DLA Piper Rudnick Gray Cary Letter Page 1
15 March 2006
Dear Sir
www.easy-mobiles.co.uk
We have been instructed by our client, easyGroup IP Licensing Limited, to write to you in relation to your registration of the domain name easy-mobiles.co.uk.
Since 5 November 2000, our client has acted as the central holder of the intellectual property rights which support the “EASY” brand.
As you may be aware, our client’s use of the “EASY” brand dates from a massive advertising campaign that was undertaken to launch the airline company, easyJet pic, which started operation in November 1995 under the mark EASYJET. easy Jet’s turnover since launch is approximately £2,350 million. On average there are about 600,000 visits to easyJet’s website per week. easyJet has carried over 50 million passenger since its first flight and currently operates 258 routes to 71 European destinations.
You will also be well aware of our client’s chain of Internet cafes that from June 1999 until October 2001 traded under the mark EASYEVERYTHING and thereafter under the mark EASYINTERNETCAFE. easylnternetcafe currently has 74 stores operating in 9 countries including the USA. Since launch over 58 million people have visited easylnternetcafes worldwide. The Internet store in New York is the largest in the world.
In November 1998, our client announced in the UK press that one of its next “easy” businesses would be in the car rental field. It registered the domain name www.easyRentacar.com in March 1999 and from May 1999 the website at this domain advertised its forthcoming business under the mark EASYRENTACAR. Originally under the mark EASYRENTACAR, and now under the mark EASYCAR, our client has offered car rental services and currently provides a brokerage service for 2000 locations in 47 countries. Total marketing spend to date is approximately £15 million and the turnover to date is approximately £88 million.
As early as March 2004, our client first publicised its intention to launch low cost mobile telephone services under an “EASY” prefixed name. In August 2004 our client announced it would be launching its mobile telephone service under the name “EASYMOBILE” in connection with the Danish communications company TDC. This was widely publicised in the national media. For example, on 11 August 2004 alone, all but one of the national daily newspapers reported the imminent launch of
tags: , nominet, whois, domain dispute, easygroup, easymobile, reverse domain hijacking