To Whom It Concerns:
We have been retained by David Katz to represent him regarding copyright
violations and other wrongdoing related to the unauthorized use of Mr. Katz’s copyrighted
photograph on Wikipedia.org. You are the registrant and owner of Wikipedia.org. I am
authorized to act on behalf of Mr. Katz, the copyright owner. My electronic signature is below.
I can be contacted at the address, phone number, and email address listed above.
Mr. Katz is the owner of the copyright and other intellectual property rights
in a photograph taken on May 17, 2005. The photograph depicts a seated Nelson Mandela
greeting then-Senator Barack Obama, the latter of whom is standing and cast entirely in shadow.
Mr. Katz has owned the copyright and other intellectual property rights in this photo without
interruption since the date it was taken. The infringing content can be located on your website at
the locations listed in the next paragraph.
Without authorization, Wikipedia.org fully incorporates Mr. Katz’s copyrighted
photograph at the following locations:
The website uses Mr. Katz’s work in multiple locations and in several different sizes. By using the copyrighted work on your website, you falsely suggest the use is authorized by or endorsed by Mr. Katz. You have no legitimate interest in Mr. Katz’s copyright and your commercial use of the work in any manner is not authorized. Your ongoing use damages Mr. Katz’s own commercial and artistic interests.
I have a good faith belief that the use of the material in the manner complained of is not authorized by Mr. Katz, his agents, or law.
Accordingly, we demand that you immediately remove Mr. Katz’s work from all web pages on Wikipedia.org, including, but not limited to, the locations listed above.
Below is a statement by me made under oath regarding this matter. Please confirm in writing your agreement to comply with Mr. Katz’s demand as soon as possible and no later than by close of business today. This letter does not waive any rights or remedies of our client, all of which are expressly reserved.
Very truly yours,
/s/ Gary M. Miller