To Whom It May Concern, We are writing concerning your registration and use of the domain name XXXXXXXX.club, which contains the Instagram trademark. You are undoubtedly familiar with Instagram and its worldwide renown in providing photo sharing and editing services and related products and services through a number of channels, including through its mobile application software and its website available at Instagram.com. Instagram owns exclusive rights to the INSTAGRAM trademark, including rights secured through common law use and registration in the United States (Reg. Nos. 4,170,675 and 4,146,057) and internationally. Instagram is a global leader in photography software for mobile devices, with over 30 million registered users. These users have uploaded more than 1 billion photos for editing and sharing with others either directly or through their social media networks. Due to Instagram’s exponential growth and immense popularity, the Instagram brand, is frequently, if not daily, referenced in the media and pop culture. Its fame entitles it to broad legal protection. We have recently discovered that you registered the domain name XXXXXXX.club, which incorporates the famous INSTAGRAM mark. Instagram has an obligation to its users and the public to police against the registration and use of domain names that may cause consumer confusion as to affiliation with or sponsorship by Instagram, dilute the distinctiveness of its INSTAGRAM mark, or otherwise tarnish the mark. Accordingly, in addition to civil actions, Instagram and its parent Facebook have filed numerous proceedings pursuant to ICANN’S Uniform Domain-Name Dispute-Resolution Policy (http://www.icann.org/en/help/dndr/udrp) to secure the transfer of infringing domain names. Moreover, the Anticybersquatting Consumer Protection Act provides for serious penalties (up to $100,000 per domain name) against persons who, without authorization, use, sell, or offer for sale a domain name that infringes another’s trademark. While Instagram respects your right of expression and your desire to conduct business on the Internet, Instagram must take action to stop the misuse of its intellectual property. As you can imagine, various third parties around the world have attempted to wrongfully capitalize on Instagram’s reputation by registering domain names that include or are derived from the INSTAGRAM brand. Such names are confusingly similar to, dilutive of, and can tarnish the INSTAGRAM mark. We understand that you may have registered XXXXXXXX.club without full knowledge of the law in this area. However, Instagram is concerned about your use of the Instagram trademark in your domain name. Accordingly, we must insist that you immediately cease using XXXXXXXX.club and disable any site available at that address. You should not sell, offer to sell, or transfer the domain name to any third party. Please confirm in writing that you will agree to resolve this matter as requested. If we do not receive confirmation that you will comply with our request, we will have no other choice but to pursue all available remedies against you. Sincerely, Edith Legal Dept. Instagram, Inc. ----------------------------------------------- Do I apply?