LINKEDINCOMMENTMORE

Thank you for sending me the images and your quick response. For ease of reference, I will refer to the fleur de lis used by Til We Meet Again ('TWMA') as the 'redesigned' fleur de lis.

The 'redesigned' fleur de lis used by TWMA is confusingly similar to the Saints' federally protected trademarked fleur de lis image. No reasonable consumer will be able to detect any of the purported differences that you outline in your email.

Further, TWMA's commercial juxtaposes the black and gold casket with the LSU casket so that both conjure an association with sports teams, particularly given the sounds of crowds chanting in the background.

Thus, the argument that TWMA's black and gold casket is 'not in any manner advertised as being a Saints casket' is undercut by (1) TWMA's use of a 'redesigned' fleur de lis that is substantially similar to the Saints' protected trademarks, (2) the juxtaposition of the black and gold casket with the LSU casket and the crowd chanting noises, (3) the use of the black and gold color scheme in the both the 'redesigned' fleur de lis and the casket, itself.

Accordingly, and for the reasons outlined above, the Saints request that TWMA immediately cease use of the 'redesigned' fleur de lis -- or any variation of a fleur de lis that is substantially similar to the Saints' federally protected trademark -- and use of the black and gold color scheme in connection with this casket. This request includes removal of the commercial and/or image of the casket from WWLTV, YouTube and any other website and social media.

I look forward to your response.

p Sincerely,
Lesli

LESLI D. HARRIS
Stone Pigman
Walther Wittmann LLC

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