VIA FACSIMILE & REGULAR MAIL
(805) 522-6642

Mr. Boris Pribich
P.O. Box 1154
Simi Valley, CA 93062

Re: Conflict with National Alliance (American Defense League
        (Our Ref. AFL TC 01/0561 11)

Dear Mr. Pribich:

We are intellectual property counsel for the Anti-Defamation League of B'nai B'n'th, owner ofthe trademark ADL. As you may be aware, our client has been using this trademark for nearly nine decades in connection with its educational services in the field of civil rights and combating prejudice and racism. Our client is also the owner of a federal trademark registration for "ADL Anti-Defamation League" which is valid, subsisting and in full force and effect. Moreover, our client's Registration No. 1,776,315 for the mark is incontestable and serves as prima facie evidence of our client's exclusive right to use ADL in connection with the services set forth in that registration.

Through decades of our client's extensive nationwide use and promotion of its mark -- including an Internet site -- the public has come to identify ADL exclusively with our client and exclusively with its educational services in the field of combating bigotry.

It has come to our client's attention that you are using our client's ADL mark in connection with the name of your organization, as well as in connection with your website located at www.americandefenseleague.com. As we understand it, your organization is dedicated to "documenting how the Jewish community is destroying our investment in America."

Your unauthorized use of our client's federally registered trademark is unlawful, and constitutes trademark infringement, unfair competition and dilution under the Lanham Act and applicable state and common law. Your conduct cannot be explained away as innocent. Clearly, your use of our client's mark and is knowing, willful and done to trade on our client's rights and to capitalize on the reputation and popularity of its mark. Indeed, use by you of our client's mark in connection with your organization will undoubtedly mislead and confuse the public into believing that our client has sponsored, endorsed, or is in some way affiliated with your organization and your web site.

Please be advised that your actions violate Sections 32(l), and 43(a) of the U.S. Trademark (Lanham) Act of 1946, 15 U.S.C. §§ 1114(l), 1125(a), as well as applicable state law, thereby entitling our client to seek all applicable remedies, including, but not limited to, a lawsuit seeking injunctive relief, monetary damages, costs and attomeys' fees.

In view of the above, we demand on behalf of our client that you cease all use of the ADL mark, or any similar mark, or any mark or phrase comprised of the ADL mark, on or in connection with any business, services or goods. Compliance with this request requires you to stop referring to your organization as "ADL" and to remove any references to the ADL mark from your web site. We ask that you confifm within ten days of receipt of this letter, that you will comply with these requests, or we will recommend to our client that it consider taking action necessary to protect its invaluable rights to its mark. It is our sincere hope that we can resolve this matter quickly and amicably.

This letter is written without waiver of or prejudice to our client's rights or remedies, all of which are expressly reserved.

Very truly yours,

[signature]

Michelle P. Foxman

MPF/cmw

cc: Jill Kahn Meltzer, Esq.

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