Date: Sun, 23 Jul 1995 15:56:23 -0700 (PDT) From: Helena Kobrin Subject: To: spurgeon@is2.nyu.edu Message-Id: Dear Mr. Spurgeon: I represent Religious Technology Center ("RTC"), the owner of the confidential Advanced Technology of the religion of Scientology, and the holder of exclusive rights under the copyrights applicable to the Advanced Technology materials. Among these copyrighted and confidential materials are the Advanced Technology materials of a certain level known as "Operating Thetan Section VII," "OT VII." I am informed that you have posted on alt.religion.scientology a portion of the OT VII materials without authorization of RTC, which, of course, would not have given such authorization had it been requested. Your action violates RTC's legal rights in that it is the unauthorized making of an electronic copy of the copyrighted material and the unauthorized disclosure of trade secrets materials. Your posting constitutes violations of applicable copyright laws and trade secret misappropriation entitling our client to damages and an injunction. It is essential that you take immediate and effective action to remove the unauthorized copy from the Internet, and that you refrain from any repetition of this or similar acts in the future. You are also to delete these and any other Advanced Technology materials from your hard drive and any floppy disks and to destroy any hard copies you have made. In addition, your downloading of the copyright and trade secret materials also violates laws prohibiting copyright infringement and trade secret misappropriation. Your use and disclosure of these materials is *not* fair use. No case in the United States has ever found fair use to apply to copying unpublished materials, as even Dennis Erlich's attorney had to admit in open court. There is no fair use defense to trade secret misappropriation. I will expect an immediate response from you with a statement of your willingness to comply with these demands. If you do not comply immediately, we will have no other recourse but to initiate legal action to compel compliance. Very truly yours, Helena K. Kobrin