This letter from a law firm represents M. Shanken Communications, owner of the CIGAR AFICIONADO trademark. It informs Roger Seawright that registering the domain name cigaraficionado.org and attempting to profit from its sale constitutes cybersquatting and infringement of M. Shanken's trademark rights. The letter demands that Seawright cancel the domain name registration and cease any solicitations to sell the domain name. Failure to comply will result in legal action to enforce M. Shanken's rights.

1. Reed Smith LLP
599 Lexington Avenue
New York, NY 10022-7650
Tel +1 212 521 5400
Fax +1 212 521 5450
reedsmith.com
Peter D. Raymond
Direct Phone: +1 212 549 0364
Email: praymond@reedsmith.com
NEW YORK  LONDON  HONG KONG  CHICAGO  WASHINGTON, D.C.  BEIJING  PARIS  LOS ANGELES  SAN FRANCISCO  PHILADELPHIA  SHANGHAI  PITTSBURGH  HOUSTON
SINGAPORE  MUNICH  ABU DHABI  PRINCETON  NORTHERN VIRGINIA  WILMINGTON  SILICON VALLEY  DUBAI  CENTURY CITY  RICHMOND  GREECE KAZAKHSTAN
r e e d s m i t h . c o m
February 27, 2014
VIA EMAIL AND FEDERAL EXPRESS
Mr. Roger Seawright
Internet Consulting LLC
d/b/a Wall Decor Prints
10300 Little Patuxent Parkway
Columbia, Maryland 21044
stormyseasphotography@gmail.com
roger@internetconsulting.co
CIGAR AFICIONADO®
- Cyber Squatting and Solicitation of Trademark Infringement and
False Association
Dear Mr. Seawright:
This firm represents M. Shanken Communications, Inc. (“M. Shanken”) in connection with intellectual
property matters.
Our client is the owner of the trademark/service mark CIGAR AFICIONADO, ®
the subject of
numerous worldwide registrations, including registrations in the United States
1
, covering a variety of
goods and services relating to its world famous print and on-line magazine in the field of cigars. Indeed,
M. Shanken has invested substantial time, money and effort in the marketing and sales of its goods and
services under the CIGAR AFICIONADO mark on an international scale. As a result, the CIGAR
AFICIONADO mark is famous, and now enjoys enormous consumer recognition and substantial
goodwill and, thus, is a property of incalculable value to our client.
It has come to our attention that you have registered the domain name cigaraficionado.org, which you
have registered through GoDaddy.com. Although it appears that you are not currently using this domain
name in connection with an operational web site (it is currently parked at GoDaddy), you are
cybersquatting the domain and intend to illicitly and unlawfully profit on its sale by soliciting 3rd
party
1 U.S. Registration Nos. 2,025,421, 2,054,780, 2,131,128, and 2,614,669.

2. Mr. Roger Seawright
February 27, 2014
Page 2
merchants in the cigar trade, as evidenced by the attached email and as posted below (emphasis added):
From: roger@internetconsulting.co
To: arangocigar@aol.com
Sent: 1/9/2014 7:37:45 P.M. Central America Standard Ti
Subj: What CigarAficionado.com doesn't want you to know...
First let me say that here I'm explaining a vulnerability. The vulnerability that I speak of is very
simple.
The company that owns the domain name CigarAficionado.com did not do their due diligence
when purchasing their domain name. They left a very critical domain name available....
www.CigarAficionado.ORG
This is a serious micalculation on their part and a vital exploit that another cigar company can
take advantage of.
1. Cigar Aficionado is not a company... its a word that describes a person with the foundness for
cigars.
Burger King and Red Lobster are also words companies but I bet you couldn't find the .org
available. You can copyright a person's name like McDonald's but not a set of words like green
car and Red House. Get it ?
2. CigarAficionado.com is a magazine. If you are not a magazine and you build your site on
www.CigarAficionado.org then there is not Trade Mark issue.
I am Accepting Offers for this valuable domain name. Please only serious offers will be
considered. This could be the best marketing decision you could make.
I own www.WallDecorPrints.com ... its ranked for the keyword Wall Decor Prints. Understand ?
With this domain name you could rank your site right under www.CigarAficionado.com
thanks for your consideration,
Roger Seawright
Internet Consulting LLC
301-385-5833
Putting aside the false and inaccurate statements of fact and law in your email, such conduct is an
infringement of M. Shanken’s trademark rights under federal and state law and constitutes
cybersquatting in violation of the federal Anticybersquatting Consumer Protection Act of 1999 (the
“Cybersquatting Act”), which is incorporated into the federal Lanham Act. Indeed, any use of a
“cigaraficionado” domain name or similar name or formative domain name is likely to confuse persons
interested in M. Shanken’s business or in doing business with M. Shanken, as well as customers,
potential customers and the general public who are seeking M. Shanken’s web site. Any such use is also
likely to misdirect persons to your web address and any web site you or your prospective customers may
intend to operate in the future. Moreover, your email solicitation, with its explicit offer for sale with the
incentive of high search page ranking (“right under www.CigarAficionado.com”), constitutes prima
facie evidence of bad faith and is a blatant attempt to commit and contribute to trademark infringement,
among other related causes of action. Even without your overt unlawful solicitations, your mere
registration of the cigaraficionado.org domain name, albeit parked at GoDaddy, is likely to cause the
interested public to mistakenly believe that you and your domain name are somehow related to,
associated with or sponsored by M. Shanken. As such, your conduct also constitutes false designation
of origin, sponsorship and endorsement under federal and state unfair competition law.
The Lanham Act provides numerous remedies for trademark infringement, including preliminary and
permanent injunctive relief, monetary damages, disgorgement of profits and attorneys’ fees. In addition,

3. Mr. Roger Seawright
February 27, 2014
Page 3
for cybersquatting, the Lanham Act authorizes a court to order the forfeiture or cancellation of a domain
name or the transfer of the domain name to the owner of the mark as well as actual monetary damages,
or, if the plaintiff elects, statutory damages, which a court may award in amounts ranging from $1,000 to
$100,000 per domain name. In addition, your registration subjects you to the jurisdiction of WIPO (the
“World Intellectual Property Organization”) and its procedures under the Uniform Domain Name
Dispute Resolution Policy (“UDRP”). Indeed, given your express bad faith statements in your email
solicitations, we would surely prevail in a UDRP proceeding.
M. Shanken is very serious about protecting its rights and the value in its intellectual property assets.
Accordingly, our client hereby demands that you promptly and completely discontinue any and all
further use, and/or abandon any plans for future use, of the cigaraficionado.org domain name or any
other similar formative name. Our client further demands the immediate cancellation of your domain
name registration for cigaraficionado.org and any other CIGAR AFICIONADO formative domain
names you may have registered in your nefarious scheme. To that end, we demand on behalf of our
client that you provide us with the Registry Key and Tracking Numbers, which were provided to you by
GoDaddy when you registered this domain name, as well as any other documentation and information
necessary, so that we may prosecute transfer of the domain name registration. Finally, and most
paramount, M. Shanken demands that you immediately cease and desist from any further solicitations to
any 3rd
party attempting to sell the cigaraficionado.org domain name or any other similar domain.
M. Shanken would like to resolve this matter expeditiously. However, in the event that you fail to
respond or refuse to comply with these demands, our client is prepared to take whatever steps it deems
appropriate to protect its rights and prevent further infringement and violation of its rights. Accordingly,
please confirm to the undersigned, in writing, within five days of the date of this letter, that you have
discontinued all infringing activities and solicitations and are complying with all demands set forth
above. If we do not receive a satisfactory response from you within this time frame, we will assume that
you are not going to comply with these demands, and our client will exercise all available legal remedies
to enforce its rights.
This letter is without prejudice to M. Shanken’s rights and remedies, in fact or law, all of which are
expressly reserved.
Very truly yours,
Peter D. Raymond
PDR:dbc
cc: Mr. Marvin Shanken
Ms. Mel Mannion
Darren B. Cohen, Esq.