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Barney's lawyers vs. WWWF Grudge Match

            February 1, 2001

BY E-MAIL AND CERTIFIED MAIL,
RETURN REQUESTED

    Re: Unauthorized Use of Intellectual Property

Dear Mr. Wright:

    This firm is counsel to Lyons Partnership, L.P. (“Lyons
Partnership”), the owners of the exclusive right to use the copyrighted
children’s dinosaur character Barney® as well as the federally
registered and famous trademark and service mark Barney.

    It has come to the attention of Lyons Partnership that you are
operating a website found at URL:
www.grudge-match.com/History/barney-wesley.shtml. We have reviewed your
website and have concluded that it incorporates an image of the
children’s character Barney without permission from Lyons Partnership.

    Your actions constitute direct copyright infringement, and make you
subject to injunction and liable to Lyons Partnership for its damages,
costs and attorneys’ fees. Pursuant to 17 U.S.C. § 501(a), “anyone who
violates any of the exclusive rights of the copyright owner as provided
by sections 106 through 118, or of the author as provided in 106(a), is
an infringer of the copyright or right of the author….”

     Lyons Partnership hereby demands that you immediately cease and
desist from reproducing, distributing, performing by means of digital
audio transmission, displaying, or in any other way infringing upon
Lyons Partnership’s copyrights. Lyons Partnership is prepared to pursue
all available remedies to protect its intellectual property rights.
However, Lyons Partnership will refrain from taking immediate legal
action upon condition that you provide written assurances by February
22, 2001, that you have ceased and desisted from reproducing,
distributing, performing by means of digital audio transmission, or
displaying the copyrighted character Barney.  Your written assurances
must also state that you have removed all website content relating to
the unlawful use of the Barney copyrights as well as any links to the
official Barney websites.

    We await an immediate response from you or your counsel.

            Sincerely,

            GIBNEY, ANTHONY & FLAHERTY, LLP
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