The Riddick/Imageline Settlement Demand Letters

Information Page

Last updated: 3/10/2009

Reprinted Letters from George Riddick of Imageline Inc.

These letters were submitted to me by the letter recipients for our reporting. Due to the large amount of space, I have created an entire page dedicated to Mr. Riddick's and ImageLine's letters. I believe you will find this interesting reading and a pattern of behavior throughout the various communications by Mr. Riddick. I think you will agree that much of what he writes is outrageous and unprofessional.


Sample Imageline Cease & Desist Letter

What you see is a sample e-mail based Cease and Desist Letter sent by Mr. Riddick himself.

From: George Riddick [mailto:griddick@imageline2.com]
Sent: XXXsday, XXXXuary XX, 2009 XX:XX PM
To: XXXX@XXXX.com
Cc: ggray528@yahoo.com; gpaine3@yahoo.com
Subject: URGENT - Copyright Infringement Notification - Cease and Desist
CONFIDENTIAL - Copyrights: Code (Red) – Embroidery Industry

Just like the ships off of the coast of Somalia, your industry is under siege. Digital pirates have infiltrated practically every channel of distribution we have been able to investigate in the embroidery design industry.

Unfortunately, we have witnessed other industries that have been totally destroyed by this exact same kind digital piracy over the past 10-12 years. The Internet has changed all of the rules of what we used to consider our “normal” distribution models - ones with the appropriate business ethics and checks and balances solidly in play. The unlawful activity we have discovered in our recent detailed and extensive investigation of embroidery companies has both severe civil and criminal consequences under the laws of this country. Please ask your own attorneys to explain these to you thoroughly.

Official Notice of Copyright Infringement

Imageline has uncovered massive and flagrant copyright infringement of our proprietary and copyright-registered electronic graphic arts content (clip art illustrations, design templates, embroidery designs, and/or animations) within the distribution channels of the embroidery industry. We have identified our exclusive digital artwork on the above web site(s) owned and/or operated by you and your company.

We highly recommend that you consult a competent intellectual property attorney and get back to us immediately.

Massive amounts of research and documentation still required

We are unable to handle the massive amount of research, investigation, and documentation that will be required to quantity all of these infringements in any short period of time. We have discovered over a million embroidery designs in the market thus far, and we have only researched a fraction of the web sites, retail stores, and other related locations where our hard-earned property may be improperly utilized in the stream of commerce.

Yet, as each day goes on, the damages suffered by this small graphics arts development company grows exponentially. Therefore, we need your help and cooperation to identify each and every embroidery design in your possession that was not originally drawn by your own in-house artists, artists under written “work-for-hire” agreements, or licensed to you with full indemnification by a reputable design/production company you can trust. We intend to continue our extensive identification and “finger-printing” efforts as well.

In the print and Internet web page worlds (where we have been an industry leader for 25 years), this research process is far easier, as we embed certain copyright identification and recognition codes and technology into our standard design files. But when your industry changes the file formats of our work to embroidery image files, much of these identification tools are removed. Those image alterations, alone, subject the violator to penalties of between $2,500 to $25,000 per image file under Section 1202 of our current copyright laws (over and above any copyright infringement claims that are made). In fact, in most cases we have discovered, you, or another company such as yourself, claims copyright ownership of the new embroidery design files, and misrepresents such exclusive ownership to your suppliers, business associates, investors, and customers.
  
The entire image discovery and documentation project is very time-consuming and precise in its implementation with the quality controls we demand. We have never misrepresented our exclusive ownership once in our 25 years of operation. We have also never lost a case we were forced to bring to trial or arbitration to protect our property.

We’ve reached out for your industry’s cooperation and assistance

As you can clearly see from the urgent e-mail we sent to the Embroidery Trade Association last week (copied below), Imageline has attempted to reach out to your industry in order to evaluate some sort of global resolution to this massive problem. Irreparable damage has already been caused to Imageline, the leading designer and developer of vector-based original designs and other digital artwork in the PC industry for the past 25 years.

Once we verify the correct detailed contact information for you and your company, we will begin sending you copies of our documentation. We will also send you all of the materials we have prepared to support these claims, including copyright registration numbers associated with the image files. You should, however, note that you are being officially notified by this e-mail correspondence to immediately cease and desist all displaying and/or downloading of any Imageline digitized graphic arts content or designs that you have not properly contracted for, licensed, and verified the legitimate copyright owner from your written records.

By continuing to display and download these proprietary Imageline images without authorization, you are also placing your clients (and their customers) at risk of further copyright infringement liabilities, as well.

Logistics and other required information

Please verify receipt of this e-mail and send us the required contact information (executive officers, owners, corporate counsel, copyright agent, facsimile numbers, e-mail addresses telephone numbers, and physical mailing address - no P.O. boxes) immediately so that we can provide you further information. It will be most beneficial for your organization (at the highest level) to attend our proposed “Alternative Dispute Resolution” conference discussions in Dallas in mid-January, as much of our confidential information will be disclosed there for the first time if we can continue on our current identification and documentation pace.

If you own or are associated with any other web sites, or physical locations, where the Imageline graphic arts content (now converted into embroidery files) may be displayed or used, please identify such sites in your response so that our research and investigative units can do further analysis into these serious copyright violations.

If you choose to get your attorney involved with this issue at this point in time, please have he/she contact me immediately directly at griddick@imageline2.com. I will then decide to what degree our attorneys need to be involved. At this point in time, we are still gathering facts, researching catalogs and web pages, and trying to determine whether you and your company intend to cooperate with us in this investigation and are prepared to negotiate the appropriate resolution (including compensation for damages already sustained) of this extremely serious matter.

Retention of files. Written communications required to manage this amount of information in the short term

Since there is strong likelihood that these disputes could end up in litigation, we also request that you retain all original documentation and files (written or electronic) pertaining to any Imageline images, embroidery designs obtained or produced from those image files, and all distribution, sales, and customer records pertaining the digital files, as well as any CDs, DVDs. Disks, Memory or Media cards, USBs, or other electronic combinations of embroidery design files, in your possession, and do not destroy any records.  

At this point in time, we would appreciate all further communications to be in written form and be documented via e-mail and/or facsimile (804-525-6943). You can verify our Imageline, Inc. copyright registrations at www.copyright.gov, and you can gauge our seriousness in this matter by the company we keep, and have kept of the past 25 years. We are executive members of the Copyright Alliance (www.copyrightalliance.org) and the Software and Information Industry Association (www.SIIA.net) in Washington D.C., and are very involved with copyright legislation and enforcement here in the U.S. and abroad.

Faster resolution possibilities for a limited number of companies

We are willing to entertain the possibility of a quick (prior to the industry-wide ADR meetings we have requested) settlement and full release with any company who shows an interest, acts in good faith, and responds to us immediately regarding these serious claims. If you are sincerely interested in pursuing such a settlement and release arrangement quickly, please contact me directly this week, as we do not have very much available time or resources that can be distracted from our primary missions under this kind of pressure.

This is a very URGENT situation, so please respond to us promptly and professionally. Time is of the essence in the resolution of this industry wide matter.

Thank you.

George Riddick
Chairman/CEO
Imageline, Inc.
P.O. Box 6275
Ashland, Virginia 23005

804-525-6941 Voice
804-525-6943 Fax

griddick@imageline2.com


Form Letter for Letter Recipients Who Won't Respond

This is the standard form letter for people who do not cooperate with Mr. Riddick. He uses this email more than once directed to different parties. For an allegedly professional company, notice how personal Mr. Riddick gets in his threats against the alleged infringer. Notice the vocabulary and choice of words he chooses. Mr. Riddick stupidly tries to ask the alleged infringer for their attorney's name. Why would anyone want to cooperate with that?

From: George Riddick [mailto:griddick@imageline2.com]
Sent: XXXXday, XXXXuary XX, 2009 XX:XX PM
To: XXXXXXXX@XXXXXXXX.com
Cc: 'Support Team'; XXXXXXXXX; 'Gary Gray'; gpaine3@yahoo.com
Subject: FW: URGENT - Copyright Infringement Notification - Cease and Desist
PERSONAL AND CONFIDENTIAL - Willful Copyright Infringement attributed to Northern Lights Embroidery at www.XXXX.com and www.XXXX.com

FOR THE PURPOSE OF SETTLEMENT DISCUSSIONS ONLY - SUBJECT TO F.R.E. 408

Dear XXXXXXXX:

We are very disappointed that you have chosen litigation for you, your family, your business partners, your distributors (i.e. XXXXXXXXX), and your end user customers. The amount of money spent bringing all of these people and companies to court is going to be enormous. But since our designs are all registered with the U.S. Copyright Office, you will end up paying every dime of these legal expenses on all sides, in addition to all infringement and DMCA (Section 1202) penalties as well. These penalties could easily exceed $35,000 per design infringed. What a shame!

As you know, we have shown you documented evidence, including side-by-side comparisons of the designs you infringed to our original design files as registered with the U.S. Copyright Office and deposited with Library of Congress in 1996 and 1997. There is absolutely no question of liability here, XXXXXXX.

We do understand that you have claimed that one of the embroidery designs (presumably the XXXXXXXX design) came to you by way of a published clip art book from one of Imageline’s competitors. We are willing to give you the benefit of the doubt on that one images without further review if we can get this dispute resolved today. There should be no question at all regarding to other two infringed Imageline illustrations and designs we sent to you for review.

Why did you cut off your discussions with Mrs. XXXXXX, XXXXXXXX? She was sincerely trying to help you. Have you even bothered to contact an experienced IP attorney? You may not care about yourself, but how about all of these other people you are dragging into this mess and setting up for additional infringement claims and liabilities, as well?

We offered you a chance to settle this dispute for pennies on the dollar and you have not even had the professional courtesy to respond to the majority of e-mail messages we have sent your way or to our deadlines. Your refusal to respond to XXXXXXX, who went to bat for you and your organization right out of the chute, is despicable in our opinion. Mrs. XXXXXXX did nothing but try to help you out of this mess out of the goodness of her own heart, and what we believe to be a sincere desire to work in an industry free of digital piracy.

We discovered these infringements, XXXXXXXX, not XXXXXX or anyone else.

We have tried hard to work with you and to be fair. We even extended your deadline from last Friday until the end of business today to off-set any delays caused by technical problems on this end late last week.

Please provide us the name, address (both physical and e-mail), and other contact information for your attorney today. We will be placing your case on the top of the case files we turn over to our new contingency attorneys in LA later this week.

For your information, we are also copying the owners of XXXXXXXX, Mrs. XXXXXX, and our representatives in California on this e-mail. We doubt you will respond (you have demonstrated a curious pattern in this regard recently ... why we simply do not know), but we do expect some of these others who you have impacted to become even more involved going forward.

Needless to say, you have angered Imageline (and me, personally) with your lack of professionalism and common courtesy in the handling of this extremely serious matter. We were counting on you as an ally, and are impressed with your experience in the XXXXXX arena. We need to work together to eliminate the damages caused by the unlawful distribution of embroidery designs, not stick our heads in the sand and wish it would all simply go away. If only it were that easy!

Do the right thing for those who trusted you, including your distribution partners and your end user customers, XXXXXXXXX. Do not bet that Imageline will not follow through on this to the bitter end. Do yourself a favor. Get your lawyer to check out our 15-year track record in this regard.

We protect talented artists from having their hard-earned property stolen out from under them in the new digital world in which we all now live.

If you have a change of heart, please contact me directly via e-mail this afternoon. Otherwise, we will see you in court.

George P. Riddick, III
Chairman/CEO
Imageline, Inc.
P.O. Box 6275
Ashland, Virginia 23005

804-525-6941 - voice
804-525-6943 - fax

Notice the sense of urgency in that last sentence by Mr. Riddick, "...please contact me directly via e-mail this afternoon. Otherwise, we will see you in court."


George Riddick Attempts to Silence Letter Recipient From Speaking Out

When someone tries to extort someone into silence especially when a case has NOT been settled, it is very disturbing. Mr. Riddick attempts to prevent the letter recipient from speaking out on this case, about him, and ImageLine. Mr. Riddick, the cat is out of the bag. His unprofessional and unseemly communication is out for everyone to read for themselves. He has done more damage to himself than anyone could have done.

From: George Riddick [mailto:griddick@imageline2.com]
Sent: XXXXday, XXXXuary XX, 2009 XX:XX PM
To: XXXXXXX@XXXXXXXXX.com
Cc: gpaine3@yahoo.com
Subject: Immediate action required to avoid additional damages to Imageline and your innocent end users.

Dear XXXXXXX and XXXXXXX,

Through further research, we have determined that your digital piracy was, indeed, willful, and that you are a dishonest and unethical person, in spite of putting on pretences to claim otherwise. We do not know how to effectively communicate with dishonest and unethical people, and we, therefore, are rarely able to settle disputes with such people or organizations short of filing lawsuits. We work within the guidelines established in our Judicial System and the various agencies within the Department of Justice to bring about civil and/or criminal charges as appropriate.

Please try to control yourself before you get into even more trouble than you are already in. Any disparaging or libelous remarks attributed to you regarding me, personally, Imageline, or any of the ethical providers of embroidery goods and services in this market, will be treated firmly and to full extent of the law. You have my personal guarantee of that.

What are doing, XXXXXXX? Trying to make yourself out to be the victim here when you are the one who stole the embroidery designs in the first place? Disgusting!

Important further notice

Since you are now under official notice that this case is going to litigation, please do not destroy ANY evidence in your possession that relates to the Imageline infringing activities brought to your attention some time back, and any and all discussions or written communications with your distributor, and co-infringer, XXXXXXXXXXX, any other embroidery design supplier who has a working relationships with XXXXXXXXXX, and any other point of unlawful distribution that you have so far chosen to hide from us, but will undoubtedly come out through discovery.

As of 9:00 a.m. this morning (EST) any and all settlement proposals to you, personally, and to XXXXXXXXX, are hereby withdrawn.

Please save yourself a lot of time and expense (and further embarrassment) and identify your attorney for us immediately. We will need his/her complete mailing and e-mail addresses, telephone and facsimile numbers, firm associations, and any other relevant information for he/she to act on your behalf in this matter.

Your failure to provide us this is information in a timely manner will be yet one more indication of your ongoing attempts to continue with this unlawful activity and place even more of your innocent end user customers in harm’s way. Despicable behavior, in my view … and in the view of everyone who seeks a clean and honest embroidery design market, in which to compete ethically and above board with people who choose not to steal from others for their own fame and fortune.

Time is of the essence in the resolution of this extremely serious matter.

Please provide Imageline with the above requested information before 5:30 p.m. (EST) today.

George P. Riddick, III
Chairman/CEO
Imageline, Inc.


Settlement & Release Agreement Form Letter

I have received multiple copies of this email from different parties. It appears to be a standard form Mr. Riddick uses for Settlement & Releases.

From: George Riddick [mailto:griddick@imageline2.com]
Sent: XXXXday, XXXXXuary XX, 2009 XX:XX PM
To: XXXXXXX@XXXXXXXXX.com
Cc: gpaine3@yahoo.com
Subject: URGENT - You are now personally at risk - your immediate response is required

CONFIDENTIAL – FOR THE PURPOSE OF SETTLEMENT DISCUSSIONS ONLY PURSUENT TO F.R.E. 408

Settlement and release agreement primary terms and conditions – XXXXXXXXXX

  1. Must close immediately in order for current proposed terms and conditions to stand. Agreement dated XXXXuary XX, 2009, which is the date that “Newly Found Images” would be released without further compensation. New images discovered with each detailed review. Archive reviews scheduled for this coming weekend.
  2. Rough draft ‘settlement and release agreement’ ready for immediate review by officers, directors, and outside counsel.
  3. Total compensation to Imageline consistent with low end of statutory scales and all other 4Q08 and 1Q09 settlements. $7,500.00 per infringed design.
  4. Less than one-half of the $15,000.00 to $150,000.00 per independent design, and attorneys fees, claims to b made in court
  5. All Imageline designs registered with U.S. Copyright Office. Deposit copy files available for verification and review.
  6. All disputes resolved via amicable settlement and release agreement or through a federal lawsuit. No exceptions.
  7. One third cash up front, two thirds worked out over time and/or through the exchange of products and/or services.
  8. Side by side image/design comparisons and copyright registration information available to all qualified executives, owners, and their attorneys
  9. Highly confidential. Terms not offered to any companies still infringing or whose infringement activities are deemed to be flagrant
  10. Settlement offers withdrawn automatically if client and or client attorney do not communicate regularly and as promised.
  11. Offer to help establish firm anti-piracy policies for those companies wishing to participate in Copyrights: Code (Red) consumer awareness campaign
  12. Release of all officers, directors, employees, owners, and other named associates and/or sponsors
  13. Release of named distribution partners, retailers, and other reseller
  14. Release of all end user customers not distributing the infringing digital designs into the marketplace
  15. Amnesty program for infringements discovered after the date of settlement. Select participants only.
  16. Participation in Public Relations campaign highlighting those supporting copyright protection (optional) and those who do not (mandatory).
  17. All specific settlement amounts, terms, and conditions strictly confidential
  18. Imageline option for arbitration in Virginia for any violations of the settlement agreement or newly discovered infringements

PERSONAL AND CONFIDENTIAL


Form Letter for Lack of Response

In this email to the letter recipient, Mr. Riddick appears to relent since the last few emails has resulted in no responses. He is practically begging for a response of any kind. I have seen this email more than once as different parties sent their versions of the letter to me. Only the names were changed. The rest of the wording is nearly identical.

From: George Riddick [mailto:griddick@imageline2.com]
Sent: XXXXday, XXXXuary XX, 2009 XX:XX PM
To: XXXXXXX@XXXXXXXX.com
Cc: gpaine3@yahoo.com
Subject: FW: URGENT - Your members must stop infringing and must be told the truth.

Dear XXXXXXXX,

I am really not sure why you have not responded to any of our attempts here at Imageline to reach out to you and try to resolve our differences in a fair and just manner under these extremely difficult circumstances. Surely, it could not be your desire to force Imageline into filing a lawsuit against you and your company. I can assure you that is NOT our preference, but we cannot simply be ignored.

Our only objective here, XXXXXXX, is help rid your embroidery industry of digital piracy, which, if left unbridled, will negatively impact everyone who creates top quality embroidery designs for a living. We do this with consistent and fair settlements (which release you and ALL of your business partners and customers) with those we think perhaps made an honest mistake. We do not deal this way with those we think pirated the designs willfully.

XXXXXXXX, if some misappropriated your proprietary designs or took your private family photo album from you and posted it on the Internet, would you simply walk away and ignore them. I do not think so.

Just in case you have received any false information or bad advice, I decided to send you the e-mail below that we sent to XXXXXXXXX this evening. Mr. XXXXXX has previously refused to cooperate with Imageline due to some legal provision of our copyright laws he apparently made up, or certainly misinterpreted.

Please let me know directly tomorrow morning if you would like to consider being left out of this pending lawsuit.

Thank you.

George Riddick
Imageline, Inc.


Standard Settlement Letter

This is one standard settlement letter Mr. Riddick sends out. More than once person has forwarded variations of this letter. Please read the attack language he uses.

George Riddick wrote:
 
*PERSONAL AND CONFIDENTIAL - FOR THE PURPOSE OF SETTLEMENT DISCUSSIONS ONLY UNDER F.R.E. 408*
 
XXXXXXXXXX and XXXX and XXXXXX, personally,
 
We have been working diligently down here for well over three months now and have not even come close to finishing "Phase One" of our standard three-phase audit into the infringement activities and related business practices within the embroidery design industry,
 
We have answered all your questions, and provided many more answers, as well, in the detailed documentation report and case studies we are now preparing for the courts, generally civil, but criminal in several select cases, as well.
 
We mean business. We hate digital pirates. We hate hypocrites even more. We never walk away from a case until a resolution in agreed to, or forced through curt order, in writing. We never will.
 
Every infringement incident we discover, regardless of the unique set of circumstances or the historical reputation of the infringers, will be resolved by negotiated written 'settlement and release agreement or through expensive and time consuming litigation. We have agreed to binding arbitration here in Virginia in two cases, but those circumstances were both quite unusual.
 
Your company, as well as its officers and directors, will be included in the federal lawsuits that we file. Only then can we really discover who did what to whom. We've only seen the end results a small fraction of the ultimate marketplace damages. All we know is that Imageline suffered all of these damages in the marketplace, not Stitchery Mall, or its principles.
 
This thorough research and investigative process takes a substantial amount of time and expense on our side of the equation. What did you do this past weekend to cease further infringing activities?
 
We will recover all of these costs, all legal fees, either actual or statutory damages penalties (our choice, not yours), and DMCA Section 1202 penalties (which are substantial in this case), as well, if you force us into litigation. We will not lose a dime.
 
As part of our ongoing evaluation of intent, we also watch closely to see what those who are infringing have done, and are doing "as we speak" to stop further damage from occurring with and by their end user customers (long after notice). We cannot see that you are doing anything at all in this regard. If that is not serious willful infringement, then what is, XXXXXXXX? In our view, each of these customers should have substantial claims against you as well.
 
We have settled dozens of cases in your industry and related industries over the past few months, so we at least feel we are making some progress to rid the industry of digital piracy, and digital pirates. All of these settlements were/are based on our fair-minded and well-balanced standard settlement and release agreement (a draft of which can be sent your way under certain conditions).
 
All settlements are based on the base settlement rate value of $7,500.00 per infringed design, or far, far, less than we will likely be awarded in court. For those people/companies who we feel are not likely to knowingly continue infringing activities going forward, we have even agreed to reasonable time payments, the exchange of products and services, including actual proprietary embroidery designs themselves in some instances, as well as digitizing and production services Imageline will need as we enter this dynamic new industry in a very big way this spring/summer. These trades are treated as 'off-sets' to reduce the financial burden of this kind of settlement on a small businesses and/or individuals in most cases.
 
Not many people, once they are convinced of our exclusive ownership rights to the well-documented infringing designs we show them, or are fully and truthfully made aware of the serious consequences they will likely face regarding their unlawful actions, choose to give all of their money away to high priced copyright defense lawyers, instead. Some fools do, but usually only for very short periods of time. Looking at a steady stream of $5-15K per month legal bills can get very old very quickly. Why do you think she shifted exclusively to contingency law firms some time back?
 
The choice is yours, XXXXXXXX. Please let me know today what you decide to do.
 
Thank you.
 
George Riddick
Imageline, Inc.


More Letters from George Riddick

Because of the overwhelming space Mr. Riddick's letters take, I have chosen to only reprint those letters that are different, not those that have already been shown above.

Mr. XXXXXXXXXXXX and Mrs. XXXXXXXXXX, c/o XXXXXXXXXX

We retain some of the top Intellectual Property attorneys in the entire country, Mr. XXXXXXXX. We have done so for the past 15 years. We have written many of the books, articles, and drafts of our current copyright laws. We are working on drafts of new laws at the request of copyright officials in Washington as we speak.

You are offending me, personally, as well as everyone else now associated with Imageline, with your stubbornness, your arrogance, and your insistence on practicing law without a license on behalf of your company and your members. Very dangerous behavior, Mr. XXXXXXXX. Not just stupid, but dangerous.

This is precisely why we made the statutory damage penalties for willful infringement behavior up to $150,000.00 per independent infringement and per every independent organization and individual found to be willfully infringing.

You are costing your members tens, if not hundreds, of thousands of dollars by suggesting that they continue infringing long after receiving official notices of copyright infringement directly from Imageline. We would not send anything through you. You do not return e-mails, you do not answer your phones, and you do not even know where your members are located, let alone how to get in touch with them, in spite of your fraudulent claims to the contrary posted on your web site.

In short, Mr. XXXXXXXX, you have handled this entire situation unlawfully and without any legal authority, or knowledge, whatsoever.

For your own protection, and for the protection of your members still infringing, I strongly suggest that you hire a competent IP attorney and have them contact Imageline TODAY. You and XXXXX NEED to know the serious consequences of your actions, both civil and criminal, and you need to know them immediately.

I am a consumer advocate, Mr. XXXXXXXX. Always have been and always will be. We do not like the way you appear to care less about creating additional infringement liabilities for your members and your end user customers. I suggest you also strongly consider whether or not this is a business activity that you are in the least bit qualified to pursue.

Someone even told us recently that you are, or were, a preacher, or a man of God, Mr. XXXXXXXX, which we find extremely difficult to believe.

We are going to pursue the maximum remedies under law against you, personally, against XXXXXX, against your company, and against those member companies you say have refused to try and resolve these issues with Imageline amicably, and, in some cases, are still infringing, apparently due to the "legal" advice you have given them.

For the sake of clarification, we have identified nine (9) member companies on your network who were suspected of infringing Imageline property. All of these companies, other than those listed below, have handled this extremely difficult situation professionally, and with class, and have done what was necessary to protect their end user customers.

The companies who have not are:

* XXXXXXXXXXXX
* XXXXXXXXXXXX
* XXXXXXXXXXXX
* XXXXXXXXXXXX

We prefer not to deal with you any longer, Mr. XXXXXXXX. You simply do not tell the truth. In fact, I find myself feeling sorry for some of the people listed above, and their end user customers, who are also still liable, will eventually be identified at trial, and who may have listened to you trying to preach to them about complex copyrights laws you simply do not understand.

XXXXXXXXXX is a reseller, makes a profit from the display, sales, and distribution of stolen property, and does NOT qualify for any of the "safe harbor" or required "notification" provisions of the 1998 DMCA, Mr. XXXXXXXXX. Didn't I explain this to you weeks ago? How about the lawyer you claimed you had retained?

Please ask your members listed above to let us know immediately and directly if for any reason they have not seen the numerous notices of copyright infringement and 'cease and desist' demand letters we have sent their way.
Notices which included the detailed image and design information you claim has never been given to anyone, by the way. Save that nonsense for the judge and jury, Mr. XXXXXXX.

You are giving me a headache. I hate hypocrites, and people who pretend to know things they really do not know at all.

Please have the professional courtesy to acknowledge the receipt of this e-mail communications right away.

Thank you

George Riddick
Chairman/CEO
Imageline, Inc.


George Riddick Attacks "Grandmother with Medical Problems"

From: XXXXXXX@XXXXX.com
Sent: XXXday, XXXXuary 30, 2009 3:03 PM
To: George Riddick
Subject: RE: identified infringements

George, I want you to know I am an unemployed grandmother with medical problems. I created my embroidery designs as a hobby. It was not a business by any standard.  I simply hoped to be able to cover some of my sewing expenses and make pretty designs for others with like interests to enjoy. I am willing to give you ALL of the funds received from your claimed image= $255.00. This is an honest and sincere attempt to make things right.

Your proposed settlement is a "win win" for you alone, not for those of us who used to have a nice hobby. I could never, under any circumstances, work for or assist you and I don't have the money to move to China.

XXXXXXXXX


 I am sorry you feel that way, XXXXXX. I, for one, totally disagree with you.
Your "hobby" has hurt more people than it has helped in my humble opinion.
First of all it was illegal, at least where Imageline designs are concerned.

XXXXXXXX, you used stolen artwork that artists here in Virginia spent many, many years creating from scratch and marketing. You should have designed your own artwork or at least paid for what you used at that time. That is exactly what you should have done.

We did reach an agreement with someone in a similar position as you recently and agreed to trade embroidery designs for the damages she has created to Imageline because she preferred not to provide services for us as well.

The choice is yours, I am a grandfather, and I have enjoyed over 350 talented artists over the years. I wish you could have seen some of their faces when we had to lay them off because of the exact same kind of digital piracy we have found on your web site and on other web sites in the embroidery industry.

If I remember correctly, you are able to get out of this difficult situation with an up front payment of either $750 or $1,500 depending on the number of images you have infringed.

From there, we can take design trades and let you go your own way.
Otherwise we have rules to follow here that are fair to everyone, and we will turn this case over to the law firms for implementation along with others who choose not to comply.

Please think about this choice carefully and let me know your decision today.
Thank you.

George Riddick
Imageline, Inc.


George Riddick Says "Quit Whining and Complaining"

From: XXXXXXXXXXXXXX
Sent: XXXXXday, XXXruary 03, 2009 7:20 PM
To: 'George Riddick'
Subject: RE: XXXXXXXXX - FW: identified infringements - unresolved

George, as I told you before when you suggested that I had infringed, I was
shocked and immediately removed the designs, closed my web site and notified those who may have downloaded the designs. Although you say you are being fair, the settlement for an unintentional possible infringement was
extremely harsh. I told you my web site is just a hobby. I offered to send
you the total amount of funds generated. As to not responding, I did not
know what to say to your threatening emails. I take offense to you
characterizing me as not having any decency. If you must, go ahead and put
my $255 of innocent infringement at the top of your list. I think you will
find that I am a quite decent person, just not able to accept your totally
outrageous settlement. I cannot pay an attorney for myself, let alone yours.

XXXXXXXXXX


XXXXXXXX, if I were you I would quit whining and complaining and pick up that phone and call Teri Sullivan right away. Teri is the only one on this planet (that I know of anyway) who has offered her expertise and kindness to try and help you, and, from what I can tell, you have treated her irresponsibly as well.

Teri was able to help one of her friends make a settlement deal today where most of the payment was made in embroidery designs themselves. We are very responsible and reasonable people and we always try to work something out within someone's means (even though our attorneys advise us otherwise) just to be kind.

We didn't write the laws of this land, XXXXXXX. Complain to your elected Congressman/woman, not us.

The kind of infringing activity you engaged in carries a penalty in this country of between $30,000 and $150,000.00 per design. What you collected from the stolen property is totally irrelevant. You went over the line in what they refer to as "willfulness". Ignorance of the law is never considered a valid excuse in this country.

If the penalty for stealing a laser printer from OfficeMax was the return of a used laser printer, what kind of civilization would we live in? I am sick of listening to you moan and groan about this and try to create an "oh poor me" umbrella around you. Tell that to one of our talented artists who had to be laid off just before Christmas due to the unbridled infringement of our property.

Once again, either ask Teri for her help (an there is absolutely no guarantee that she would even help you now) or face the consequences. Our lawyers will not care about any of your excuses. They are trained to take people's houses and cars if that is what's necessary to uphold the law and collect on the judgments we will get in a case that is legally uncontested.

Do the right thing, XXXXX. Quit whining and admit that what you did was against the law. Be responsible.

George Riddick
Imageline, Inc.


George Riddick Extends Deadline Due to Technical Problems

Dear XXXXXX,

Due to some technical difficulties with the documentation and delivery of evidence from Imageline at the end of last week, we are extending the deadline for you to respond to our most recent ‘settlement and release’
proposal until 5:30 p.m. (EST) on Tuesday, February 3. 2009.

Unfortunately, we have been forced to protect and defend our copyrights due to Internet-based piracy for the past fifteen (15) years almost without stop, and at enormous cost to Imageline, as a company, and to many of the over 350 artists, designers, digitizers, programmers, and illustrators we have employed and contracted with along the way.

The Imageline Compliance Committee accepted the recommendation of some very influential, kind, and experienced people from within the embroidery industry and tried our best to structure settlement arrangements that were both workable and fair under these difficult circumstances. Some of you recognized our sincere attempts and have resolved our disputes. We are appreciative of these efforts.

Never before have we set settlement standards such as these with the amount of cash that is due at settlement at the absolute minimum, under any interpretation of fairness, leniency in granting the infringer all arguments in the analysis of reasonable doubt and intentions, and sincerity in our desire to get these disputes behind us and move on in a more productive, and sometimes even cooperative, fashion.

If you choose not to settle, please let us know as soon before the above-stated deadline as possible. From there, we will turn over this case to our outside legal team, and begin the process of filing suit. In this kind of lawsuit, we will seek damages of between $15,000.00 and $150,000.00 per infringed embroidery design, all legal cost and expenses (which we are eligible for here due to the fact that all of the infringed designs are registered with the U.S. Copyright Office and have been for quite some time before the actual infringing activities first occurred, and all copyright identification and misrepresentation penalties available to us under Section 12 (see Sections 1201 and 1202) of the Digital Millennium Copyright Act (DCMA) which range from $2,500.00 to $25,000.00 in fines per design, over and above any copyright infringement claims available to Imageline under law.

We will also instruct our lawyers to look into filing personal lawsuits against you, others who own and/or operate your embroidery design business, as well as Stitchery Mall and other distributors we can identify. Your customers will also face liability as we identify them through discovery, as well.

Just to insure that any technical issues from last week are resolved, I have attached examples of the infringing artwork and designs found by our investigators on your web site (or the web sites of your authorized distribution partners, who we will also file suit against for these infringements), along with all copyright registration information you will need to provide to your lawyer once we file suit.

Finally, if you choose not to cooperate with Imageline and settle these claims, please provide us with the complete name, address (physical and e-mail), and other contact information for your attorney as quickly as possible. This will help us move the legal requirements and procedures along more rapidly as well.

This is not the resolution we here at Imageline were hoping for, even though we almost always make 5-20 times more money by letting the legal system run its course.

Good luck in your future and please make sure no other hard-working artists and designers are harmed by copyright violations based on your efforts.

Thank you.

George Riddick

Imageline, Inc.

P.S. If you have agreed to settle, and therefore release all of your business partners and end user customers from further copyright infringement claims as well, I applaud the wisdom of that decision and appreciate those efforts. In these cases, we will work with you and your attorneys (if desired) to research and bring claims on your behalf against anyone who may have defrauded you concerning Imageline’s exclusive property rights, and in any other way we can to help you recover from this unfortunate incident and move forward.


George Riddick Introduction Form Letter

Another friendly introduction letter by Mr. Riddick.


From: "George Riddick" <griddick@imageline2.com>
To: <XXXXXXXX@XXXXXXXXXX.com>
Subject: Copyright issues - URGENT
Date: Sat, 21 XXX 2009 XX:25:48 -0500

PERSONAL AND CONFIDENTIAL

Dear XXXXXXXX,

According to public records, the web site www.XXXXXX.com is owned and operated by you.

I have some very bad news to share with you this afternoon.

My name is George Riddick. I am the Chairman/CEO of Imageline, Inc. in Ashland, Virginia.  Imageline owns one of the largest archives of vector-based digital illustrations, designs, and animations in the world, and has led the electronic clip art industry here in the Untied States for over 20 years. We also lead our industry in the enforcement of the copyright laws here in the U.S. and abroad.

On weekends, I often review the lists of official notices of copyright infringement that are scheduled to go out the following week. If a company peeks my interest, I will take a look around its web site(s) before I authorize the official notices to be delivered.

Your company, primarily due to its devotion to the small business and creative markets, got my attention. I have supported small business and creative, family-run enterprises, ever since I left IBM back in 1980.

So, here is the bad news:

Your company and its web sites, XXXXXXXX, are infringing a significant number of designs owned exclusively by Imageline. All of these designs are registered with the U.S. Copyright Office and have been so since 1996 and 1997. We have never authorized anyone to have the rights to convert our proprietary designs into embroidery designs for re-sale. Consequently, your companies are engaging in widespread infringement of our properties, and are liable for sizable penalties and other remedies under our laws. I will give you an example.

When we turn these cases over to our outside attorneys, we file copyright infringement claims of anywhere from $15,000.00 to $150,000.00 per design, depending on the degree of willfulness and the extent of the distribution. We are  also able to recover all legal fees since the infringements occurred after our designs were registered. In addition, we have independent claims of up to $25,000.00 per design based on DMCA Section 1202 violations.

We do not prefer litigation, however. We try to resolve all disputes with a standard settlement and release arrangement we have fine-tuned throughout the years, These terms, too, however, have remained consistent. Consistency is the only way to effectively deal with the problem of digital piracy these days. We know. We have worked with Washington for over a decade now and have contributed significantly to most of the copyright laws that are currently in force or pending.

Our settlement rate is consistent with what we charge for an annual license for unlimited distribution in other markets - $7,500.00 per design. We have, on occasion, agreed to the trade-off of goods and/or services against a significant percentage of these fees, however, with design and digitizing services, or even design acquisitions, when appropriate, leading the way. We only offer this degree of flexibility to those we feel made an honest mistake (which does not impact liability under our copyright laws), and are not likely to continue their infringing activities once these issues with Imageline are put to rest. I have made the hunch that your organization falls into that classification.

If you would like to consider an amicable settlement of these claims before the lawyers get involved, please contact me directly as soon as possible. I will then send you a complete list of all of the infringing designs we have identified on your web sites, and in your products, thus far, with the appropriate reference to their copyright registrations.

I hate to deliver this bad news to you over the weekend, but time is of the essence as we try to eliminate digital piracy from the embroidery industry the best that we can. We have significant experience at doing just that, but I must admit, your industry presents far more challenges than most.

I look forward to hearing from you within the next few days.

George P. Riddick, III
Chairman/CEO
Imageline, Inc.


Imageline Accepts Payment Plans During These "Rough Times"

Mr. Riddick is so courteous to extend a payment plan (in light of these rough economic times) for his gracious $7,500 settlement. Anyone interested?


From: "George Riddick" <griddick@imageline2.com>
To: <XXXXXXXX@XXXXXXXXX.com>
Subject: Infringement identified and documented
Date: Fri, 27 Feb 2009 11:53:56 -0500

Hello XXXXXX,

This is the only Imageline image/design that we have found to be infringing on your website. Please remove the design immediately. We charge $7,500.00 for an annual unlimited and unrestricted license to display and distribute one of our proprietary designs. How many years have you had this design available for download from your web site, XXXXXX?

____________________________________________________________

231.  Registered with the U.S. Copyright Office in the Imageline Master Gallery
(VA0000765894) on May 5, 1996.
____________________________________________________________

For small businesses with cash flow concerns during these rough times, we will consider a payment plan as long as we are convinced that no more infringements are going to take place on the identified web site(s).

Please let me hear back from you today.

Thank you.

George

George Riddick
Imageline


Share Your Information and Responses On Our Online Discussion Forum!

Send email to:

Teri S. Negotiates on Behalf of George Riddick/Imageline

I received information and emails earlier about a woman named Teri S. but did not post it out of respect and at the request from my first informant. I also did not have enough information to responsibly report what her actual role was in the Riddick/ImageLine controversy. Teri has asked me to not reveal her full name but I can only oblige her partially. I have partially revealed Teri's name because I want any letter recipient to know that there is a possibility they may be contacted behind the scenes by this Intermediary for Mr. Riddick.

Another informant has stepped out with a series of revealing emails that seem to indicate that Teri S. is a prior letter recipient who ultimately "settled" with Mr. Riddick and became an intermediary for him. What is apparent is that Mr. Riddick approved of Teri's efforts to mediate settlements for other letter recipients. In one email, Teri admits to this and in another email Mr. Riddick expresses his disbelief and displeasure that one of his letter recipients chose to ignore her emails and disengage from Teri.

The obvious question is, why would someone who was a letter recipient (who ultimately "settled") become an advocate and intermediary for Mr. Riddick? All of this reads like a soap-opera plot twist. It seems quite strange to me. I have some ideas of why (that goes beyond her explanation) but it is only speculation and cannot be substantiated. It would be irresponsible for me to list them here because the possibility exists that someone would then repeat that speculation and state it as fact.

Teri had contacted me regarding her name being displayed in our discussion forum. Allegations were made about her that could not be substantiated and I deleted all messages relating to that discussion. I also deleted messages that had no direct relevance to the Riddick/ImageLine controversy.

Teri contacted me stating her position over why she tried to assist in settlement efforts for Mr. Riddick. She claims it was her concern over others going through the same thing she did and she wanted to be helpful. She also believed that Mr. Riddick could carry out his threats. I find the credibility of her statement low due to the urgent tone within her emails to letter recipients in addition to what she states in her emails. It is strikingly similar to Mr. Riddick's sense of urgency to get people to settle.

What I found disturbing about Teri's emails to me is how uninformed she appears to be. In her emails to me, she continues to defend her position and beliefs. She also continues to believe that what she did was "right" and that Mr. Riddick is "unstoppable." Clearly, I disagree with that. She also claims to be a letter victim (which appears to be true) however, these emails do not reveal her to be a passive supporter of the letter recipients. It does appear that she was an active negotiator (despite her statements otherwise) on Mr. Riddick's behalf. Not only that, she makes the case for him in the emails. Needless to say, I find this unsettling.

I mostly believe Teri when she says she only settled out of fear and she believed she had no other recourse. However, my personal email exchange with her tells me I am not getting the full story. Whether I get the full story or not is unimportant at this point.

What is important is that any letter recipient should not be discussing their issue with anyone who is an uninformed and unqualified third-party. If Teri (or anyone else) makes contact with you without your solicitation to negotiate a settlement with Mr. Riddick and/or ImageLine, I highly recommend you disregard those communications. Let Mr. Riddick do his own work. Go find your own independent counsel whether it is your own attorney, advisor, or Oscar Michelen.


George Riddick Encourages Letter Recipient to Work with Teri S.

Thank you, XXXXXX.

That is step one in this process.

Now we must turn the discussion to compensation to Imageline for the fact that our proprietary copyright-registered illustrations and designs have been infringed, and the release of XXXXXXXXX, and other distributors and/or retailers you have used, as well as all of your end user customers.

I have authorized another young lady who works with XXXXXXXX to try and work with the other members she knows to explain carefully what Imageline is trying to do here, and what options an infringer has when they are discovered infringing.

I think you will find us to be extremely fair-minded in the way in which we have organized the options for the people Teri SXXXX (XXXXXXXXX) says she knows and trusts.

XXXXXX, we resolve every single incident of infringement with either a lawsuit or a negotiated 'settlement and release agreement', whereby all customers who are now using one of our proprietary designs they purchased or otherwise downloaded from you and/or your distributors are released and you do not have to worry about additional related infringement claims down the road.

I am sending a slew of documents and other information down to Teri on a regular basis (you folks are fortunate to have her as a friend and business associate in my opinion), so I strongly encourage you to continue talking to Teri if you are not already doing so.

Unfortunately, we have very little time here to debate this issue. We have made a commitment to turn over quite a few embroidery industry cases to our contingency law firm in California starting next week. I sure hope you do not decide to go that route. The attorneys fees, alone, force most people to throw in the towel after awhile and they are still subject o paying the damages.

Fair negotiated settlements always work out better, XXXXXX. I know. We have been involved in hundreds of them over the years.

If you do decide to challenge Imageline in court, please provide me with the correct contact information for your attorney either later this evening or first thing tomorrow morning, if at all possible. Once that decision is made, obviously things will become more confidential and Mrs. SXXXXXX will no longer be in the communications loop.

I surely hope you make the right decision and I am sorry that this happened to you and your business.

George Riddick

George P. Riddick, III
Chairman/CEO
Imageline, Inc.


Teri Initiates Contact to Letter Recipient

Teri appears to initiate contact without any solicitation from letter recipient. Along with the introduction, Teri states that Mr. Riddick has allowed her to be a "mediator".

Subject: Email
Date: Thu, XX XXX 2009 XX:59:49 -0600 (CST)
From: teri@XXXXXXX.com
To: XXXXXXXXX@gmail.com

Hello XXXXXXX,

It's extremely important that I get in touch with you asap, but my emails to you via the address on your site are bouncing back.  Please email me at teri@XXXXXXX.com as soon as you can.

Teri SXXXXXX
www.XXXXXXXX.com
Fellow Vendor at XXXXXXXXXXX


Subject: Infringement Claim
Date: Thu, XX XXX 2009 XX:45:56 -0500
From: Teri SXXXXXX <teri@XXXXXXXXX.com>
Reply-To: teri@XXXXXXX.com
Organization: XXXXXXXXXXXXXXXXX
To: XXXXXXXXXXXXXXXXX

Hi XXXXXXX,
This is a very difficult email for me to write and it gives me no pleasure in doing this.  I also hope we can keep this confidential.  I recently settled a copyright infringement claim with a clip art company out of Virginia called Imageline.  I am also aware that they have found one or more designs on your site and/or at the Stitchery Mall that they claim violates their copyright.  If you haven't received a Cease and Desist letter, you will get one very soon, I'm sure. 

I spent a great deal of time working through this with the company CEO.  It consumed the better part of 3 weeks of my time.  I ended up, out of an abundance of caution, removing all designs from my site that I could not definitively say that I had express permission to digitize, even though only one design was actually found that violated their copyright.  I, like many of us, was always under the impression that "Royalty Free" meant I could digitize the clip art.  Well, that is not so.  This company distributed a lot of its clip art through large clip art collections, at least one of which I had purchased and thought was okay to use.  The clip art in question was registered with the copyright office many years ago and this company has successfully sued and won or settled about 150 cases similar to mine.  Needless to say, I didn't feel like I had a leg to stand on, and while the settlement amount was way higher than I felt justified or even more than I felt I could afford to pay, it has been well worth the peace of mind to know that this is behind me and that I didn't have to get an attorney or go to court over this.

Mr. Riddick, the company CEO, informed me that their company is currently researching the machine embroidery design market with the future intent of selling designs made from their clip art.  They are finding massive numbers of infringements and are suing and/or settling with each and every one, no matter how minor.  They are even taking on some of the largest and well known embroidery design companies.  It truly amazed me how aggressive they are about this.  Not leaving a stone unturned.  The upside of all of this is that in the end, their efforts will, I hope and believe, make a huge difference in the embroidery world.  Once the word gets out that someone in this industry is actually making headway eliminating copyright infringement against even the largest of companies, it can only benefit those of us who work so hard to produce a quality product at a reasonable price.  I truly believe that.  They have a very organized campaign underway to clean up copyright infringement regarding their clip art.  I have no doubt this campaign will continue and expand its focus to include piracy of embroidery designs, once this company gets into that market.

This brings me to the purpose of my email to you.  I managed to reach a settlement with this company that protects me from future claims on any past designs I may have missed on my site.  It also protects the XXXXXXXXX and my customers from those potential claims.  It was a long, draining, and very stressful process, not to mention the embarrassment I felt at having made this mistake.  When I found out how comprehensive Imageline's campaign is, I was a bit worried about my embroidery friends and did not want any of them to go through what I did.  I was able to convince Mr. Riddick that a lot of the digitizers that I know are good, decent, honest people who would not knowingly break copyright law.  He agreed to let me work with those that I can vouch for as somewhat of a mediator in this.  You are, of course, free to totally ignore my offer to help you, and try to work something out on your own, or hire an attorney to do that for you.  One thing that I can assure you will not happen is that this will not just go away on its own.  Imageline is determined to settle or bring each and every case to court.  They have a large group of cases that are going to their attorneys in early Feb. 2009.  Once these cases are turned over to the attorneys, they become "cookie cutter" cases and the attorneys will be asking for the maximum damages allowed under law.

Please don't take this the wrong way, XXXXX.  I just want to help those I care about.  I, like you, sell through the XXXXXXXXXXX, and I care very much about every vendor there, as this can potentially affect all of us at the mall in an adverse way.  I can help by working with you and Mr. Riddick on a settlement that will probably be hard to swallow, but will give you peace of mind.  Please let me know as soon as you can whether you want my help.  Or consult your attorney.  Either way, I hope this all works out well for you in the end.


Teri Admits That Mr. Riddick Wants Her to Be Involved in Settlements

Teri speaks with authority as to Mr. Riddick's intent and actions. For a passive supporter, she appears quite active and assertive here.

Subject: Re: Infringement Claim
Date:Fri, 30 Jan 2009 09:56:38 -0500
From: Teri SXXXXXX <teri@XXXXXXXXX.com>
Reply-To: teri@XXXXXXX.com
Organization: XXXXXXXXXXXXXXXXX
To: XXXXXXXXXXXXXXXXX

Hi XXXXX,

Mr. Riddick typically sends the image of the design in question when he sends the cease & desist, which you will likely get today.  Once you get that, unless you choose to counter file your own claim to it, then you would be best advised to remove the design from anywhere that it might be displayed/distributed as soon as possible and then reply to him with an email telling him you've done that.  He will then want me to work with you on a workable settlement.  I will tell you up front that just removing the design will not be enough.  They either sue or settle on each and every infringement they find.  They've been doing this for years and are like a well-oiled machine in that regard.  Also, time will be of the essence in this, as they are turning over as many cases as they can next week to the attorneys for litigation and you sure don't want to end up in that group, I don't think, especially for one design.


Settlement Agreement Form Letter by Teri to Letter Recipient

I have seen versions of this email sent by Teri to different parties. This is where I got confirmation that Teri was dealing with more than one recipient and I believed she was negotiating on behalf of Mr. Riddick/ImageLine. The entire center portion of the email was written by Mr. Riddick which was passed on by Teri. Teri clearly encourages the letter recipient to settle quickly.

Subject: Settlement Offer
Date: Fri, XX XXX 2009 XX:40:32 -0500
From: Teri SXXXXXX <teri@XXXXXXXXX.com>
Reply-To: teri@XXXXXXX.com
Organization: XXXXXXXXXXXXXXXXX
To: XXXXXXXXXXXXXXXXX

Hi XXXXXX,

Mr. Riddick has devised a settlement structure to be used for the people I am mediating with.  Please read below.  I haven't changed anything except names of other designers, as this is all confidential.

Like virtually everything else I do, once I get something into my mind I have a hard time getting it out of there until I try to implement our newly proposed plans. You have gotten my attention in trying to be creative and structure deals that the average designer or digitizer could live with and yet still play an important role as we work together to change the disturbing trends we now see impacting the entire embroidery industry, and eliminate as much digital piracy as we possibly can. This will benefit everyone in the long haul. Even those we have discovered as infringing in our current campaign.

How can anyone effectively compete against goods and services that are stolen? The answer is simple. They cannot.

I truly do prefer amicable solutions as opposed to litigation, but we are committed to resolve each and every case we discover in one way or the other, Eight years ago we tried to simply warn people and slap people on the wrists while we asked them politely to comply. That strategy only increased the piracy rates in every industry sector we tried it in. It does not work. There needs to be consequences for unlawful actions, even if the infringer had no idea what they were doing was wrong. They must learn the law of the land. I also much prefer to have ADRs (a term we use in the industry for Alternative Dispute Resolutions) structured in a cookie cutter fashion so that creativity (and customization) does not begin to result in a lack of productivity and progress, which is also often the case when we are trying to resolve complex matters.

I am known industry-wide for my creativity in structuring deals that work for both sides, however. No sense in stopping now. Even the lawyers probably do not care this time around, as the number of cases we have for them already is enormous, and growing exponentially each month.

Here is what I am thinking. We’ll use Lucy(fake name) as an example below. This scenario could be played out to any member of the XXXXXXXXXX or anyone else we decide for you to handle through this process. We will be concentrating on giving you the cases where we feel honest mistakes were actually made. Just like we feel about you, XXXXXX, xxx, xxx, and the others we have thus far discussed.

 Please note. These plans will be offered only to strong, ethical, members of the embroidery community. Those who made a bad choice or an uniformed choice somewhere along the way that caused them to have these current problems. Those who will not likely be engaged in copyright infringement activities again. These people must believe in the philosophy that “the customer comes first”, and that quality should come before all else. They must also believe that the protection of copyrighted work is essential in order for the industry to survive.

Scenario One: 1-3 Imageline designs discovered as infringing. Digital files posted and available for distribution

 $7,500 per independent infringement (this is les than ½ what we know have our attorneys demanding in the cases in legal custody already)
1/3 cash, 2/3 products and/or services
$750 cash up front
12-month payment plan to make up remaining cash component*
Services include digitizing, consulting, administrative, investigative, or educational
Products include embroidery designs at $200 per design. Chosen from existing collections or digitized from scratch from existing Imageline artwork libraries

 * payment plan payments can be exchanged for products and services with mutual consent. In no case should the payment plan be structured so that it would adversely impact infringers ability to earn a living and stay in the embroidery business if they choose to do so.

Scenario Two: 4-10 Imageline designs discovered as infringing. Digital files posted and available for distribution

$7,500 per independent infringement
1/5 cash, 4/5 products and/or services
$1,500 cash up front
12-month payment plan to make up the remaining cash component
Services include digitizing, consulting, administrative, investigative, or educational
Products include embroidery designs at $200 per design. Chosen from existing collections or digitized from scratch from existing Imageline artwork libraries

* payment plan payments can be exchanged for products and services with mutual consent. In no case should the payment plan be structured so that it would adversely impact infringers ability to earn a living and stay in the embroidery business if they choose to do so.
 
Scenario Three: 11 or greater Imageline designs discovered as infringing. Digital files posted and available for distribution.

$7,500 per independent infringement
1/5 cash, 4/5 products and/or services
$3,000 cash up front
12-month payment plan to make up the remaining cash component
Services include digitizing, consulting, administrative, investigative, or educational
Products include embroidery designs at $200 per design. Chosen from existing collections or digitized from scratch from existing Imageline artwork libraries

* payment plan payments can be exchanged for products and services with mutual consent. In no case should the payment plan be structured so that it would adversely impact infringers ability to earn a living and stay in the embroidery business if they choose to do so.

Specific case study example

So let’s apply one of the above scenarios to Lucy. I think she qualifies for consideration from what I have learned through my own research and what you have told me as well. She would fall into Scenario Two above, as we have discovered six (6) infringements thus far on her web site or in her collections.
 Six times $7,500 results in a very large number, but we firmly believe this number equates to actual damages we suffer over time from an infringement of this magnitude. Remember, statutory damage claims can go as high as $150,000 per independent infringement if lawsuits come into play.

Our number here is $ 45,000

Lucy would need to come up with $1,500 cash up front. She would have $7,500 to finance/pay over time. That totals $9,000 or 1/5 of our negotiated settlement and claim. I know in today’s economic climate that coming up with extra cash can be really, really tough. However, I also know how important it is for someone who will be considered our “partner” going forward to have some “skin in the game”. I trust you will remember the long conversations (and yes, “debates”) you and I have had on this subject. Believe me, Teri, I know what works best over time. No one in the country has resolved more of these kinds of digital graphic arts content disputes than me and Imageline.

So we agree to acquire the rights to 200 designs that Lucy has produced (and owns outright) and that are not critical to her ongoing business plans. We agree to pay Lucy $200 per design.

So let’s see where that puts us.
 $1,500 cash down payment;
$40,000 worth of goods;
for a total of $41,500.

That means that Lucy will only have to pay the remaining $3,500 (the total claim of $45,000 minus the $41,500 discussed above) to us over time. AND, if that becomes too much of a financial burden, you or Lucy, can tell us that, and we could always pay Lucy $200 per new design to digitize some of the thousands of designs in the Imageline archives to off-set further payments.
 
What could be more fair than this, Teri?

If Lucy were to try and hire an experienced intellectual property lawyer or litigator to assist her on this dispute if it went to court, the retainer fee, alone, would like exceed $10,000. If you don’t believe me on that, I’ll give you a dozen or so people to call and ask. These specialty attorneys are VERY expensive these days. We are fortunate. Since our designs are all copyright-registered with U.S. Copyright Office, we will likely be awarded all attorneys fess as well in court, along with the statutory and/or actual damage awards.

I am trying hard to make this a “no-brainer” decision for your friends and allies, Teri. No haggling. No cussing. No secret hideouts. No bankruptcies. No moving to China. No rants and rages, Just a fair deal under the circumstances and an opportunity for both parties to consider this a win-win proposition over time.

 Please let me know your thoughts.

George

You have 2 designs involved here, XXXXX, so you would fall into the second scenario. 

Today is the day he needs an answer from you as to whether you will agree to his offer.  The first group of these cases are going to the attorneys next week and I will no longer be able to mediate a settlement for you.  If you agree to this, I will need your business name and your contact information as it needs to appear on the settlement documents so they can be drawn up and signed and payment instructions will then also be sent. Let me know if you have any questions.  You are also free to phone me on my business cell at (XXX) XXX-XXXX.


Teri Attempts to Sympathize with Letter Recipient

The letter recipient strongly states their position and intent to Teri. They state that they would be "stupid" to consent to a settlement without consultation and that there would be no reply until they were better informed. Teri seems to back down in this email but still pushes Mr. Riddick's position and encourages settlement.

XXXXXX (letter recipient) wrote:

First off, I do believe in respecting graphics copyrights. It's always been something that I have preached to others.

The images I used were obtained in good faith that they were legal to use for our purposes.  They are from a collection of images that were purchased from a retail store. I have no control over what the publishing company put in that collection and if there are no separate copyrights filed for each single graphic, then there is no way to find out if a single graphic has a copyright on it. I need to see the copyright proof of the image.

2. I would be utterly stupid to consent to paying what is asked without consulting a lawyer or anyone else about this matter. For that matter, where is the proof that these are his graphics? Again, stupid move to pay anything before having proof of copyright infringement. I'm not saying it's impossible, but anyone with a brain should ask for the copyright proof.

If there are only 2 designs involved here, then why the second category? Is the first one not the 1 - 3 designs?

If there is a copyright infringement, then yes, I would expect to have to take part in the agreement and I wouldn't argue about it. But once again, they do need to send out the proof when they are sending out the rest of the documents.

3. Does XXXXXXXXX know that you are contacting other members and turning email addies and other information over to these guys??

You contacted me for my email addy, through XXXXXXXX, then passed it on. That email addy was given to you in good faith.

4. There will be no answer until a lawyer is consulted. I've done a bit of internet research this morning and have come up with a lot of interesting information on this matter.

XXXXXX


Subject: Re: Settlement Offer
Date: Fri, XX XXX 2009 XX:41:21 -0500
From: Teri SXXXXX <teri@XXXXXXx.com>
Reply-To: teri@XXXXXXXX.com
Organization: XXXXXXXXXXXXX
To: XXXXXX <XXXXXXXXXXX@gmail.com>
References: XXXXXXXXXX, XXXXXXXXXX

Hi XXXXXX,

First, I must apologize for my mistake and saying you fell into scenario 2.  You are right, and I am wrong, that 2 infringements fall into the first one.  I am really sorry.  Just trying to do too many things at one time.  So please allow me to correct that right off the bat.

Second, yes, Mr. Riddick has contacted the XXXXXXXXXX and is awaiting their response.  They are aware of what is going on and I'm sure XXXXXX understands full well that if any of these cases end up in litigation, the XXXXXXXX will be held liable as well.  At this point, their cooperation with Mr. Riddick can only benefit them.  And I have no doubt they will, as I am sure you know what a stickler about copyrights and such that XXXXXXX is.  But I am not involved in those discussions.  I am only involved in the ones that I felt made honest mistakes like I did and should not have to be dragged into court.

Third, you are wise to contact an attorney for advice.  Yes, this is a serious matter and yes, it can cost you a great deal of money.   You will find, I'm sure, that to go to court and lose will cost you many times more than settling now with Imageline.  If you lose (and Imageline has more experience in this area than anyone), you will likely have to pay not only your attorney fees and the damages, but also Imageline's attorney fees.  I will arrange to have the registered copyrighted images sent to you for verification so you have the proof.  You are wise to ask for that as well.  However, I will tell you that Imageline has never allowed its images to be digitized and redistributed in any electronic form.  I'm sure Mr. Riddick will want to know what cd you found that image on, as that company may also be held liable. 

I understand how you feel, XXXXXXX, believe me, I've been there.  But I am here to help you work out an agreement you can live with.  If you and I don't work out something, then it goes to the attorneys next week, at which point it's out of my hands.  Imageline's attorneys are asking double the settlement amount ($15,000 per infringement), whereas Mr. Riddick is asking $7500 total.


Teri Expresses Urgency to Settle

Very similar to Mr. Riddick's style of urgent emails, Teri questions why there has been no response and urges cooperation. She apparently believes that Mr. Riddick will soon forward her case (among others) to his attorneys. This email also demonstrates that Teri is actively participating in this process and not a passive participant as she tried to lead me to believe.

Subject: REPEAT - Information you requested and More
Date: Mon, XX XXX 2009 XX:44:11 -0500
From: Teri SXXXXX <teri@XXXXXXXX.com>
Reply-To: teri@XXXXXXXXX.com
Organization: XXXXXXXXXXXX
To: XXXXXXXXXXXX

Hello XXXXXX,

I am resending this last message that I sent on Friday, as I have not heard back from you.  I have not attached the image this time, but will send it again if for some reason you did not get that email.  It's extremely important that you get back to me today on this. I'm not sure why I haven't heard from you, but I hope it's not because you choose to ignore this.  I will not email you again after this, as I don't want to pester you.  But you must understand that working out a settlement through me is the only way you can avoid being taken to court.  Mr. Riddick is doggedly pursuing each and every infringement again his company and every case must be settled or turned over to the attorneys for litigation.  These cases are starting to be turned over this week and he has told me that the ones that do not cooperate will be at the top of the list.  So please, you need to decide what you are going to do.  If I don't hear back from you today, I can only assume you don't want my help.  And that's fine.  This is not something I enjoy doing and it does take a lot of my time.  But you should know that I have already helped one designer to be totally released from two infringement claims and another is in the process of settling for a small fraction (cash portion) of the total claim.  There are ways to settle the claim without having to pay most of it in cash.  Again, I'm willing to help you, but if I don't hear back from you today, then I will withdraw my offer to help as it will be out of my hands once it goes to his attorneys.

I have gotten the information you requested regarding the original Imageline image and the copyright registration of that image.  I have attached the original WMF file to this message.  It is registered with the US Copyright Office in the Imageline MasterGallery (VAXXXXXXXXXXX) filed XXXXXXX XX, 1996.  Here's the direct link: http://xxxxxxxxxxxxxxxxxxxxxxxx

If that link doesn't work, go to http://www.copyright.gov/ , then Search Records, then Search the Catalog, then put the number in and search by Registration Number. Does that help?

Also, XXXXXXX, I know you are upset with me for getting your email address.  I tried emailing you from your site and it bounced back.  I also emailed the address listed for your domain registration and it bounced back.  If I hadn't gotten your email address, Mr. Riddick would have probably contacted your hosting company directly, or the XXXXXXXXXX folks, with a Cease & Desist against them as well and this whole thing could be much worse and much more embarrassing than it already is.  Remember, I do know how you feel.  But please know that I am only trying to help you out here.  The ONLY people I offered to help in this situation are fellow XXXXXXXXXX vendors, as I know we have all been thoroughly vetted and are upstanding, honest, hard working digitizers.  You are one of several at XXXXXXXXXXX who finds themselves in this position.  If you don't want my help, that's fine with me.  I don't really  know you and you don't know me, either.  But I can tell you that I have already managed to have one vendor totally and completely released of any infringement claims.  Another one is making a settlement that will benefit her in the long run.  You are certainly free to go the attorney route, but like me, you won't win the case with the evidence they have.  Are you willing to risk thousands of dollars in attorney fees (both sides) and damages and court costs if you lose?  And how can you possibly win if you did not draw the design yourself?  It's pretty obviously the same image that you used.  Only the lettering is different.  Not only that, but XXXXXXXXX can be held liable and your customers can also be dragged into this.  But that's your decision and choice to make.  For me, it was stressful and difficult, but much preferable to settle than go the other route.  This company will not drop this claim.  They mean business.  If you did research on them today, you will see that they are very good at protecting their intellectual property.  I do hope you make the right decision here.  And let me know asap what you decide, as I don't think you want to end up in that first group of cases going to the attorneys next week.



Single Trail of Emails to Another Letter Recipient

Below is a single trail of emails to one letter recipient. Notice the progression in the tone of emails. Mr. Riddick throws a lot of threats and dialog around until there is silence. That is when he practically begs for a response at the end and tries without success for a "settlement".

From: George Riddick
To: contact@xxxxx.com
Cc: gpaine3@yahoo.com
Sent: XXXXday, XXXXXber 29, 2008 5:XX AM
Subject: URGENT - Copyright Infringement Notice - 3rd Notice

CONFIDENTIAL – September 29, 2008

www.xxxxx.com

Imageline has uncovered copyright infringement of our proprietary and copyright-registered electronic graphic arts content (clip art illustrations, design templates, and/or animations) on the above web site.

We have been unable to verify the correct detailed contact information we need to send you the materials we have prepared to support these claims.

Please verify receipt of this e-mail and send us the required contact information (executive officers, owners, corporate counsel, copyright agent, facsimile numbers, e-mail address(es), telephone number(s), and physical mailing address (no P.O. boxes) immediately so that we can provide you further information.

If you own or are associated with any other web sites where the Imageline graphic arts content may be displayed, please identify such sites in your response so that our research organization can do further investigations into these serious copyright violations.

If you choose to get your attorney involved with this issue at this point in time, please have he/she contact me directly at griddick@imageline2.com. I will then decide to what degree our attorneys need to be involved. At this point, I am simply gathering facts and trying to determine whether you and your company intend to cooperate with us in the investigation and appropriate resolution of this extremely serious matter.

At this point in time, we would appreciate all communications to be via e-mail.

This is a very URGENT matter, so please respond to us immediately.

Thank you.

George Riddick
Chairman/CEO
Imageline, Inc.
9533 Kings Charter Drive
P.O. Box 6275
Ashland, Virginia 23005

804-525-6941 Voice
804-525-6943 Fax


From: George Riddick
To: xxxxx.com'
Sent: XXXXday, XXXXXXber 29, 2008 6:XX AM
Subject: RE: URGENT - Copyright Infringement Notice - 3rd Notice

Wait a second, Mr. xxxxx. I thought you indicated that the first time you heard from us was this morning. If that is the case, why are now claiming that our web site has been under construction “since its inception”? Was your first response simply a smokescreen? No wonder you refuse to identify yourself.

It appears to us that you are simply making up excuses so that you can continue your unlawful use of our proprietary, copyright-registered digital images. That constitutes willful copyright infringement by even the most conservative analysis by xxxxx, and we will gladly turn this over to our outside attorneys if that is the path you prefer us to take.

Please advise ASAP. Time is of the essence on this matter.

George Riddick
Imageline, Inc.

P.S. I strongly suggest that you consult a competent Intellectual property attorney before making this important decision fro yourself and your company.


From: George Riddick
To: xxxxx.com'
Cc: gpaine3@yahoo.com
Sent: XXXXXday, XXXXXber 03, 2008 9:XX AM
Subject: RE: URGENT - Copyright Infringement Notice - 3rd Notice

Dear Mr. xxxxx,

Please immediately remove all of the attached copyrighted Imageline images from your web site immediately, send us a complete and thorough listing of all of your customers who were provided with products that contain any of these proprietary images, give us the e-mail addresses of all prospective or existing xxxxx customers who visited your web site and may have downloaded one of our clip art images from your clip art gallery, and put forward your proposed resolution to this very serious copyright infringement violation (including appropriate compensation to Imageline) as quickly as you possibly can.

I would be happy to send you a rough draft copy of our standard Settlement and Release Agreement, which we have used over 100 times over the past few years (unfortunately).

We will attempt to resolve these copyright infringement issues amicably with you, or we will turn this serious issue over to our contingency attorneys and see what happens from there, at your option.

If, for any reason, you contest our exclusive ownership rights to any of the attached images, please let us know that immediately, as well. Thank you.

Hopefully, we will hear back from you yet today.

George Riddick
Imageline, Inc.


From: George Riddick [mailto:griddick@imageline2.com]
Sent: XXXXXday, XXXXXber 28, 2008 2:XX PM
To: 'contxxxxxact@xxxxx.com'
Subject: Flagrant copyright violations

Dear copyright infringer:

Please identify your outside counsel for us immediately. On November 1, 2008, Imageline will begin the process of turning over all unresolved infringement cases to our new contingency law firms, filing the appropriate lawsuits, and serving papers on you and the other officers and directors of your company, as well. We would be happy to work through your outside attorneys if you provide us with the requested information in a timely manner.

Please also provide us with the complete name and physical mailing address for each of your officers and/or directors that should be served at any location other than your company headquarters location, as identified on your web site and/or the “whois” international domain registration database.

We will also seek identity of all of your customers and prospective customers who visited your web site(s) during the time that any Imageline infringed illustration or design was displayed. As I am sure you know, these end user customers are potentially liable for yet additional infringement and/or CMI removal claims. We intend to resolve all of these issues over the coming months.

You have had more than ample opportunity to resolve this issue peacefully and professionally, and have yet chosen not to do so. We can only assume you must feel we are bluffing. Well, guess what? We do not bluff. If we did, we would never be able to convince anyone to take us seriously.

We have selected four new aggressive and contingency based laws firms to work with us in this Internet anti-piracy campaign and dedicated legal efforts. For the most part, cases will be divided up by territorial regions, and, in some cases, based on the industry and customer set you serve.

Please provide us with the required contact information as soon as possible.

Thank you.

George P. Riddick, III
Chairman/CEO
Imageline, Inc.
P.O.Box 6275
Ashland, Virginia 23005

804-525-6941 – voice
804-525-6943 – fax
griddick@imageline2.com


From: George Riddick
To: xxxxx@xxxxx.com
Sent: XXXXday, XXXXXber 14, 2008 11:XX AM
Subject: FW: Flagrant copyright violations

Please acknowledge receipt of the below referenced e-mails. Thank you.

Imageline, Inc.


From: George Riddick
To: xxxxx@xxxxx.com
Cc: ggray528@yahoo.com ; gpaine3@yahoo.com
Sent: XXXXXday, XXXXXber 18, 2008 10:XX AM
Subject: Final attempt to settle this infringement dispute amicably - CONFIDENTIAL

CONFIDENTIAL – FOR THE PURPOSE OF SETTLEMENT DISCUSSIONS ONLY

Hello xxxxx,

By now you certainly have me designated as the copyright “kid who cried wolf”. We have been late implementing all of our plans. I really hate it when this happens. The primary reason for this 2008 delay has been that we wanted the new copyright laws (and a new administration, for that matter) to be in place before we officially launched the Copyrights: Code (Red) anti-piracy campaign we have been working on now for the past two years, and began filing lawsuits against those who choose to not to settle.

As I have told you all along, one of two things will happen with all the companies we have discovered infringing our proprietary works (and there are hundreds of them ... unfortunately!) since January of 2007:

  1. We will settle amicably (settlement releases both the company, its officers and directors, and all of its infringing end user customers); or
  2. We will file a lawsuit with one of our new contingency law firms (we now have top notch IP law firms retained in Atlanta, Washington D.C., Lake Tahoe, and Los Angeles, with another one almost set to go for Canada), and go for the maximum remedies available to us under the law, both civil and criminal, if those, too, apply.

Well, guess what? We are finally ready to launch. On Monday of this week we met with Marybeth Peters (Register of Copyrights) and Marybeth’s “right hand woman”, Maria Palante, for three hours in Washington D.C. We are working with the U.S. Copyright Office to shape new legislation that makes it even harder for Internet piracy to survive, let alone thrive. All companies interested in the protection of their copyrighted digital property available over the Internet will benefit from our efforts.

While in Washington this week, we also briefed the Executive Directors of both the Copyright Alliance (www.copyrightalliance.org) and Software and Information Industry Association (www.SIIA.net), both of which are involved in extensive anti-piracy activities and include Imageline among their executive members, regarding our new Copyrights: Code (Red) campaign. They response we have gotten thus far is very encouraging.  

Hear are some of the recent and upcoming events that are shaping our priorities and enhancing our confidence

- The ’Pro-IP Act’ will be implemented starting in January. (more resources available to chase down pirates and stricter penalties for infringement)
- The proposed ‘Orphan Works’ legislation will now include some additional clauses designed specifically to protect visual artists.
- New programs are coming out in 2009 that will force web site operators to choose between copyright compliance or severe consequences.
- A new district court ruling just out from Minnesota adds precedent for the enforcement of Section 1202 rights for copyright holders of between $2,500 (minimum) and $25,000 (maximum) per image (over and above any copyright infringement claims), regardless of registration status (a HUGE win for digital graphic artists and one that is causing us at Imageline, and a few of our select partner web sites, to adjust our settlement per image numbers by over 100% upward to $6,500 per infringed image).

Sir, you DO NOT want this infringement case with xxxxx.com and your other web sites to go to court. Believe me. The results, and exposure, could destroy your companies and your reputation. You know that. We have never taken a case to court yet that didn’t cost our opponents hundreds of thousands of dollars in legal fees, alone. And we have NEVER lost a case. You know you have no valid defenses under the copyright laws of this county.

Why have you not considered settlement more carefully? Your actions make no sense to me at all. I simply do not understand your logic, unless, of course, you concluded that this east coast “kid who cried wolf” was bluffing. Well. We are not. I can assure you of that.

I am a fair-minded entrepreneur. I know how difficult it is to survive out there in the jungle … and especially the Internet jungle. I am often creative in the settlements I agree to. Our lawyers are not. I won’t allow them to be. If you would like to attempt to settle this dispute amicably before year end and avoid the cost of a protracted lawsuit, please give me a time either later today, tomorrow, over the weekend, or on Monday where you would be available to talk.

Thank you. I hope to hear back from you today. If I don’t I will assume that is a clear indication of your desire that we proceed with a lawsuit against you and your organizations as discussed now for quite some time.

Sincerely,

George

George Riddick
Imageline, Inc.


From: George Riddick
To: xxxxx.com'
Sent: XXXXday, XXXXuary 18, 2009 9:00 AM
Subject: RE: URGENT - Copyright Infringement Notice - 3rd Notice

Good morning, xxxxxxxxxx,

We have finally reached the point here at Imageline (after almost two years of research and preparations) where we can comfortably turn all of our outstanding infringement disputes over to our contingency attorneys and get back to design work, which I prefer. We will be announcing a major library acquisition from Getty Images within the next two weeks.

We now have retained four law firms around the country, and will be adding one more here in the States and one in Canada soon. Eleven (11) lawsuits will be filled in February and March, along with the official announcement of our long overdue Copyrights: Code (Red) consumer awareness anti-piracy campaign.

We are looking for more allies to support this campaign. We have finally gotten the approval from our attorneys to list the infringing web sites online, which I personally think will be a big help. The combination of the new Pro-IP Act and some other legislative activity I have been involved with up here in Washington has given us the impetus we have been waiting for, but now we are starting to worry a bit about statute of limitations issues. Unfortunately, hundred of companies are now included in the Copyrights: Code (Red) infringement listings.

As I have told you all along, we do not drop any infringing issues we discover without either an executed ‘settlement and release agreement’ or a legal filing. Consistency is the ONLY way to stop digital piracy, and we know that for sure. Now I think the key people in Washington understand that as well, after almost ten frustrating years of slack enforcement of our copyright laws.

We continuously monitor web sites once we discover infringing activity. I will tell you that we have not seen any new infringements on your various web sites. We applaud you for that. This industry needs all the pro-copyright proponents we can get!

xxxxx is on the attorneys’ active list, as you know. However, I want to shorten the list a bit if I can. I am willing to drastically reduce our settlement standards from the number I proposed to you quite a while back to a one time payment of $15,000.00 to release all claims. You won’t even be able to retain a decent IP attorney for that. Please don’t make the mistake of calling my bluff. If you prefer a court battle with Imageline, that is fine, however. Just let me know. Playing more guessing games doe not benefit either one of us.

Please show the professional courtesy to let me know one way or the other today. I am really trying to stretch our rules and reach out to you on this, but since we have never met, you may interpret things differently. I remain convinced that our determination and tenacity over the years is going to benefit all of us in the digital graphic arts content arena.

I look forward to hearing back from you today.

George

George Riddick
Chairman/CEO
Imageline, Inc.  


From: George Riddick
To: xxxxx.com'
Cc: gpaine3@yahoo.com
Sent: XXXXXday, XXXXuary 19, 2009 6:XX PM
Subject: FW: URGENT - Copyright Infringement Notice - 3rd Notice

xxxxxxxxxx
Please accept or reject the enclosed settlement and release proposal that was sent to you earlier this week. This is our final offer. Please do not send us a counter-proposal under terms and conditions.

Thank you.

Imageline, Inc.


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