WASHINGTON D.C. OFFICE anchorage, alasll'n 4 fz'??h floor ?at/Tug. r/u'na fiaur building new york. new york A A street nw portlana?, wagon SCHUBERT washington. (Le. 20007-350! wattle. waskt'ngtan A PARTNERSHIP or PROFESSIONAL CORPORATIONS TEL 202 965 7330 FAX 202 965 1729 GSBLAW.COM Please reply to BRAD C. DEUTSCH bdeursch@gsb1aw.com TEL EXT 1793 June 12, 2015 VIA CERTIFIED U.S. MAIL RETURN RECEIPT REQUESTED AND BY EMAIL TO Mr. Cary L. Peterson 848 N. Rainbow Blvd, Suite 3419 Las Vegas, NV 89107 1 101 Avenue, NW, FL-S Washington, DC 20004 info@b etonbernie.com Re: Bet on Bernie 2016 Dear Mr. Peterson: This ?rm serves as legal counsel to Bernie 2016, Inc. (?Bernie 2016?), the of?cial campaign committee for Senator Bernie Sanders? 2016 U.S. presidential bid. Your political committee, ?Bet on Bernie 2016,? FEC Committee ID: C00572537 (the and associated campaigns (2. g. Ready for Bernie Sanders 2016) and websites ?ready4bernie.com,? ?betonbernie.com,? ?pledgesander32016.c0m,? ?plus and ?facebook.com/ 6? (collectively the ?Campaigns and Websites?), have recently been brought to our attention. While Bernie 2016 is grateful for your enthusiasm, we are compelled to inform you that your current efforts are illegal and are causing harmful confusion for supporters of Senator Sanders? campaign. As you surely understand, contributions are critical to the success of any political campaign. Your Campaigns and Websites are creating supporter confusion because they appear to be of?cial pages for Junel2,2015 3.1 a] Cary L. Peterson Page 2 the Bernie Sanders 2016 US. presidential campaign, and are therefore intercepting donations which are likely intended for the of?cial campaign. In addition to this practical concern, your Campaigns and Websites violate federal law and infringe upon Bernie 2016?s intellectual property. Most obviously, the name ?Bet on Bernie 2016? is a clear violation of section 102.l4(a) of the rules, 11 CFR which prohibits your committee from using ?the name of any candidate in its name.? Furthermore, section 110.16(b) of the rules, 11 CFR prohibits soliciting donations by fraudulently misrepresenting ?the person as speaking, writing, or otherwise acting for or on behalf of any candidate or political party or employee or agent thereof for the purpose of soliciting contributions or donations . . . In addition to these serious violations of federal law, your Campaigns and Websites infringe upon Bernie 2016?s intellectual property. Bernie 2016 holds the trademarks and copyrights in ?Bernie 2016,? and the distinctive logo (the ?Bernie Marks?). Section 43(a) of the Lanham Act, 15 U.S.C. 1 125, prohibits the use in commerce of ?any word, term, name, symbol or device . . . which is likely to cause confusion, or to cause mistake, or to deceive as to the origin, sponsorship or approval of his or her goods, services, or commercial activities by another person.? As discussed above, your Campaigns and Websites have caused, and will continue to cause, this type of confusion among potential contributors to Bernie 2016. Your Campaigns and Websites also infringe upon Bernie 2016?s copyrights in violation of 17 U.S.C. 501. We appreciate your support for Senator Sanders and this letter is intended to be a courtesy, in advance of any action Bernie 2016 may have to take to protect its rights and prevent fraud. It is our sincere hope that such action will not be necessary. To that end, please, con?rm, within ?ve (5) days of the date of this letter that you will immediately: 1. Take of?ine ?ready4bernie.com,? ?betonbemiecorn,? ?pledgesanderSZOI6.com,? ?plus. goo 1 and any other websites or social media accounts in your control associated with the ?Bet on Bernie 2016? political committee or Senator Bernie Sanders. 2. Either change the name or terminate the ?Bet on Bernie 2016? political committee; 3. Cease and Desist any further use of the Bernie Marks, any other deceptively or confusingly similar mark or proprietary content, or Senator Bernie Sanders? name and/or likeness; 4. Provide us a full ?nancial accounting detailing all donations received by ?Bet on Bernie 2016,? and any and all associated campaigns. "9 Cary L. Peterson :1 GARVEYSCHUBERTBARER June12,2015 _l Page 3 A prompt response is both appreciated and expected. If you have any questions, please have your attorney contact me at the number above. Bernie 201,6 reserves all rights, claims, defenses, remedies, and contentions that it may have in connection with the subject matter of this letter. This letter is not. a full recitation of all reletrant matters, and nothing omitted from earlier contained in this letter shall be construed as, or deemed to be, an admission or a Waiver by Bernie 2016. Sincerely, 5 Brad C. Deutseh WASHINGTON. DC. OFFICE OTHER OFFICE-5 fifth floor lmijmg, rhino flour mill building new york. new york in 1000 polamac street nw washington. (Le. 20007n3501 scuttle, TEL 202 965 7880 FAX 202 965 [729 GARVEYSCHUBERTBARER A 0N5- Please reply to BRAD C. DEUTSCH bdeulsch@gsblaw.cam '1 TEL EXT 1793 it June 19,2015 VIA CERTIFIED U.S. MAIL RETURN RECEIPT REQUESTED AND BY EMAIL T0 . . qp-A?. Mr. Cary L. Peterson 848 N. Rainbow Blvd, Suite 3419 Las Vegas, NV 89107 1101 Avenue, NW, FL-S Washington, DC 20004 clpeterson@betonbernie.com Re: Citizens Socially United (fka Bet on Bernie 2016) FEC Committee ID No. C00572537 Dear Mr. Peterson: As you know, this ?rm serves as legal counsel to Bernie 2016, Inc. (?Bernie 2016?), the of?ciai . campaign committee for Senator Bernie Sanders? 2016 U.S. presidential bid. First, let me thank you for your recent phone and e-mail communications and the steps you have taken to comply with applicable cepyright and trademark laws, as well as federal election law by changing the name of your political committee. I also want to thank you for your commitment to transition all of your activities to enSure that you and your activities do not misrepresent that you are in anyway af?liated .g with, endorsed by, or acting on behalf of Senator Sanders or Bernie 2016. PW..- decision and the proliferation of so?called Super PACs. In fact, campaign ?nance reform is at the forefront of Senator Sanders? presidential campaign. Moreover, it is illegal for any candidate to As you know, Senator Sanders has taken a strong position against the Supreme Court?s Citizens United I I <3 3 Cary L. Peterson A i; r: 21 r; "r June 19,2015 n; Page 2 coordinate with a Super PAC, and therefore any communications between your political committee (which operates, in-part, as a Super PAC) and the campaign would risk leading to prohibited coordination and therefore would be inappropriate. Accordingly, the campaign is not granting any requests from Super PACs for meetings or direct communication. As I have indicated to you before, we appreciate your continued support for Senator Sanders. However, in light of the legal issues outlined above and in our previous letter dated June 12, 2015, as well as because of Senator Sanders? ?erce opposition to Super PACs, we must insist that you refrain from claiming or implying any connection between yourself or your political committee and Senator Sanders or his campaign. Bernie 2016 reserves all rights, claims, defenses, remedies, and contentions that it may have in connection with the subject matter of this letter. This letter is not a full recitation of all relevant matters, and nothing omitted from and/or contained in this letter shall be construed as, or deemed to be, an admission or a waiver by Bernie 2016. Brad C. Deutsch