Date:          Thu, 21 Nov 1996 22:28:38 -0800 (PST)
  From:          Helena Kobrin <hkk@netcom.com>
  Subject:       Unauthorized use of copyrighted material
  To:            nettguiden@nettguiden.no


  Dear Mr. Robbestad,

       I represent Religious Technology Center ("RTC"), the owner
  of the confidential Advanced Technology of the Scientology
  religion and the holder of exclusive rights under the copyrights
  applicable to the Advanced Technology materials.  The Advanced
  Technology materials are confidential, unpublished, copyrighted
  works.  RTC's works include, among others, the individual works
  comprising levels known as "OT II," "OT III," and "NOTs."

       I have been informed that one of your subscribers, Andreas
  Heldal-Lund, has placed certain OT II, OT III, and NOTs works on
  his web site at the following web pages: 

        http://www.nettguiden.no/clambake/
        COS-THE_THRIVING_CULT_OF_GREED_AND_POWER_.html

        http://www.nettguiden.no/clambake/HUBBARD.html
        http://www.nettguiden.no/clambake/WAS.html
        http://www.nettguiden.no/clambake/A.html
        http://www.nettguiden.no/clambake/PATHOLOGICAL.html
        http://www.nettguiden.no/clambake/LIAR.html
        http://www.nettguiden.no/clambake/AND_A.html
        http://www.nettguiden.no/clambake/MADMAN.html

        http://www.nettguiden.no/clambake/SCIENTOLOGY_IS_A_HOAX.txt

        http://www.nettguiden.no/clambake/otleeroy.txt

        http://www.nettguiden.no/clambake/otbork.txt
 
       The last two versions are in an encoded style, but decipher
  into some of the same works.

       You have been informed by telephone by Allan Cartwright that
  these works have been placed onto this web site without the
  authorization of my client.  The works are registered with the US
  Copyright Office under registration numbers TXu 303388; TXu
  290496; and, TXu 257326 and TXu 257527.  

       These postings violate the copyright laws of the United
  States and Norway.  Because these postings are on your site, they
  are copyright infringements for which you can be held liable.  I
  therefore request that you remove these materials immediately. 

       We are currently involved in litigation in the United
  States, Holland and Sweden over the same and similar materials in
  several lawsuits.  A preliminary injunction based on copyright
  infringement is in place in three of those suits in the United
  States District Court in San Jose, California.  And a United
  States District Court in the state of Virginia granted summary
  judgment in favor of my client, related to copyright infringement
  of some of these works.  

       The court in Holland has recognized that similar materials
  are copyrighted, and the defendants in the Dutch case have taken
  off their postings of the copyrighted materials in question in
  that case.  And in Sweden, the court has issued an injunction
  against the defendant who posted these works to the Internet.

       The courts in California and Holland have both ruled that an
  access provider which is informed that infringement is occurring
  through its system and does nothing to stop it can be liable for
  contributory infringement.

       We are not seeking to become involved in litigation, but we
  will take all necessary measures to protect my client's
  intellectual property rights.  The infringements on your site are
  a serious situation.  We presume that you do not want your system
  to be used as an instrumentality of infringement, and we hope
  that we can resolve this amicably.

       Please confirm that you have removed the copyrighted
  material as requested above. I must urge you that speed in
  dealing with this situation is critical in light of the fact that
  unpublished materials are involved.

                                     Sincerely,
                                     Helena K. Kobrin