copyrighted Works

1.   Photograph of "Captain David Miscavige" (Chairman of the Board Religious
Technology Center) located under the following URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/steering

.jpg

     The photograph of Mr. Miscavige is taken from the publication Highwinds:
Magazine of the Sea Organization and is copyrighted by Church of Scientology
International, Issue 19, 1996 at page 11.  

2.   Photograph of persons sitting around a table, entitled "The top of 
Scientology in
1990", located under the following URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/4.jpg

     This photograph is taken from the publication Impact: Magazine of 
International
Association of Scientologists, Issue 33, 1990 at page 48, and is copyrighted 
by Church of Scientology International.

3.   Photograph of Heber Jentzsch (President of the Church of Scientology
International),  located under the following URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/6a.jpg

     This photograph of Mr. Jentzsch is taken from the publication Highwinds:
Magazine of the Sea Organization, Issue 19, 1996 at page 52, and is 
copyrighted by 
Church of Scientology International.

     4.   Photograph of Ms. Liz Ingber located under the following URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/6b.jpg

     This photograph of Ms. Ingber is taken from the publication Highwinds: 
Magazine
of the Sea Organization, Issue 19, 1996 at page 52, and is copyrighted by 
Church of
Scientology International. 

     5.   Photograph of Jeff Hawkins located under the following URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/6c.jpg

     This photograph of Mr. Hawkins is taken from the publication Highwinds:
Magazine of the Sea Organization, Issue 19, 1996 at page 52, and is 
copyrighted by 
Church of Scientology International. 

     6.   Photograph of the Gold Sea Org Ring, located under the following 
URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/6d.jpg

     This photograph of the Gold Sea Organization ring is taken from the 
publication
Highwinds: Magazine of the Sea Organization, Issue 19, 1996 at page 52 and is
copyrighted by Church of Scientology International.

7.   Photograph captioned "Helena Kobrin's early years", located under the 
following
URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/5b.jpg

     This photograph is taken from the publication Impact: Magazine of the
International Association of Scientologists 1991, Issue 39,  at page 32, and 
is copyrighted by Church of Scientology International.  

8.   Photograph captioned "OSA: Office of Special Affairs", located under the
following URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/3.jpg

     This photograph is taken from the publication Highwinds : Magazine of 
the Sea
Organization, Issue 19, 1996 at page 36, and is copyrighted by Church of 
Scientology International.

9.   Photographs captioned "They donated 1,000,000 USD each!" and "Don't go,
there's more . . .", located under the following URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/1.jpg

     These photographs are taken from the publications, Impact: Magazine of 
the
International Association of Scientologists,  Issue 34, 1991 at pages 20 & 21 
and Issue 39, 1991 at page 24, and is copyrighted the Church of Scientology 
International. 

10.  A photograph headed "Don't go, there's more . . ." located under the 
following
URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/2a.jpg
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/2b.jpg

     These photographs are taken from the publications, Impact: Magazine of 
the
International Association of Scientologists,  Issue 39, 1991 at page 24 and 
are
copyrighted by Church of Scientology International. 

11.  A photograph of persons standing on the deck of a ship located under the
following URLs:

http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum 
http://osiris.978.org/~brianr/mirrors/www.xenu.net/archive/photoalbum/7a.jpg

     This photograph is taken from the publication Highwinds: Magazine of the 
Sea
Organization 1996, Issue #19 at page 11, and is copyrighted by Church of 
Scientology International.

     You have posted these copyrighted works on your web site without the
authorization of our client.  As such, your conduct violates United States 
copyright law. 

     Numerous permanent injunctions and awards of statutory damages and 
attorneys'
fees have been entered regarding similar infringements.  For instance, in May 
1998, a
jury in the United States District Court in San Jose, California awarded 
statutory damages in the amount of $75,000 against a Mr. Henson for engaging 
in similar infringing activities on the Internet as to one single copyrighted 
work.  Statutory attorneys' fees were also awarded against Mr. Henson and, in 
addition, he is also permanently enjoined from committing any further 
infringements.   A United States District Court in the state of Virginia 
granted judgment for damages, costs, and a permanent injunction related to 
similar copyright infringement.  Permanent injunctions have also been entered 
in three additional U.S. cases.

     Similar results have been reached in Europe.  On September 14, 1998, a 
Swedish court enjoined a defendant who engaged in similar infringements, in 
addition to finding that his actions in placing our client's copyrighted 
works on the Internet violated the owner's rights under Swedish copyright 
law.  He was also fined for his illegal actions and ordered to pay litigation 
costs.  The decision by the Swedish court was upheld on appeal in a decision 
issued on March 9, 2001.   On June 9, 1999, a Dutch court found an individual 
and numerous Internet service providers had engaged in copyright infringement 
by posting, or hosting, our clients' copyrighted works on their web sites.  
The court ruled that the service providers must remove such postings as soon 
as they are notified of them, subject to a monetary penalty for each day on 
which they do not comply.  
 
     We request that these works be removed immediately.

Sincerely,
Ava Paquette
Moxon & Kobrin
3055 Wilshire Boulevard
Suite 900
Los Angeles, California 90010
Tel: (213) 487-4468
Fax: (213) 487-5385