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Letter dated 14 March 2000 Letter dated 21 March 2000

The Royal Bank of Scotland plc letter to Douglas Cosbert dated 21 March 2000

Extract of Letter:

From: The Royal Bank of Scotland plc

To: Douglas Cosbert

Date: 21 March 2000

Dear Sir

In relation to your comments we are not concerned with simply any domain name containing the letters 'r', 'b', and 's' and therefore we have no issue with the other domain names which you have registered containing these letters.

In respect of the two domain names referred to in our letter of 14 March, following our recent acquisition of National Westminster Bank plc we are concerned that the sequence of letters 'r', 'b', 's, and their use in combination with the letters 'n', 'w'. In our view these domain names give rise to the potential to trade unlawfully upon the enlarged Bank's reputation. The recent court cases in this area clearly state that it is unlawful to register domain names with the intention of trading upon the another's reputation or transferring the name to someone who might. Given the nature of the domain names in question and the fact that these names were registered during the height of the publicity surrounding the take-over of National Westminster Bank plc the clear inference is that these domain names were registered with precisely this intention.

In the circumstances we would reiterate our request that you transfer the domain names rbsnw.co.uk and rbsnw.com to us for which we will reimburse your reasonable and necessary costs incurred in registering the domain names and carrying out the transfer, provided that these are fully vouched. In addition, we are prepared to offer you the sum of £500 on an ex gratia basis. Please note however, that we consider this offer to be fair and reasonable in the circumstances and it is not intended as a basis for negotiation.

We look forward to hearing from you with 7 days from the date of this letter.

This letter is written without prejudice to our whole rights and pleas in this matter and may not be referred to or founded upon in any subsequent court proceedings.

Yours faithfully

Aileen Rose

Solicitor






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