Chuck Williams Email to WWE. Number One:
From: RockinRebel1@aol.com
Lauren Dienes-Middlen (WWE’s VP of Legal and Intellectual Property [WWE’s Trademark Lawyer])
Sent: 2/27/2014 1:29:35 P.M. Eastern Standard Time
Subj: Fwd: TRADEMARK and statement
Lauren,
I spoke to my lawyer and I am sending you this statement.
I never gave permission/consent to Todd Gordon, Paul Heyman or anyone else involved at the time I worked for ECW or signed any documents to allow my name and video footage to be aired. I also have had the name Rockin’ Rebel since I started wrestling in 1988 and had it also trademarked I feel that I should be compensated or be paid royalties for use of MY name and footage.
Respectfully,
Chuck Williams
2-27-14
| Word Mark | ROCKIN’ REBEL |
| Goods and Services | IC 041. US 100 101 107. G & S: Entertainment services, namely, wrestling exhibits and performances by a professional wrestler and entertainer. FIRST USE: 1988 1200. FIRST USE IN COMMERCE: 19881200 |
| Standard Characters Claimed | |
| Mark Drawing Code | (4) STANDARD CHARACTER MARK |
| Serial Number | 85279209 |
| Filing Date | March 28, 2011 |
| Current Basis | 1A |
| Original Filing Basis | 1A |
| Published for Opposition | August 9, 2011 |
| Registration Number | 4045041 |
| Registration Date | October 25, 2011 |
| Owner | (REGISTRANT) Williams, Chuck INDIVIDUAL UNITED STATES 302 North Five Pts Road West Chester PENNSYLVANIA 19380 |
| Type of Mark | SERVICE MARK |
| Register | PRINCIPAL |
| Other Data | The name “Rockin’ Rebel” identifies a living individual whose consent is of record. |
| Live/Dead Indicator | LIVE |
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Chuck Williams Email to WWE. Number Two:
From: RockinRebel1@aol.com
Sent: Friday, March 14, 2014 3:12 PM
To: Krasik, Curtis B. (WWE Lawyer at KL Gates)
Subject: Re: WWE
Mr. Krasik,
I left you a voice mail explaining all the details.
Respectfully,
Chuck Wiliiams
610-986-XXXX is my number to call me.
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WWE Email to Chuck Williams. Number Three:
In a message dated 3/14/2014 4:40:30 P.M. Eastern Daylight Time, (Curtis Krasik a WWE Lawyer) writes:
Mr. Williams:
I am in receipt of your voicemail message and your email below. I understand from your prior correspondence with Lauren Middlen of WWE that Joseph XXXX, Esq. is representing you in this matter. I, therefore, am not comfortable speaking to you directly unless you advise that Mr. XXXX is not in fact representing you in this matter or Mr. XXXX advises that he consents to my speaking to you directly. Thank you.
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Chuck Williams Email to WWE. Number Four:
From: RockinRebel1@aol.com
Sent: Thursday, March 20, 2014 5:04 PM
To: Krasik, Curtis B. (WWE Lawyer)
Subject: Re: WWE
I have not heard from you and wanted to touch base and see how we can resolve this matter.
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WWE Email to Chuck Williams. Number Five:
From: ( Curtis Krasik a WWE Lawyer)
To: RockinRebel1@aol.com
Sent: 3/24/2014 4:36:34 P.M. Eastern Daylight Time
Subj: RE: WWE
Mr. Williams:
There is nothing for us to discuss, much less something to resolve. Assuming arguendo that you even possess certain rights in the name “Rockin Rebel” in the first instance, the alleged use of that name to truthfully and accurately identify performances by you on behalf of ECW does not violate any legal rights. Please advise if I have misunderstood the nature of your claim. But, otherwise, I trust that this matter is closed.
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WWE Email to Chuck Williams. Number Six:
In a message dated 3/25/2014 11:49:37 A.M. Eastern Daylight Time, ( Curtis Krasik a WWE Lawyer) writes:
Mr. Williams:
I am in receipt of your email below and the voicemail message that you left for me last night. I would prefer that our communications be in writing regarding this matter.
As I advised you yesterday, irrespective of any rights you claim to possess in the name “Rockin Rebel,” the alleged use of that name by WWE to truthfully and accurately identify performances by you on behalf of ECW does not violate any legal rights. Your claim that WWE previously elected to stop referring to a different wrestler on Tough Enough as “Rockin Rebel” after you complained is completely irrelevant to WWE’s alleged use of “Rockin Rebel” to refer to you. If you, in fact, possess rights in the name “Rockin Rebel,” there most certainly is nothing conceivably false, misleading, or confusing about referring to you and your performances by that name. As a matter of law, WWE is fully authorized to truthfully and accurately refer to and/or describe performances by you on behalf of ECW by the name under which you actually performed. Indeed, there would be no other way to truthfully and accurately refer to and/or describe such performances without using the name under which you performed. Once more, let me be clear, you are not entitled to any compensation and will not receive any compensation from WWE. We consider this matter to be closed.
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Chuck Williams Email to WWE. Number Seven:
From: RockinRebel1@aol.com
To: Krasik, Curtis B. (WWE Lawyer)
Sent: 3/25/2014 2:12:35 P.M. Eastern Daylight Time
Subj: Re: TRADEMARK and statement
WITH MY NAME TRADE MARKED IS IS UNLAWFULL TO “USE” MY NAME WITHOUT MY PERMISSION CHECK YOUR FACTS. LOOK INTO DIGITAL COPYRIGHT MILLENIUM ACT VIOLATIONS TOO….I RETAINED A LAWYER AND WILL BE SUEING WWE AND MY ATTORNEY AGREED IT IS OK TO GO PUBLIC WITH THIS MATTER AS ALL I WILL BE DOING IS STATING THE FACTS AND MAKING IT PUBLIC RECORD TO TMZ ,TWITTER AND “ALL” THE PRO WRESTLING DIRT SHEETS.HOPE YOU AND THE WWE ARE HAPPY ABOUT THIS BECAUSE IT BE A SHAME TO MAKE ALL MY E MAILS PUBLIC …CAUSE ALL THIS WILL DO IS NOT LOOK GOOD FOR THEM WITH WRESTLEMANIA JUST AROUND THE CORNER..I TRIED TO BE FAIR AND RESPECTFULL WITH THIS MATTER BUT WITH YOU AND LAUREN NOT PROPERLY COMMUNICATING WITH EACH OTHER AND MYSELF LET THE RECORD SHOW IT WAS UNPROFESSIONAL ON YOU/WWE PART. THIS ISN’T MY FIRST RODEO I KNOW THE BUSINESS BETTER THAN MOST PEOPLE DO AND MY LEGAL RIGHTS AS WELL. DON’T CONTACT ME ANYMORE UNLESS VINCE AND THE WWE WANT TO SETTLE THIS RESPECTFULLY.
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From:RockinRebel1@aol.com
To:Krasik, Curtis B. (WWE Lawyer)
Sent: 4/4/2014 4:11:15 P.M. Eastern Standard Time
Subj: Re: TRADEMARK and statement
I would like for you to know of your rude and unprofessional behavior that after speaking with my attorney,myself and my lawyer will be reporting you to the disciplinary board for your conduct pertaining to this matter.
Editors note: The actual email addresses of the WWE lawyer(s) have been altered to reflect only their name and identifier in (parentheses). It also appears a few messages have may been lost in the thread but they are not present because we do not have them. We also express no legal opinion as to the merits of the respective sides (indeed we do not have all the facts that may have been needed) and leave it to the reader to draw their own conclusions.