Case 1:17-cv-20952-UU Document 101 Entered on FLSD Docket 03/14/2017 Page 81 of 120

Mareh3,2017

David Jnhanilliams. President

Trinidad Tobago Football Association
--

Haser Crawrord Notional smdiurn

Road

Port or Spain

Trinidad Tobago, WJ.

 

Dear Mr. John-Williams:

I write to follow up on the email that I sent Dn Wednesday to Francisco 831de of
Publicidades USA. Francisco had extended an invitation on your behalffor the two of us to meet
in Miami, I remain happy to meet with you if our schedules allow However, I want to further
emphasize the other points that mtlde in my email to Francisco.

Telemundn learned in mid--February, when] was contacted by Ylan Singer of Elite Soccer
that Elite seemed to be trying lo resell U.S. Spanish-language broadcasl rights to
upcoming 2018 World Cup qualifying matches of the Trinidad men's natinnal team. We later
confirmed that this strategy of trying to resell the rights to those matches was, in fact, authorized
by the We nlso learned that agents acting for the WM were contacting competitors of
Tulcmundo and olfcring to sell them the rights,

The Elite and Publicidades are well aware that Telemundo acquired those rights --
exclusively. in good faith, and for Valuable consideration 7 in a transaction with 'l'rat'lic Sports
and Media World in December 2014. Until the very recant communications from Ylan and
Francisco, no one representing the (or anyone else) ever questioned the legitimacy of
Telemundo's acquisition nfthe rights. In fnct,just last November, we broadcast on the NBC
Universo network the Costa Rica vs. Trinidad qualifying game played in Trinidnd sand no one
snid a word to us to indicate that Telemundo's rights were in question

We now understand that is asserting dist them was some impropriety in the
transaction the Caribbean Football Union and Truffle Spons. We are obviously not in a
position to speak to matters concerning that transaction other than to say that we purchased the
rights ror valuable consideration and without notice ornny such alleged impropriety, imd have
been enioying those rights with the 'l'l'lt'A's rull knowledge and without any objection rroni the

25M

Case 1:17-cv-20952-UU Document 10-1 Entered on FLSD Docket 03/14/2017 Page 82 of 120

TTFA until now. Whatever defect that the lTFA claims might exist in any transfer of the rights
that occurred upstream from Telemundo, please know that Telemundo owns, and will vigorously
assert, the exclusive U.S. Spanish broadcast license to the games in question - including the
games scheduled for March 24 and March 28, 2017. Any attempt by the lTFA or its agents to
resell, renegotiate or market those rights is a violation ofTelemundo's rights, an interference
with Telemundo's contract with Traffic and Media World, and is wholly unacceptable to
Telemundo. Likewise, any action (or inaction) on the part of the TTFA or its agents that hinders
Telemundo from broadcasting the games, such as any interference with the television production
of the games, would be a violation of our rights.
Accordingly, please confirm in writing, by 5 p.m. EST on Monday, March 6, 2017, that:
(1) TTFA and its agents recognize that Telemundo has the exclusive U.S. Spanishlanguage broadcast rights to the 2018 World Cup qualifying matches of the Trinidad
men's national team;
(2) TTFA and its agents will cease and desist from any effort to resell, renegotiate or
market those rights; and
(3) Neither TIFA or its agents will not take any action (or inaction) that hinders
Telemundo from exercising those rights.

If the TTFA does not agree to respect Telemundo's rights, please specify in writing all of
the reasons for the TIFA's position.
Telemundo has been, and we want to continue to be, a good broadcast partner for the
TTFA,just as we are for other CONCACAF members. Please know, however, that if necessary
we will take all appropriate legal action against the 1TFA and its agents to enforce our rights.
In the interim we continue to reserve all of our legal rights in this matter.

Eli Velazquez,
Executive Vice President, Sports,
Hispanic Entertainment & Content, NBCUniversal

Cc: Francisco Salcedo, Publicidades USA (fjsa1cedo@gmail.com)
Ylan Singer, Elite Soccer Agency (ylan@msportsgroup.com)
Eliot Pedrosa, Esq., Greenberg Traurig LLP
Jonathan Walker, Partner, M. Hamel-Smith & Co.

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